In the logistics and warehousing sectors, protecting buildings and stored goods from frost is a critical operational requirement, especially during the winter months. However, many businesses are unaware that heating systems designed solely for frost protection can be exempt from Energy Performance Certificate (EPC) requirements under UK regulations.
This article explains how the exemption works, why it matters, and how Powrmatic’s Air Rotation System offers a proven solution to maintain compliance, cut costs, and safeguard your facility.
Frost protection refers to the use of low-level heating systems to prevent freezing within a building, particularly in unoccupied or industrial spaces. Rather than providing comfort heating, these systems maintain internal temperatures just above 0°C to safeguard critical infrastructure—such as sprinkler pipes, stored goods, and machinery—from frost damage during cold weather.
Under current UK EPC regulations, commercial buildings with heating systems designed exclusively to prevent freezing (not to provide comfort heating) can be legally exempt from requiring an EPC.
The heating system’s primary purpose must be frost protection, not occupant comfort.
The internal design temperature must remain below 12°C during normal operation.
Heating should be triggered only when necessary to keep areas such as sprinkler lines, infrastructure, or stored goods above freezing.
This exemption is particularly relevant to industrial warehouses, distribution centres, and large storage facilities that do not require comfort heating for occupants but need to prevent frost damage to their operations.
The exemption is supported by guidance in the UK’s Approved Document L (Volume 2) for non-domestic buildings, which explicitly excludes:
“Heating or cooling equipment only intended for emergency or occasional backup use”
and
“Heating equipment for frost protection.”
This confirms that heating systems operating purely to prevent freezing – such as Powrmatic’s air rotation units configured for frost protection – are not counted towards a building’s energy rating and therefore do not require an EPC.
Powrmatic’s Air Rotation technology is a cost-effective and energy-efficient solution designed to meet EPC exemption requirements.
Air rotation systems are designed to maintain sub 12°C internal temperatures, not comfort heating levels.
Heating is only activated to prevent freezing, such as protecting sprinkler lines and infrastructure.
The system meets all frost-only criteria set out in EPC regulations.
This makes air rotation a practical, compliant option for businesses looking to reduce their compliance burden while ensuring frost protection.
Beyond regulatory benefits, air rotation systems also offer major insurance advantages by proactively reducing frost-related risks.
Air rotation systems ensure even temperature distribution throughout large spaces, preventing cold spots that could damage goods, packaging, or equipment.
Traditional heating systems often cause stratification, where warm air rises and leaves ceilings cold—putting sprinkler systems at risk of freezing. Air rotation eliminates this by constantly circulating air from floor to ceiling.
Many insurers look favourably on heating systems that help reduce the risk of frost-related damage, which may lead to lower insurance premiums or simpler policy compliance. 95% of Powrmatic air rotation projects are designed specifically for frost protection.
(image from https://www.jjfe.co.uk/birmingham-warehouse/)
Buildings using heating solely for frost protection—operating below 12°C—do not require an EPC under current UK rules.
Powrmatic’s Air Rotation system is a compliant and efficient solution, supporting both operational needs and regulatory exemptions.
With support from Approved Document L and insurance compatibility, air rotation systems present a low-risk, high-impact option for frost protection.
If you are considering a frost-only heating system or need to confirm EPC exemption eligibility, speak to Powrmatic. Proper system design and documentation ensure compliance, efficiency, and peace of mind.
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