The main difference between an air heating product and a local space heater is the location of the heat generator.
Local space heaters fall under the scope of Regulation (EU) 2015/1188. The heat generator of a local space heater is situated in the space that is heated, see Art.2(1) of Regulation (EU) 2015/1188.
Excluded from the scope of Regulation (EU) 2015/1188 are air heating products. According to that regulation, an air heating product’s heat generator delivers its heat via an air based heating system. Here, it is the air based heating system that is at least partly situated in 12 the space that is heated, see Art.2(23) of Regulation (EU) 2015/1188. As an example, when the air based heating system is a duct with a fan, this duct will supply the heated air from the heat generator (not situated in the space that is heated) to the space that is heated.
An additional specification is that to be excluded from the scope of Regulation (EU) 2015/1188, air heating products need to be fastened or secured in a specific location or wall mounted.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
According to its article 1.(j), Regulation (EU) 1186/2015 with regard to the energy labelling of local space heaters does not apply to sauna stoves.
According to Article 2, definition (15), a sauna stove ‘means a local space heater, incorporated in, or declared to be used in, dry or wet sauna's or similar environments’. As a consequence, sauna cabins are not in the scope of Regulation (EU) 1186/2015 and consequently do not have to be entered into EPREL. The same is a priori true for infrared cabins, which can be considered to be part of the ‘similar environment’ in the above definition.
However, a registration would be necessary for local space heaters used in the sauna and/or infra-red cabins, if they could also be used in another type of environment (such as a standard room heating means for room heating in a dwelling).
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
No. Ecodesign requirements need to be fulfilled with all fuels the product is marketed to be operated with.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
If the programmable external user interface includes additional functions not featured by the control in the product which are necessary for the product to comply with the ecodesign requirements, , the instruction manuals for installers and end-users, as well as free access websites of the manufacturers, their authorised representatives and importers, need to clearly mention that the unit needs to be complemented with a control providing the claimed functions in order to be compliant with the mandatory ecodesign requirements. The manufacturer may then apply the F(2) or F(3) correction factors allowing the placing of the product on the market.
The product has to be equipped with all necessary components to be able to use these function(s). Offering these functions only as options to be purchased separately and installed by the customer is not sufficient for applying those correction factors.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Yes. Regulation (EU) 2024/1103 regulates the placing on the market of separate related controls, namely controls intended to be used with local space heaters in scope of this Regulation but placed on the market separately. Manufacturers are allowed to place on the market local space heaters without control and claim the corresponding correction factors making the product compliant with the Ecodesign requirements.
However, the product has to be equipped with all necessary components to be able to use these function(s). Offering these functions only as options to be purchased separately and installed by the customer is not sufficient for applying those correction factors.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
The heat output is independent of net or gross calorific value. The difference between net and gross calorific value affects the fuel input (for example energy efficiency or emission requirements).
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
The classification of the local space heater is dependent on its intended use and how it is marketed (in the catalogues, leaflets, etc.). If the product is marketed as a local space heater that can be used either as a portable or as a fixed local space heater, then it has to comply with both requirements.
In practice, this means that the product has to comply with the most stringent requirements, i.e. those of the fixed local space heaters.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
According to the definitions of ‘electric fixed local space heater’ and ‘electric portable local space heater’ these two types are mutually exclusive, so no product can be required to meet requirements for both categories.
Local space heaters sold with features which can be used to fix it on a wall or a fixed appliance sold with a kit of castors fall under the description are 'designed to be used while fastened or secured in a specific location or wall mounted' even though they have an alternative possible use. They are therefore electric fixed local space heaters.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
No. How the product is marketed is not sufficient. The design (technical characteristics and specifications) of the product should be able to distinguish the product from those intended for indoor space heating to reach and maintain a certain thermal comfort of human beings.
For example: a local space heater marketed as ‘frost protector’, but equipped with a thermostat that can be set for temperatures that are compatible with the thermal comfort of human beings, should be considered a local space heater in the scope of the regulation (unless other technical characteristics and specifications would indicate otherwise).
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Yes. The definition of 'with electronic room temperature control plus day timer' in Regulation (EU) 2024/1103 does not specify manually/automatic, or with/without display.
Please note that the unit should be programmable; a predefined fixed factory setting does not “allow the setting of timing and temperature" and therefore does not comply with the definition.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
No. The standby mode provides only one or more of the following functions:
- a reactivation function, or reactivation function and indication of enabled reactivation function;
- reactivation function through a connection to a network (‘networked standby’);
- information or status display.
Any mode that provides other functions is not considered as standby mode. The function whereby the product is able to provide heat to the room according to a temperature set out by the user is defined in Regulation (EU)2024/1103 as ‘idle mode’.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Visibly glowing radiant local space heaters are subject to specific ecodesign requirements and are therefore not considered as electric fixed local space heaters. Subsequently, they are also subject to specific F(3) factors that are not mutually accumulative with F(3) factors for electric fixed local space heaters.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
The Regulation defines in point 20 of Annex I standby mode as "a condition where the product is connected to the mains power source and provides only one or more of the following functions, which may persist for an indefinite time:
- reactivation function, or reactivation function and indication of enabled reactivation function
- reactivation function through a connection to a network (‘networked standby’);
- information or status display".
What is presented as so-called 'off' falls under the definition of stand-by, assuming the product can be re-activated. The fact that in such 'off' the control is working (and presumably consuming some energy) is precisely why standby is addressed in the regulation.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Yes. The regulation does not specify that the control should be able to control all the heat generators. Therefore, the correction factor can be applied even if it only controls one of the heat generators.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
As far as the content of the technical documentation is concerned, testing one combination for each separate space heaters heat generator and housing is sufficient where only the color differentiates the housings.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Auto programmable devices capable of generating a weekly-customized profile can be considered as weekly timers.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
For definitions (36) to (40) and (46) ( the definitions specifically indicate that the control can be external. For definitions (33) to (35), (45) and (47) there is no specification on whether it should be integrated or external, so both are possible.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
According to the definitions of ‘electric fixed local space heater’ and ‘electric portable local space heater’ these two types are mutually exclusive, so no product can be required to meet requirements for both categories. Local space heaters sold with features which can be used to fix it on a wall or a fixed appliance sold with a kit of castors fall under the description of ‘electric fixed local space heater’ because they are 'designed to be used while fastened or secured in a specific location or wall mounted', even though they have an alternative possible use. They are therefore electric fixed local space heaters.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Replacing a broken control with a new one does not determine how a product is affected by the Ecodesign regulation. If the local space heater (separate control+ heater) was placed on the market before the date of application of Regulation (EU) 2024/1103, the Ecodesign requirements applicable to that product at the moment of its placing on the market will still apply to that product after the replacement of the control.
Moreover, replacing a broken control is a pure maintenance operation. Nothing prevents the user to replace the faulty control with the same type of device, not existing any obligation to fit a better performing equipment in order to fulfil the legislation on Ecodesign. Where this be the case, it should be explicitly set out in the regulation, which is not the case.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Yes. Under the previous Regulation (EU) 2015/1188, slave heaters were excluded from the regulatory scope. Slave heaters were defined as an electric local space heater which is not capable of autonomous operation and needs to receive signals from an external master controller. Electric floor heating cables getting a signal from an external master controller could be considered as slave heaters insofar as heater and controller were sold separately, and were therefore exempted from the scope of Regulation (EU) 2015/1188.
On the contrary, heating cables coupled to a simple thermostat that cuts the electric current when the desired indoor temperature has been reached without sending any signal to the heating cable were not slave heaters and consequently were considered as local space heaters in the scope of Regulation (EU) 2015/1188. Regulation (EU) 2024/1103 has removed the exemption for slave heaters, so that it becomes clear that all electric floor heating cables fall in its scope, regardless of the external device to which they are connected.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Yes. As long as the nominal heat output of the local space heater is 50 kW or less, they are in the scope of the regulation.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Yes. When the installer manual or any other material (online or not) concerning the local space heater indicates that the product can be installed indoors, it is in the scope of the regulation.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
This product does not have to bear an energy label, nor should it be registered in EPREL (European Product Registry for Energy Labelling).
EPREL Public website (europa.eu)
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
According to Article 3 of Regulation (EU) 2015/1186 and Article 3 of the new Energy Labelling Framework Regulation (EU) 2017/1369, the label shall be printed; there is no specific indication on where to provide it, but websites cannot be used to provide an alternative to “printed” labels.
It is to be understood that the dealer has to be provided with correct and clear information on the energy performance of heaters. The label may be delivered together with supplementary material as long as labels are provided with each individual local space heater.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
No. Regulation (EU) 2015/1186 for the energy labelling of local space heaters is only applicable to products that are placed on the market or put into service from 1 January 2018 onwards.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.