This report provides an analysis of international approaches to regulating domestic energy efficiency and heat decarbonisation that are comparable with Scotland’s aims, as outlined in the Scottish Government’s Heat in Buildings Strategy.

Particularly of interest were regulations focused on existing domestic buildings (more so than new build) and regulations that promote a phase out or ban the use of fossil fuel-based heating.

The research identified regulations and policies relevant to heat and energy efficiency internationally, investigated their effectiveness and, where possible, identified why some approaches work and others fail.

The report highlights key considerations or precedents within the international policy area to better determine how similar regulations could work in Scotland.

It provides key learnings from other countries, regions and cities, which will be useful to the development of successful regulations by the Scottish Government.

Summary of key findings
  • The most common type of domestic heat regulations are bans prohibiting the use or installation of certain heating systems or certain fossil fuels, and mandates that set minimum emissions levels from these heating systems.
  • For energy efficiency, the most common type of regulation is mandating minimum energy efficiency levels.
  • Bans and mandates are similar in nature and impact. Generally, mandates provide more flexibility to the householder as to how they meet regulations. Both bans and mandates are effective in reducing the use of fossil fuelled heating systems and/or reducing carbon emissions from homes.
  • Regulations and policies are heavily focused on new builds rather than retrofitting existing buildings. In many cases, implementing measures in new build was a precursor to implementing them in existing housing.
  • There isn’t a regulation or measure focusing only on multi-family homes, although these types of homes are usually included as a target in the regulations.
  • There is little evidence of legal challenges to the measures and policies analysed in this study. In the rare instances when it happened, citizens challenged the regulation for fears of housing cost increase, but there was general support for the objectives of the regulation. However, it should be noted that the regulations implemented to date have mostly been tackling old and inefficient appliances and more ambitious regulations are likely to be needed to meet more stringent climate change targets.
  • A few of the regulations allow hybrid heating systems. For example, in Germany, if a low-carbon alternative isn’t technically feasible, the heating system needs to be hybridised to include at least one renewable source.
  • With bans and mandates, there is usually a phase-in period between 1 and 10 years before the measure is enforced and compliance monitored. Financial support schemes have been implemented by governments alongside bans and mandates.

For further details on the findings and a list of recommendations, please read the report attached.