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.