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What is Lot 20? EcoDesign Compliance Explained

lot 20 ecodesign compliance

Lot 20 is an effective legislation for protecting our environment and driving energy efficiency standards, helping Britain to meet its carbon reduction targets. This latest ecodesign directive for the heating industry follows similar ‘lots’ that have included changes to the production of light bulbs, washing machines, televisions, and other electrical appliances. Lot 20, part of the 2021 Energy Efficiency Directive (EED 2015/1188), makes it necessary for all heating manufacturers to comply with a specific efficiency standard when producing heaters or radiators, be they gas, liquid, or electricity-driven. Lot 20 compliant heaters don’t just cover radiators – they also include underfloor heaters and electric and gas fires.

Ultimately, the Lot 20 legislation aims to help manufacturers create EcoDesign products that use significantly less energy to provide heat to our homes. Lot 20 regulations will not only have a positive impact on the UK’s carbon footprint, but they should also save you money on home heating costs each month.

Eco Design Directive

The European Eco Design Directive (Directive 2009/125/EC) for energy-using products (EUP) is a framework that all manufacturers must follow to ensure that their heating products are produced in a way that is as environmentally friendly as can be.

This new eco design directive is an important ongoing, worldwide shift to greener and more effictient energy use. By making heating and other appliances in our homes more efficient, we can save significant amounts of wasted energy and save money on monthly energy bills while we’re at it. As a result, improving the efficiency of just one household product – in this case, heaters and radiators – can have an enormously positive impact on the nation’s energy output.

EUPs cover many energy-using appliances, from traditional gas boilers to fuel burners and even phone chargers. As such, it is necessary to split these wide-ranging EUPs into separate ‘Lots’ within the Ecodesign Directive. This allows for better governance and the introduction of specific rules for each Lot to ensure products remain ecodesign compliant.

Lot 20 is one such Lot, created to enforce EU eco design regulations for space, electric, radiant, storage, underfloor and other heater types, among many others.

What is Lot 20?

Lot 20, the aforementioned subdivision of specific EUPs under the European Ecodesign Directive, covers almost all household electronics and not just radiators and heaters. This includes dishwashers, bulbs, boilers and beyond, and aims to make them as Lot 20 compliant and energy-efficient as possible.

What does Lot 20 compliant mean?

Lot 20 complaint simply means that the product adheres to a specific set of standards that ensure it is created efficiently and operates in an energy-efficient manner once installed or used in homes – or else it cannot be manufactured or sold. Today, the Lot 20 legislation, among other similar Lots created for the same purpose, plays a vital role in reducing Europe and the UK’s carbon footprint. Though the UK began its departure from Europe following the 2016 Brexit vote, Lot 20 must still be followed across Britain.

Is Lot 20 Still Relevant After Brexit?

While many may have thought the Ecodesign Directive UK would no longer apply once Britain left the EU, Lot 20 came into effect before Brexit and continues to be honoured due to its significance in reducing Britain’s energy output. Furthermore, Lot 20 is now deeply integrated into UK law and has been in force, successfully, for several years. Despite the UK’s position post-Brexit, eco design regulations remain a necessary and beneficial legislation if the UK is to continue to work towards reducing its carbon footprint.

How Has Lot 20 Changed Electric Heaters?

As of January 2018, all electric heaters must come equipped with an electronic thermostat with a 24/7 timer as well as open window detection sensors or adaptive start capabilities. Under Lot 20, any heater classed as a ‘fixed electrical local space heater’ must have a minimum 38% efficiency rating if they produce heat of an output of 250W or higher.

This applies to:

  • Panel heaters
  • Electric radiators
  • Radiant heaters
  • Underfloor heating
  • Infrared heaters
  • Oil Filled Radiators
  • Storage Heaters

Fire producing heaters must now display an energy rating ECO Label (similar to those displayed on large kitchen appliances such as fridges and dishwashers) which will include the heat output and the Energy Efficiency Index.

This applies to:

  • Electric & Gas Fires

Finally, portable heaters can no longer be wall-mounted and must now feature an integrated thermostat in order to meet the EcoDesign’s standards, and must also feature 24/7 timers and adaptive start functions or open window sensor capabilities.

This applies to:

  • Portable Heaters

Lot 20 Does Not Cover

The following heaters are not included under Lot 20:

  • Towel rails
    • Providing they cannot reach and maintain a specific level of thermal comfort for human heating within an enclosed space. This is specified in Article 1(b) of the Regulation (EU) 2015/1188.
  • Air curtains
    • Providing they are not equipped with an electric internal heat generator, which would classify them as a space heater. The majority of these appliances are powered by heaters that are covered by other regulations and therefore exempt from Lot 20.
  • Slave heaters
  • Sauna Stove
  • Patio and outdoor heaters
  • Tubular Heaters
  • Frost Protection Heaters

What Makes an Electric Heater Lot 20 Compliant?

It’s virtually impossible to effectively calculate the exact energy consumption of every single heater in the EU market, so the Lot 20 legislation utilises a simple formula that assigns a percentage bonus, or penalty, to each unit depending on its energy efficiency. Doing so makes it far simpler to establish Lot 20 compliant heaters.

An electric space heater may gain a bonus of 7% if it includes room temperature controls and a 24/7 timer, as mentioned in the previous sections. Additional features that position that unit as ‘energy saving’ will grant it additional bonuses that ultimately will help it hit the efficiency target outlined by Lot 20. Similarly, aspects that may cause the heater to be less efficient and drain more energy will result in deducted percentage points.

For example:

If the product is equipped with (only one option may apply): Correction Factor F(2)

For electric local space heaters

Single-stage heat output, no room temperature control 0.0%
Two or more manual stages, no temperature control 0.0%
Mechanic thermostat room temperature control 1.0%
Electronic room temperature control 3.0%
Electronic room temperature control plus day timer 5.0%
Electronic room temperature control plus week timer 7.0%


If the product is equipped with (multiple options may apply): Correction Factor F(3)

For electric local space heaters

Room temperature control with presence detection 0.0%
Room temperature control with open window detection 1.0%
Distance control option 1.0%
Adaptive start control 1.0%
Working time limitation 0.0%
Black bulb sensor 0.0%

How Does it Affect You?

For consumers, the Eco Design Directive, and Lot 20, has meant a significant impact on prices – particularly on lower value products. Because heaters are required by law to now include a range of new features, from timers to open window detection capabilities. Naturally, the cost of the units themselves has had to increase.

That being said, while initial purchasing may be more expensive, monthly heating bills should be lower than previously as the new Lot 20 compliant heaters are more efficient and therefore waste less energy and money.

Lot 20 and Landlords

It is now a landlord’s responsibility to ensure their properties meet the Eco Design standards and that all appliances are Lot 20 compliant. Historically electric heating rules and regulations have been difficult to follow for landlords, but under Lot 20, they are fairly simple – all electric heaters must adhere to these standards outlined above.

To calculate whether your units are compliant with Lot 20, use the above tables to tally up your percentage and add 30 on top of that (the baseline number that every heater has). If you reach the Lot 20 target score, your heater is up to scratch. This process must be applied to every heater in your property.

That being said, different heaters have different targets depending on a range of factors and the type of heater – a mechanical thermostat on a wall-mounted panel heater is worth only one point. In contrast, the same thermostat on a portable panel heater is with 6 points.

What has Lot 20 Compliance Achieved?

Lot 20 has already done much to improve Britain’s energy output and reduce poorly controlled temperature regulators in favour of smart, energy-efficient heaters:

  • Reduced energy bills for consumers
  • More efficient electric heating
  • Reduced carbon footprint for Britain
  • The widespread adoption of smarter electric heating solutions
  • The removal of energy-hungry, inefficient heating appliances

Lot 20 Compliant Heaters from Best Electric Radiators

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What is Lot 20 legislation?

Lot 20 legislation is a UK-wide law that ensures homes are using smart, energy efficient heaters (and other appliances). Reducing wasted energy through the introduction of these appliances has, and continues to have, a significant impact on Britain’s carbon footprint, and helps us waste much less energy.

What does lot 20 compliant mean?

Lot 20 compliant means that a heater adheres to a specific set of standards outlined in the legislation. This varies among different heaters, but cites that specific heaters must come equipped with specific features to avoid wasted energy. See the How Has Lot 20 Changed Heaters? section earlier in this page for further details.

What did the Eco Design Directive oblige manufacturers to do?

As of January 2018, the Eco Design Directive forced manufactures to install all electric heaters with an electronic thermostat with a 24/7 timer as well as open window detection sensors or adaptive start capabilities. For more information on these changes, see the How Has Lot 20 Changed Heaters? section earlier in this page.


While the rules and regulations surrounding the Lot 20 legislation may be overwhelming at first glance, it is an extremely positive policy that has had, and continues to have, an incredible impact on Britain’s carbon emissions.

To ensure your existing units are Lot 20 compliant, make sure to use the information throughout this article, along with our handy points tables. If you’re looking to install new electric heaters in your home, look out for the ECO Label that outlines heat output and Energy Efficiency Index ratings.

The Lot 20 legislation is just one of a number of policies implemented by the UK government in recent years to help the nation waste less energy, and consumers must consider this effort when selecting their next home heating system.

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