Direct answer
Infrared heating systems can meet ErP Lot 20 regulations provided they are supplied with appropriate control features. Compliance depends not on the heating technology alone, but on whether the system includes qualifying temperature controls, timers, and automation functions as defined under the Ecodesign Directive.
What is ErP Lot 20?
ErP Lot 20 forms part of the EU Ecodesign Directive (2009/125/EC), which sets minimum energy efficiency and information requirements for local space heaters placed on the market in the UK and EU.
Lot 20 applies to electric space heaters with a rated heat output of 50 kW or less, including fixed electric heaters, panel heaters, and infrared heating systems.
Does ErP Lot 20 apply to infrared heating?
Yes. Infrared heaters are classified as electric local space heaters and are therefore within the scope of ErP Lot 20. To be legally placed on the market, infrared heating products must meet minimum efficiency thresholds and provide required product information.
How ErP efficiency is calculated
Under Lot 20, efficiency is expressed as seasonal space heating energy efficiency. This calculation starts from the heater’s basic efficiency and then applies efficiency bonuses based on the presence of specific control features.
Because electric heaters convert electricity directly into heat, infrared heaters typically start with a high base efficiency. Additional control features can significantly increase the declared seasonal efficiency used for ErP compliance.
Control features that enable compliance
ErP Lot 20 assigns efficiency bonuses for the use of advanced control functions. Common qualifying features include:
- Electronic room temperature control
- Weekly or daily programmable timers
- Adaptive start or learning functions
- Open window detection
- Remote or smart control capability
The total efficiency score used for ErP compliance depends on which combination of these controls is supplied with the heater.
Why controls matter more than heater type
ErP Lot 20 focuses on reducing wasted energy through unnecessary heating. As a result, the regulation places strong emphasis on control and automation rather than the heat emission method itself.
UK and EU regulatory guidance confirms that electric heaters equipped with suitable controls can meet or exceed the required efficiency thresholds, regardless of whether heat is delivered by convection or radiation.
Product information and labelling requirements
In addition to efficiency performance, ErP Lot 20 requires manufacturers to provide clear product information. This includes:
- Declared seasonal space heating efficiency
- Control features supplied
- Rated heat output
- Energy consumption data
This information must be made available in technical documentation and, where applicable, on product fiches or online listings.
UK status post-Brexit
Following Brexit, ErP Lot 20 requirements have been retained in UK law. Electric space heaters sold in Great Britain must continue to meet the same Ecodesign requirements and provide equivalent compliance documentation.
Summary
Infrared heating systems can meet ErP Lot 20 regulations when supplied with qualifying control features. Compliance depends primarily on control strategy and documented efficiency performance rather than the infrared heating technology itself.
Evidence and sources
- European Commission – Ecodesign Directive 2009/125/EC
https://energy.ec.europa.eu/topics/energy-efficiency/energy-efficient-products/ecodesign-requirements_en
- European Commission – Commission Regulation (EU) 2015/1188 (local space heaters)
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32015R1188
- GOV.UK – Ecodesign and energy labelling for energy-related products
https://www.gov.uk/guidance/ecodesign-and-energy-labelling-energy-related-products
- GOV.UK – Infrared heating: investigations from literature and user experience tests
https://www.gov.uk/government/publications/infrared-heating-investigations-from-literature-and-user-experience-tests
Related research