The ecodesign regulation on local space heaters 2024/1103 excludes air heating products from its scope. Air heating products are defined in 2024/1103 as an air heating product as defined in Article 2, point (1), of Commission Regulation (EU) 2016/2281. This is not the same definition as in the repealed Regulation (EU) 2015/1188, which defined air heating products as a product providing heat to an air-based heating system only that can be ducted and is designed to be used while fastened or secured in a specific location or wall mounted which distributes the air by means of an air moving device in order to reach and maintain a certain level of human thermal comfort within an enclosed space in which the product is situated. By specifying that air heating products must be fastened or secured, small portable heaters such as fan heaters lied in the scope of Regulation (EU) 2015/1188, under electric portable local space heaters. This is relevant because under Regulation 2016/2281, fan heaters would be subject to a seasonal space heating energy efficiency threshold of 31%, whereas in Regulation (EU) 2015/1188 the energy efficiency threshold for portable local space heaters is 36%, thus requiring an electronic control which would not be necessary to comply with Regulation 2016/2281. It is then proposed to amend Regulation 2024/1103, so that fan heaters are back in the scope of the requirements for local space heaters.
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