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.