ErP and ecodesign rules for commercial boilers up to 400 kW

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The ErP (ecodesign) rules for commercial boilers come from Commission Regulation (EU) No 813/2013, which in Great Britain is now assimilated law published on legislation.gov.uk. It applies to space heaters and combination heaters "with a rated heat output ≤ 400 kW" when they are placed on the market or put into service. For gas and oil boilers above 70 kW and up to 400 kW, it sets minimum useful efficiencies at full and 30% output and limits on nitrogen oxide (NOx) emissions, and it requires manufacturers to publish set technical data for each model. It is a product rule: the installation itself still has to meet the Building Regulations (Approved Document L) and be carried out safely by a Gas Safe registered commercial engineer. This guide explains the GB legal status, what is in and out of scope, the limits that apply around the 70 kW split, the data you can ask for, and how ErP sits alongside Part L.

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Commercial heating tips and advice · 22 October 2026 · Fast Commercial Boiler Help, Gas Safe 985448

Is the ErP regulation still law in Great Britain?

Yes, in its UK version. legislation.gov.uk explains that EU legislation as it applied to the UK on 31 December 2020 "became part of UK domestic legislation under the control of the UK’s Parliaments and Assemblies", and that after the end of 2023 "‘retained EU law’ became known as ‘assimilated law’, by section 5 of the Retained EU Law (Revocation and Reform) Act 2023". Section 5 of that Act lists the name change directly: retained EU law is known as assimilated law "As regards all times after the end of 2023".

Regulation 813/2013 is published on legislation.gov.uk as "the UK version", and it has been amended for GB use. For example, Article 2 now points to the definitions in the Ecodesign for Energy-Related Products Regulations 2010, Article 4 sets out conformity assessment by reference to those 2010 Regulations and refers to "UK marking", and Article 5 says market surveillance checks are carried out by "the authorities of Great Britain". When we checked the contents page on 22 October 2026, it said: "There are currently no known outstanding effects by UK legislation for Commission Regulation (EU) No 813/2013."

Northern Ireland is different. legislation.gov.uk notes that under the Northern Ireland Protocol, EU legislation can continue to apply in respect of Northern Ireland, so this guide covers Great Britain only.

What counts as a boiler under the ErP rules, and what is outside them

The regulation covers "space heaters", which Article 2 defines as devices that provide heat "to a water-based central heating system" to keep an enclosed space such as a building at the desired temperature, and "combination heaters", which also heat drinking or sanitary water. A "boiler space heater" is a space heater that generates heat by burning fossil fuels and/or biomass fuels, or by electric resistance heating. Annex I defines a "condensing boiler" as one in which water vapour in the combustion products "is partially condensed, in order to make use of the latent heat of this water vapour for heating purposes".

Article 1 lists what the regulation does not apply to. The exclusions most relevant to commercial sites are:

Warm air and steam plant: "heaters for heating and distributing gaseous heat transfer media such as vapour or air". Warm air heaters still have their own efficiency guidance in Approved Document L, and their own servicing needs: see our guide to warm air heater heat exchanger inspection.
Hot water only: heaters "generating heat only for the purpose of providing hot drinking or sanitary water". Those fall under a separate regulation, (EU) No 814/2013, which covers water heaters "with a rated heat output ≤ 400 kW" and hot water storage tanks up to 2,000 litres.
Solid fuel heaters, and heaters "specifically designed for using gaseous or liquid fuels predominantly produced from biomass".
Cogeneration space heaters "with a maximum electrical capacity of 50 kW or above".
Like-for-like replacement heat generators designed for heaters placed on the market before 1 January 2018, "to replace identical heat generators and identical heater housings". The replacement product or its packaging "shall clearly indicate the heater for which it is intended".

Boilers above 400 kW rated heat output are outside the regulation's scope altogether. For those, Approved Document L Volume 2 says that "the manufacturer’s declared efficiencies should be used".

ErP rules for commercial boilers: the limits either side of 70 kW

Article 3 sets the timetable, and Annex II sets the requirements. For fuel (gas or oil) boilers, the efficiency requirements have applied since 26 September 2015 and the NOx limits since 26 September 2018:

Boiler	Efficiency requirement (Annex II, point 1(a))
Fuel boiler space heaters and combination heaters, rated heat output ≤ 70 kW (other than small type B1 boilers)	Seasonal space heating energy efficiency (ηs) "shall not fall below 86 %".
Fuel boiler space heaters and combination heaters, rated heat output > 70 kW and ≤ 400 kW	Useful efficiency "at 100 % of the rated heat output shall not fall below 86 %", and "at 30 % of the rated heat output shall not fall below 94 %".

Fuel	NOx limit for fuel boilers (Annex II, point 4(a)), expressed in nitrogen dioxide
Gaseous fuels	56 mg/kWh fuel input in terms of GCV
Liquid fuels	120 mg/kWh fuel input in terms of GCV

Two definitions help when reading data sheets. Annex I defines "useful efficiency" as the ratio of the useful heat output to the total energy input, with the input expressed in terms of gross calorific value (GCV). Article 2 defines "seasonal space heating energy efficiency" as the ratio between the space heating demand for a designated heating season and the annual energy consumption needed to meet it. Our guide to planning a commercial boiler replacement explains how these efficiency floors fit into a wider replacement project.

Energy labels and ErP data sheets: what you can ask for

The energy label that many people associate with ErP comes from a separate regulation, (EU) No 811/2013, which sets labelling requirements for space heaters and combination heaters "with a rated heat output ≤ 70 kW". Above 70 kW that labelling regulation does not apply. For example, Ideal's Evomax 2 installation and servicing manual gives a product fiche with a seasonal space heating efficiency class ("A") for its 30 to 60 kW models.

What applies across the whole range up to 400 kW is the product information requirement in Annex II, point 5. Since 26 September 2015, "the instruction manuals for installers and end-users, and free access websites of manufacturers, their authorised representatives and importers" must contain the technical parameters in Annex II, Table 1, together with:

"any specific precautions that shall be taken when the heater is assembled, installed or maintained";
"information relevant for disassembly, recycling and/or disposal at end-of-life".

Table 1 includes whether the boiler is a condensing boiler, its rated heat output, seasonal space heating energy efficiency (ηs), useful heat output and useful efficiency at rated output in the high-temperature regime (60°C return, 80°C feed) and at 30% of rated output in the low-temperature regime (30°C return for condensing boilers), auxiliary electricity consumption, standby heat loss, NOx emissions, and the manufacturer's name and address. As a real example, Hamworthy's Upton floor-standing installation guide includes a table headed "Product information - technical parameters required by ErP Regulation (813/2013)", giving these figures for each model in the range.

When you get quotations for a new boiler, it is reasonable to ask each installer for the ErP data for the exact model and output they propose, and to keep it with your plant records and building log book. See heating maintenance records insurers, landlords and auditors ask for.

How ErP sits alongside Part L of the Building Regulations

ErP and Part L do different jobs. Approved Document L Volume 2 (buildings other than dwellings, 2021 edition incorporating 2023 amendments) explains that the Ecodesign for Energy-Related Products Regulations 2010 "set the efficiencies and standards that must be met when introducing new energy-using products to the market", while the approved document "sets standards that should be met when installing fixed building services". It adds: "In cases where the Energy-Related Products Regulations and the Building Regulations both apply, both standards should be met."

Different measures. Approved Document L uses a boiler seasonal efficiency (gross calorific value) worked out from part-load and full-load efficiencies (equation 6.1: 0.81η30% + 0.19η100%) for single boilers and identical multiple boilers up to 400 kW producing low temperature hot water. Its Table 6.2 sets 91% for a single natural gas boiler up to 400 kW output in an existing building, and Table 6.1 sets 93% for a single natural gas boiler up to 2 MW in a new building.
Which edition. GOV.UK now lists Approved Document L (2026) for buildings subject to the 2026 standards, and says "Earlier versions of Approved Document L continue to apply to buildings subject to previous regulatory standards." Ask your installer or building control body which edition applies to your project.
Documented performance. Where a complete heating system is replaced in an existing building, Approved Document L says the energy performance of the whole system should be assessed and handed over to the building owner. One of the accepted records is "A documented assessment of the installed system produced in accordance with Ecodesign and associated energy labelling requirements."

In short, a boiler that meets ErP is allowed to be sold and put into service, but it still has to be the right boiler for the building, installed, controlled and commissioned to Part L. We cover surveys, sizing, controls and commissioning in our replacement planning guide rather than repeating them here.

What ErP means if your boiler is already installed

Article 1 says the regulation establishes requirements for "the placing on the market and/or putting into service" of heaters. On that wording it governs boilers as products being supplied and commissioned. It does not, by itself, require a boiler that is already installed and in safe working order to be taken out. What keeps an existing boiler in use is its condition and safe operation: it must be maintained in a safe condition under the Gas Safety (Installation and Use) Regulations 1998, and serviced to the manufacturer's instructions. See what a commercial boiler service includes.

ErP becomes relevant again when you replace a boiler, or a major part of one. If an engineer proposes a replacement heat exchanger or heat generator for an older boiler, ask whether it is a like-for-like replacement of the kind Article 1(2)(g) describes, and which heater it is intended for.

The installation: IGEM/UP/10 and Gas Safe registration

Meeting ErP says nothing about whether a boiler has been installed safely. IGEM/UP/10 Edition 4 covers the installation of flued gas appliances in industrial and commercial premises, including hot water boilers of net heat input exceeding 70 kW and not exceeding 20 MW. Its contents include ventilation, chimneys, gas and fire detection, "Commissioning and handover" and "Servicing and maintenance". IGEM/UP/10 uses net heat input, whereas ErP uses rated heat output, so the two 70 kW thresholds are not the same measure; your engineer will confirm which standards apply to your plant room.

All installation, commissioning and maintenance of gas boilers is for a Gas Safe registered engineer who is qualified for non-domestic work. Site staff should not alter boiler settings, controls, flues or gas pipework to change efficiency or emissions. Our guide on checking a Gas Safe engineer's commercial qualifications explains what to look for.

Duty holder responsibilities

Regulation 35 of the Gas Safety (Installation and Use) Regulations 1998 (GSIUR) requires every employer or self-employed person to ensure that "any gas appliance, installation pipework or flue installed at any place of work under his control is maintained in a safe condition so as to prevent risk of injury to any person." HSE's guidance for employers says that in premises such as shops, restaurants, schools and hospitals, work on gas fittings "must be carried out by a Gas Safe registered engineer who is qualified to do the work", and that "It's your responsibility to check a person is registered and is qualified." IGEM/UP/10 makes a similar point: "The primary responsibility for compliance with legal duties rests with the employer."

For the duty holder, a practical approach to ErP is to:

ask installers to confirm in writing that the proposed boiler meets the ecodesign requirements for the GB market, and to supply its ErP data;
ask which edition of Approved Document L applies, and how the proposed boiler meets its efficiency figures;
keep the ErP data, commissioning records and log book information with your gas safety records and service reports;
check that the engineer doing the work is Gas Safe registered for the commercial appliances involved.

Replacing a commercial boiler up to 400 kW?

Call us on 0800 0996 007 or WhatsApp 07947 578332 to talk through a replacement. Our Gas Safe registered engineers (Gas Safe 985448) handle commercial boiler installation and replacement and the rest of our commercial boiler services, and can keep your existing plant safe in the meantime through commercial boiler servicing. You can also email [email protected].

Safety note

Under the Gas Safety (Installation and Use) Regulations 1998, gas work must be carried out by a Gas Safe registered engineer, and we apply that rule on every site. Don't attempt DIY work on gas appliances, burners, flues or safety devices. On pressure systems, trained site staff should stick to visual and gauge checks, log the readings and report anything abnormal. Never adjust, cap, plug or test-lift a relief valve yourself.

Talk to a Gas Safe commercial engineer

Fast Commercial Boiler Help is a Gas Safe registered (985448) commercial heating business based at 4 Market Hill, Clare, Sudbury, Suffolk CO10 8NN. Our team of over 10 local engineers covers East Anglia and East London, working on commercial boilers, plant rooms, water heaters, and warm air, radiant and unit heaters. We work on commercial premises only.

Call 0800 0996 007

Call or WhatsApp 07947 578332 (a photo of the appliance data plate or the fault display helps) · Email [email protected]

Frequently asked questions

Is Regulation 813/2013 still in force in the UK after Brexit?

In Great Britain, yes, in its UK version. legislation.gov.uk explains that EU legislation as it applied on 31 December 2020 became part of UK domestic law, and that after the end of 2023 retained EU law became known as assimilated law under section 5 of the Retained EU Law (Revocation and Reform) Act 2023. Regulation 813/2013 has been amended for GB use, for example to refer to the Ecodesign for Energy-Related Products Regulations 2010, UK marking and the authorities of Great Britain. Northern Ireland follows different arrangements.

What are the ErP efficiency limits for commercial boilers between 70 kW and 400 kW?

For fuel boiler space heaters and combination heaters with a rated heat output above 70 kW and up to 400 kW, Annex II of Regulation 813/2013 says the useful efficiency at 100% of rated heat output shall not fall below 86%, and at 30% of rated heat output shall not fall below 94%. These have applied since 26 September 2015. Boilers up to 70 kW are instead judged on seasonal space heating energy efficiency, which shall not fall below 86% for most fuel boilers.

Do commercial boilers over 70 kW need an ErP energy label?

No. The energy labelling regulation, (EU) No 811/2013, covers space heaters and combination heaters with a rated heat output up to 70 kW. Boilers above 70 kW and up to 400 kW still have to meet the ecodesign requirements of Regulation 813/2013, and their manufacturers must publish the technical data set out in Annex II, Table 1, in instruction manuals and on free access websites.

Do ErP rules apply to warm air heaters or boilers above 400 kW?

Regulation 813/2013 does not apply to heaters for heating and distributing gaseous heat transfer media such as vapour or air, and its scope is limited to a rated heat output up to 400 kW. Approved Document L still sets efficiency guidance for warm air heaters, and for boilers above 400 kW it says the manufacturer's declared efficiencies should be used. Ask a Gas Safe registered commercial engineer which rules apply to your plant.

If a boiler meets ErP, does it automatically meet Part L?

Not automatically. Approved Document L says that where the Energy-Related Products Regulations and the Building Regulations both apply, both standards should be met. ErP sets standards for products placed on the market, while Approved Document L sets standards for the installation, including minimum boiler seasonal efficiencies, controls and commissioning. Check which edition of Approved Document L applies to your project.

Sources and further reading