Which? published its response to the Scottish Government's consultation on the Heat in Buildings Bill on 8 March 2024, setting out recommendations on targets, consumer support, installer certification, the private rental sector, products and costs, flexibility, and enforcement1. The consumer body said it is not an environmental organisation and so cannot take a position on the merits of some of the proposed targets, but has made recommendations on the design of the requirements and the support households will need if the regulations are introduced1.
The consultation, published on 28 November 2023 under the title "Delivering Net Zero for Scotland's Buildings", proposes a Heat in Buildings Bill that would prohibit the use of fossil fuel heating as the primary heating system in all buildings by 1 January 20462. Which? notes that the installation of new gas boilers would be banned from 2035, and that the Clean Heat Market Mechanism will ramp up requirements on boiler manufacturers to sell heat pumps from this year3. Consumer Scotland, the statutory consumer body for Scotland, also responded on 8 March 2024, saying it broadly supports the principle of the proposals but is "currently unable to take a view on behalf of residential or small business consumers on much of their substance on the basis of the information presented in the consultation"2.
On targets, Which? said:
"Consumers benefit from long term and well publicised targets that give households clarity about the changes that are required."
Which? also called for all installers to belong to an approved certification scheme, and backed a minimum energy efficiency standard for the private rented sector alongside protections for tenants and support for small scale landlords, noting that the sector "has high levels of fuel poverty and presents particular challenges due to the split incentives between landlords and tenants"1. On costs, it said the Scottish Government should work with the UK government to rebalance levies between gas and electricity prices, and consider efficiency standards for clean heating systems1.
The consultation documents set out differing dates for energy efficiency standards:
| Requirement | Proposed date |
|---|---|
| Minimum energy efficiency standard for private sector landlords | End of 20282 |
| Minimum energy efficiency standard for owner occupied homes with polluting heating | End of 20332 |
| All owner occupied homes without a valid abeyance or exemption to meet the energy efficiency component of the Heat in Buildings Standard | 1 January 20342 |
| Prohibition of fossil fuel heating as primary heating system in all buildings | 1 January 20462 |
Which? cites figures on current support: low income households are eligible for grants covering 100% of the cost of switching to clean heating, other households can receive grants covering up to 75% of insulation costs up to £10,000, with low interest loans for remaining costs, and a Private Rented Sector Landlord loan of up to £15,000 is available for energy efficiency measures3. It also cites research finding that 68% of homeowners who had searched for information online wanted more personalised information specific to their home, and 46% said it was difficult to know where to start3.
Why it matters for households
The proposals would set dates by which homes in Scotland must meet energy efficiency standards and stop using fossil fuel heating as the primary system2. For owner occupiers, the energy efficiency component would apply by the end of 2033 for homes still using polluting heating, and by 1 January 2034 for those without a valid abeyance or exemption2. Private landlords would face the standard by the end of 2028, even where clean heating is already in use3. Which? notes that around 40% of Scottish households live in flats and tenements, where it says viable clean heating options and any legal barriers to installation need to be addressed3. It also warns that electrified heating is currently more expensive than gas heating in some cases, which it says is particularly important for fuel poor households3. Consumer Scotland says the evidence, data and analysis required to support the specific proposals is "in large part currently unavailable"2.
What happens next
Consumer Scotland says it intends to publish a series of short papers during the 2024-2025 financial year to explore consumer protection issues in greater detail before parliamentary scrutiny of the proposed Bill commences2. It also recommends further modelling and analysis of the impact of the proposals on consumers2. Which? suggests further consultation on the measures households can install to meet the minimum energy efficiency standard, and maintaining the option of using an EPC1. The Scottish Government's response to the consultation has not been reported.
Sources3 cited
- Scottish Government consultation on Heat In Buildings Bill - Which? response - Which?, which.co.uk
- Scottish Government consultation on Delivering net zero for Scotland's buildings - Heat in Buildings Bill. (HTML) | Consumer Scotland, consumer.scot
- Scottish gov consultation on heat in buildings, media.product.which.co.uk