Amended building standards for new buildings in Scotland were published in June 2022, the Scottish Government has confirmed. The amended standards apply to all building warrants applied for on or after 1 December 20221. They were published following the 2021 Energy Review consultation and set improved standards for energy efficiency, alongside provisions intended to support the implementation of the New Build Heat Standard (NBHS)1.
The Scottish Government is consulting on detailed proposals for the NBHS, which would prohibit the use of direct emissions heating systems in new buildings applying for a building warrant from 1 April 20241. The prohibition would be made through amendments to the Building (Scotland) Regulations 2004, using existing powers under the Building (Scotland) Act 2003, and monitored and enforced through the building warrant process1.
"We are seeking views on our detailed proposals for a New Build Heat Standard (NBHS) to prohibit the use of direct emissions heating systems in new buildings warranted from April 2024."
The 2022 building regulations already set out provisions intended to support the NBHS. These require that all new wet heating systems are designed to operate at lower temperatures, to be compatible with non-direct-emissions solutions such as heat pumps and heat networks; simplify the approach to connecting new buildings to heat networks by focusing on the performance of the building itself; exempt new buildings constructed without direct emissions heating systems from demonstrating compliance with a Target Emissions Rate under Standard 6.1, while still requiring them to meet the new delivered energy target; and require new buildings constructed with direct emissions heating systems to show they are designed to enable simple retrofit to a non-direct emissions heat solution1.
The Scottish Government states that direct emissions from buildings still account for almost 20% of Scotland's total greenhouse gas emissions. Analysis of the Energy Performance Certificate register for all new build homes completed in the 12-month period to the end of 2020 showed that over 80% were served by mains gas fired boilers as their main heating system, with a further 3% using heating oil and LPG, and only around 10% served by non-direct-emissions systems1.
Under the proposals, from 1 April 2024 new buildings not served by a heat network must meet their space heating, cooling and hot water demand using systems that produce zero direct greenhouse gas emissions at the point of use, where the system is located within the building or its curtilage1. The standard would remain technology-agnostic. Research commissioned by the Scottish Government from ClimateXChange confirmed that heat pumps, heat networks, solar thermal and solar thermal storage systems, electric storage heaters, electric boilers, fuel cells and direct electric heaters produce no direct in-building greenhouse emissions from normal operation at point of use and would therefore be compliant1. Findings for 100% hydrogen were inconclusive due to a lack of real-life data, and the Scottish Government says it will commission independent laboratory testing of hydrogen appliances1.
The table below sets out the compliance position for new buildings under the amended standards and the proposed NBHS1.
| Date | Zero direct emissions heating system | Direct emissions heating system |
|---|---|---|
| 1 December 2022 | Compliance with new energy target; meet requirements of notional building | Compliance with Target Emissions Rate; design building for simple retrofit to zero direct emissions; compliance with new energy target; meet requirements of notional building |
| 1 April 2024 | Compliance with new energy target; meet requirements of notional building | Not permitted |
Why it matters for households
The amended standards and the proposed NBHS shape what heating systems are installed in new homes in Scotland, and how those homes are designed to be heated. For a household buying or occupying a new build, the provisions mean the property's wet heating system should be designed to run at lower temperatures, which is the operating range heat pumps and heat networks use, and that a home built with a direct emissions system should be designed so it can later be retrofitted to a non-direct-emissions solution without major disruption1. The exemption from demonstrating compliance with a Target Emissions Rate for buildings without direct emissions heating, while still requiring the delivered energy target to be met, changes what developers must show at warrant stage1. Energy Performance Certificates are also being reformed to indicate whether the heat source installed at a dwelling is compliant with the zero direct emissions standard, with a response to the July 2021 consultation due to be published1. The Scottish Government states that direct emissions from buildings account for almost 20% of Scotland's total greenhouse gas emissions, and that continued deployment of direct emissions heating systems is not compatible with Scotland's net zero targets1.
What happens next
The consultation on the detailed NBHS proposals closed after publication; the Scottish Government says it aims to have the standard in place by early 2024, ahead of the 1 April 2024 warrant date1. It also states that it is publishing a Bioenergy Action Plan in 2023, and that the first Local Heat and Energy Efficiency Strategies are due to be finalised by the end of 20231.