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EU Regulation 2024/1103 Guide to Lot 20 for Efficient & Sustainable Heating

eco design erp lot 20
 
The European Union has established, through a specific directive, general ecodesign and sustainability rules for various product categories. Lot 20 identifies products for local space heating, and EU Regulation 2024/1103 translates these provisions into concrete requirements that manufacturers must comply with. Let’s take a closer look.

A brief history

On 31 October 2009, Directive 2009/125/EC, known as the Ecodesign Directive, was published in the Official Journal of the European Union. It is a key instrument designed to improve the energy efficiency of products and reduce their environmental impact. The directive sets minimum design requirements for household appliances, electronic devices, and heating systems, with the aim of using fewer resources, reducing emissions, and promoting a more sustainable market—without compromising performance and quality.

To implement these principles, the EU divided products into different lots, each relating to a group of equipment with significant energy consumption. Among the most relevant are refrigeration, lighting, electric motors, ventilation systems, and local space heaters.

Lot 20 covers all local space heating systems, including electric ones. The European Commission initially defined the technical requirements with EU Regulation 2015/1188, aiming to improve energy efficiency and reduce emissions. As technologies and environmental needs evolved, this regulation was updated and replaced by EU Regulation 2024/1103, which extends Lot 20 rules to include separate control devices and introduces stricter criteria for manufacturers. The new rules entered into force on 1 July 2025, marking an important step towards a more sustainable and efficient heating market.

Main requirements of EU Regulation 2024/1103

EU Regulation 2024/1103 sets out rules to make local space heating appliances, such as products for electric home heating or electric bathroom heating, more efficient and sustainable. Key points include:

  • Energy efficiency: appliances must be equipped with features that enable efficient use, ensuring lower energy consumption and reduced emissions.
  • Low-power modes: even when appliances are in standby or inactive mode, energy consumption must be minimal, avoiding invisible energy waste.
  • Mandatory information: manufacturers must provide efficiency values and technical parameters in the documentation, facilitating checks, compliance, and informed consumer choice and comparison.
  • Resources and sustainability: the regulation encourages designs that promote repairability, spare parts availability, ease of maintenance, and material recycling.

⚡ Energy efficiency targets

The regulation aims to improve appliance efficiency, helping to save energy without sacrificing comfort. Each energy-saving feature—such as weekly programming or open-window detection—receives a score. These scores are combined in a formula that calculates a parameter known as Seasonal Space Heating Energy Efficiency, for which mandatory minimum values are set. The higher the score, the greater the ability to use the appliance efficiently and cost-effectively throughout the heating season.

🔽 Low-power modes

Even when an appliance is in standby, inactive, or networked standby mode, it continues to consume energy. EU Regulation 2024/1103 sets precise limits for consumption in these modes, helping to reduce “invisible” energy use. In practice, when the appliance is not actively heating, it may only use minimal amounts of energy within defined maximum limits. For example, in standby mode with information display (such as current date or time), consumption must not exceed 1.00 W.

🏷️ Mandatory product information

Manufacturers must provide mandatory information in instruction manuals, including data on consumption, energy performance, and parameters useful for correct and efficient use. This enables consumers to easily compare products and choose those that are more efficient and sustainable. This information must be made publicly available on the freely accessible website of the manufacturer, importer or authorised representative.

🔧 Resource efficiency specifications

The regulation establishes obligations related to repairability and sustainability: essential spare parts must be available for at least 10 years, and technical documentation must be accessible for maintenance, repair, and dismantling. This reduces waste and pollution, extends product lifespan, and promotes material recycling. This information must be made publicly available on the freely accessible website of the manufacturer, importer or authorised representative.

In summary

EU Regulation 2024/1103 does not only aim to improve the energy efficiency of local space heating appliances, but also introduces:

  • Limits on consumption in low-use modes
  • Information and documentation obligations
  • Design criteria that support sustainability and recyclability

Together, these measures promote higher-performing, less energy-intensive, and more sustainable products, benefiting both consumers and the European market.

FAQ – Frequently asked questions

What is Directive 2009/125/EC (Ecodesign)?

It is a European regulation that defines minimum energy efficiency requirements for energy-consuming products, reducing emissions and waste while promoting more sustainable devices.

What does Lot 20 mean?

Lot 20 identifies local space heating appliances, including Radialight electric heating products, and sets rules to improve their energy efficiency and sustainability.

What does ErP mean?

ErP stands for Energy-related Products. It includes all products that consume energy or influence its use and are subject to efficiency and ecodesign criteria.

Why is EU Regulation 2024/1103 important for consumers?

It ensures more efficient products with reduced standby consumption, clear information, and sustainable performance, enabling energy savings and comfort.

What will change with the update planned for 2026?

The regulation will be updated to be clearer and more effective, improving efficiency, simplifying requirements, and promoting greater transparency.

Which appliances fall under Lot 20?

All local space heating appliances, including electric models—both portable and wall-mounted, Wi-Fi enabled, electric towel warmers, or bathroom fan heaters.

What are low-power modes?

These are operating states in which the appliance is inactive or in standby. The regulation sets precise limits to reduce invisible energy consumption and waste.

How long must spare parts be available under the regulation?

Essential spare parts must be available for at least 10 years from the last date the product is placed on the market, together with technical documentation for maintenance, repair, and dismantling.

Do I need to replace the heating appliances I already own?

No, there is no need to replace existing heating products. The regulation only applies to new appliances placed on the market; products purchased before its entry into force can continue to be used normally.

Does the regulation affect the warranty of my existing appliances?

No, the legislation does not change the warranty conditions of products already purchased. Manufacturers and retailers must comply with the obligations in force at the time of purchase, so warranties remain valid under the original contract.

Is it mandatory for a heating product to comply with EU Regulations 2015/1188 or 2024/1103?

Yes. All products placed on the market between 01/01/2018 and 30/06/2025 must comply with EU Regulation 2015/1188, while those placed on the market after 30/06/2025 must comply with EU Regulation 2024/1103. Manufacturers, importers or authorised representatives are required to draw up and make available the technical documentation necessary to demonstrate compliance with the applicable regulation.