BEAMA publishes position paper urging EPC reform to include indoor air quality

BEAMA, the trade body for electrotechnical and energy products, published a position paper on 8 November 2024 urging Government to broaden the Energy Performance Certificate (EPC) remit to recognise and assess the indoor air quality of homes¹. The paper was released to mark World Ventil8 Day, and was presented at a World Ventil8 Day meeting in London¹.

The paper argues that the current EPC framework has evolved to focus on energy efficiency performance since the early 2000s, and that this leaves a gap. In BEAMA's words, "This key aspect of a building's impact on occupancy is entirely missed across any policy mechanism linked to EPCs or, worse still, Government funding schemes"¹. It adds that even within the Government's preferred PAS 2030: 2024 framework, ventilation and indoor air quality is "the poor relation to energy efficiency with no published evidence to suggest it is delivering change in living standards related to indoor air quality"¹.

Lee Nurse, Business Development Director of Volution Group and Chair of BEAMA's Ventilation Group, said at the London meeting:

"the expansion of the remit of EPCs is a common sense approach to what is a national health crisis. It is absolutely the right time to enforce the principle that a healthy home is a basic human right. With so much policy focus on retrofitting homes to improve their energy efficiency, we should not be ignoring the ongoing health of occupants"

The paper sets out figures on the scale of the issue. It states that 465,000 EPCs were issued in England and Wales between January and March 2023, against a peak of around 600,000 in 2014, and that 410,000 of those lodged were for existing buildings². It reports that 48.6% of homes are below EPC C, and notes that a rating at or above C is not in itself proof of good air quality². It also cites Building Research Establishment figures putting NHS spending on treating people affected by poor quality housing at around £1.4bn per annum, and the social cost of poor housing in England alone at £135bn over 30 years². On damp and mould, it states that as 2025 is entered there are 65,000 homes with Category 1 issues, and that a £250m investment to tackle those would create £4.8bn of societal savings over 30 years and an NHS saving of over £33m a year². It further states that households can save up to 26% of their heating costs by using energy efficient ventilation systems².

The paper also points to the amended Energy Performance in Buildings Directive, which it quotes as stating that member states will have to define requirements to ensure that good indoor air quality is fully part of their national regulatory framework². It cites the legal text of Approved Document F: "F1. (1) There shall be adequate means of ventilation provided for people in a building"². Its proposed approach includes assessment during a property sale or rental transaction and compliance with Approved Document F². The paper also refers to raising the bar for MEES in the private rented sector to a minimum EPC rating of C by 2030, and to linking to the Warm Homes Plan through the Social Decarbonisation Fund allocation for private rented dwellings². It states that 23% of homes classed as non-decent are in the private rented sector, against 13% for owner occupiers².

Why it matters for households

An EPC is the document a householder meets at the point of buying, selling or renting a home, and it currently reports energy efficiency. BEAMA's argument is that this leaves the health of the indoor environment unrecorded at exactly the moment when a property changes hands. For a household, the practical consequence of the proposal would be that ventilation provision, and not only heat loss and running costs, forms part of the recorded picture of a home. The paper links this to energy efficiency work itself: it states that homes rated C or above could still have indoor air quality problems where ventilation needs were not addressed during a retrofit, or where ventilation was poorly specified under Approved Document F². That connects directly to home ventilation, since measures that tighten a building can change how air moves through it. The paper also frames the issue in terms of cost, stating that energy efficient ventilation systems can cut heating costs by up to 26%², and in terms of the wider condition of the UK housing stock, where it reports 48.6% of homes below EPC C². Any change to the EPC would sit within the broader EPC regulations and reform process, and the paper's proposals on the private rented sector touch on the housing quality standards that apply to rented homes.

What happens next

The paper sets out policy links rather than a timetable. It refers to raising the bar for MEES in the private rented sector to a minimum EPC rating of C by 2030, and to the Warm Homes Plan, which it states has £3.4bn committed over three years and £9bn overall². It lists grants for low income households, finance for the able to pay sector and local authority targeted social funding as the funding routes it envisages². No Government response to the position paper, and no date for any change to the EPC remit, has been reported¹.

Sources2 cited

1. BEAMA EPC Reform Position Paper, beama.org.uk
2. BEAMA-EPC-Reform-Position-Paper.pdf, beama.org.uk