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.