BEAMA, the trade body representing manufacturers across heating, electric vehicle charging, appliances and electrical infrastructure, has published its response to the Department for Energy Security and Net Zero (DESNZ) consultation on the Energy Smart Appliance Regulations for the Smart Secure Electricity Systems (SSES) Programme. The response is dated 5 February 20261.
The body said it answered every question across all five sections of the consultation, and that its members support the regulations in principle while holding specific technical concerns about implementation1. It called for urgent clarification and guidance documents, saying the number of questions already raised by members suggests the published wording is not sufficient to make informed judgements on compliance1.
"Overall, BEAMA have responded to all five sections of the consultation and answered all the questions."
On scope, BEAMA raised concern about bringing heat pumps up to 45kW into scope, which it said are very unlikely to be installed in domestic premises, and proposed a limit closer to 20kW1. It disagreed with the proposed definition of a storage heater, suggesting instead the definitions in BS EN 60531:2000+A11:2019, already referenced in SAP, the upcoming HEM and the MCS thermal energy storage standard MIS 30081. It also disagreed with the proposed definition of a "relevant heat battery", saying it inadvertently captures indirect hot water heat batteries, and proposed a capacity limit of 60L to 300L1. For standalone direct electric hot water cylinders, it proposed the same 60L to 300L range1.
On metering, BEAMA said that to be fully compliant with the Mid-Infrastructure Requirements (MIR) a meter must hold both Module B (type approval) and Module D (verified), with certificates issued by a UK approved notified body1. It said it is aware of only five testing centres in the UK, which it does not feel is sufficient to ensure compliance and full testing by the December 2027 timeline, and called for enforcement to be delayed through a two-year voluntary or grace period before full mandatory compliance in December 20291. It recommended that heat appliances in domestic settings be exempted from full MIR Class B compliance, with requirements focused instead on functional accuracy and reliability appropriate to device-level measurement used for control and flexibility rather than billing1.
On cyber security, BEAMA said DESNZ should consider equivalent compliance beyond ETSI EN 303 645, for example EN 180311. On randomised delay, it said delays of up to 10 minutes may help avoid demand surges from simultaneous start-up, but the regulations do not appear to address the risk of large numbers of devices turning down or switching off at the same time1. It said the current wording would permanently put heat pumps into a randomised delay cycle as they are by nature always on, and that the timeline for randomised delay changes for EV charging should move to the end of 2027 in line with other energy smart appliances1.
| Area | BEAMA position |
|---|---|
| Heat pump scope | Closer to 20kW maximum rather than 45kW1 |
| Heat battery and direct cylinder capacity | 60L to 300L1 |
| MIR Class B enforcement | Two-year voluntary or grace period, full compliance December 20291 |
| Cyber security | Consider EN 18031 alongside ETSI EN 303 6451 |
| EVSCP timeline | Align with other energy smart appliances at end of 20271 |
Why it matters for households
The regulations will determine which appliances in a home must be able to respond to signals from the grid, and what metering and security they must carry. BEAMA's response indicates that the definitions of heat pumps, storage heaters, heat batteries and hot water cylinders are still unsettled, and that the compliance timeline for smart metering hardware may be difficult to meet. For a household, the practical questions are which devices fall in scope, whether they can still be charged or run on a schedule the occupant chooses, and whether solar self-consumption is affected by mandatory delays. BEAMA states that under current wording, households with solar panels cannot charge their vehicles optimally through solar while still applying a randomised delay of up to 30 minutes1. The consultation process itself is set out in the site's guide to how energy consultations work, and DESNZ is covered in the guide to the department behind home energy policy.
What happens next
BEAMA has recommended a voluntary or transitional phase from 2027, followed by a permanent compliance date once Phase 2 requirements and associated technical specifications are fully defined1. It has also recommended that the timeline for randomised delay changes for EV charging move to the end of 2027 in line with other energy smart appliances1. No government response to the consultation, and no revised timetable, has been reported.