Does a product without display, but equipped with a daily programming function comply with the definition 'with electronic room temperature control plus day timer'?

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.}