Resource efficiency requirements (NEW REQUIREMENT)
The Commission’s Circular Economy Action Plan and the Ecodesign and Energy Labelling Working Plan 2022-2024 underline the importance of using the ecodesign framework to support the move to a more resource efficient and circular economy.
Therefore, the new regulation lays down appropriate circularity-related requirements ensuring that products are effectively repaired thanks to the availability of a range of spare parts, setting maximum delivery time for spare parts and specifying what repair and maintenance information is to be given to professional repairers and end-users.
These requirements are only regulated through the new regulation (EU) 2024/1103, and therefore apply from the 1st of July 2025 and are concerning:
- Availability of spare parts.
- Maximum delivery time of spare parts.
- Access to repair and maintenance information.
- Requirements for dismantling for material recovery and recycling while avoiding pollution.
The supplier of the LSH is responsible for meeting all related requirements.
Availability of spare parts
For all models, for which units are placed on the market from the 1st of July 2025 (i.e. the requirements also apply to models that have been placed on the market already before this date, if they are continued to be placed on the market from this date onwards), for electric LSH (there are no requirements for gaseous or liquid fuel LSH, i.e. neither for commercial nor for non-commercial LSH) at least the following spare parts shall be made available to professional repairers (empty fields mean that there is no requirement). Please see table below.
Table: List of spare parts to be available under the new regulation
| Electric portable LSH and electric visibly glowing radiant portable LSH | Electric fixed LSH, towel rails and electric underfloor LSH | Electric storage LSH
| Electric visibly glowing radiant LSH except portable products
| |
| Control | Yes | Yes | Yes | Yes |
| Ambient thermostat | Only for electric portable LSH | Yes | ||
| Motor for heaters equipped with a fan | Only for electric portable LSH | |||
| Printed circuit boards | Yes | Yes | Yes | |
| Display or status indicators | Yes | Yes | Yes | Yes |
| Impellers | Yes | Yes | Yes | Yes |
| Control sensors | Yes | Yes | Yes | Yes |
| Buttons and switches | Yes | Yes | Yes | Yes |
| Floor sensor | Only for electric underfloor LSH | |||
| Remote control sensors | Yes | Yes | Yes | Yes |
| Repair kit for heating cables | Yes, but only for electric underfloor LSH | |||
| Fixation brackets, if needed | Yes | Yes | Yes | |
| Heating elements | Yes | Yes | ||
| Safety switches | Yes | |||
| Connection cables | Yes | Yes | ||
| Housing for mechanical parts | Yes | |||
| Fans | Yes |
Additionally, remote controls must be available to professional repairers and also to end users.
Suplliers of electric LSH shall ensure that:
- From two years after placing the first unit on the market (remote controls and software from 1st of July 2025 in any case) until 10 years after placing the last unit of the model on the market, suppliers have to make available
- Spare parts (see lists above):
Delivery within 10 working days after receipt of the order - List of spare parts and procedure for ordering them on a supplier’s free access website
- Indicative pre-tax prices at least in Euros and of fasteners and tools if supplied with the spare parts on a supplier’s free access website
- For LSH using software: Software and firmware updates free of charge.
- Spare parts (see lists above):
- Spare parts must be replaceable with commonly available tools without damaging the LSH.
Access to repair and maintenance information
Electric LSH
During the period of availability of spare parts, the supplier shall provide access to the appliance repair and maintenance information to professional repairers in the following conditions:
- Their website shall indicate the process for professional repairers to request access to information; to accept such a request, the suppliers may only require the professional repairer to demonstrate that:
- The professional repairer has the technical competence to repair LSH and complies with the applicable regulations for repairers of LSH in the Member States where it operates. Reference to an official registration system as a professional repairer, where such system exists in the Member States concerned, shall be accepted as proof of compliance with this point;
- The professional repairer is covered by insurance covering liabilities resulting from its activity regardless of whether this is required by the Member State;
- Suppliers
- Shall accept or refuse the registration within 5 working days from the date of request;
- May charge reasonable and proportionate fees for access to the repair and maintenance information or for receiving regular updates. A fee is reasonable if it does not discourage access. The main criterion for being reasonable is that the fee must take into account the extent to which the professional repairer uses the information;
- Once registered, a professional repairer shall have access, within one working day after accepting the request, to the requested repair and maintenance information. The information may be provided for an equivalent LSH model or an LSH model of the same family if relevant.
- The repair and maintenance information shall include:
- The unequivocal LSH identification
- A disassembly map or exploded view
- Technical manual of instructions for repair
- List of necessary repair and test equipment
- Component and diagnosis information
- Wiring and connection diagrams
- Diagnostic fault and error codes
- Instructions for installation of relevant software and firmware including reset software
- Information on how to access data records of reported failure incidents stored on the local space heater
- Electronic board diagrams
Gaseous and liquid fuel LSH
Regarding gaseous and liquid fuel LSH, without prejudice to intellectual property rights, third parties shall be allowed to use and publish unaltered repair and maintenance information initially published by the supplier as numerated above one the supplier access to that information after the end of the period of access to repair and maintenance information.
Requirements for dismantling for material recovery and recycling while avoiding pollution
Manufacturers, importers or authorised representatives shall ensure that LSH are designed in such a way that the materials and components referred to in Annex VII to Directive 2012/19/EU can be removed from the appliance with the use of commonly available tools.
Manufacturers, importers or authorised representatives shall fulfil the obligations laid down in Article 15(1) of Directive 2012/19/EU.