FEGECA analyses the main regulatory changes in the air conditioning sector

Alberto Jiménez, a member FEGECA's Technical Commission, summarises for us the standards that have affected the heating, cooling and DHW production sector in 2025 and also gives us a preview of the drafts and standards set to be amended over the coming months, and that have been put to public consultation, particularly the new Technical Regulation on the Distribution and Use of Gaseous Fuels, encompassing amendments to the RSIF; the Royal Decree establishing the marketing of fluorinated gases (RD 115/2017); and the amendment of the CTE (Technical Building Code).

In terms of regulatory changes in the sector in 2025, the first one to highlight is the Guidelines for the interpretation of the European Energy Performance of Buildings Directive (EPBD) (Directive (EU) 2024/1275). "On 30 June 2025, the Commission adopted a support package providing practical guidance to help EU countries implement and transpose the Energy Performance of Buildings Directive into national legislation by 29 May 2026. Of the 20 supporting documents published there is one that specifically addresses fossil fuel boilers". 

Article 13, paragraphs 7 and 8 of the European Energy Performance of Buildings Directive establishes the need to define the concept of "fossil fuel boiler". A supporting document entitled: "Fossil fuel boilers (Article 13 and Annex II)" defines the official concept of a fossil fuel boiler. It is made clear that it is the fuel and not the equipment that defines whether it is fossil fuel or not. Specifically, with regard to the ban on fossil fuel boilers by 2040, it states: "it is the fuel used in the boiler in 2040 that defines whether in 2040 a boiler is to be considered a ‘fossil fuel boiler’ or not." In other words, a biogas-fired boiler will not be considered fossil fuel boiler.

It also states that it will be up to member states to determine the decarbonisation pathway for buildings by 2040, either through the replacement of units, the roll out of biogas or both. With these clarifications, the confusion over the possible banning of boilers in the coming years has been definitively cleared up.

F-Gas Regulation 

Although the F-Gas Regulation entered into force in March 2024, some of its impositions are staggered over several years. In January 2025, the first of the bans introduced under the standard came into force, prohibiting the placing on the market of split units with an indoor unit with a refrigerant gas charge of less than 3kg and a GWP above 750. This de facto prohibits the use of R410A for these types of units.

Thermal installations 

Regarding the Thermal Installations Regulation (RITE 1027/2007), an explanatory note was published in June 2025 answering three frequently asked questions relating to inspection procedures. In summary, it is stated that for installations with a capacity above 70 kW with hot air generators or radiant panels or tubes, safety should be given priority over performance during inspection. Ensure that combustion is correct, take CO measurements and check the safety features associated with the combustion itself.

In the case of absorption refrigeration equipment with gas burners, it is clarified that the measurement of equipment efficiency during inspections is not required. Such equipment was only permitted where there was a source of free, residual thermal energy or in cases where electricity could not be used.

Meanwhile it is confirmed that cooling equipment below 12 kW, i.e. air conditioning units, are exempt from energy efficiency inspections. Units between 12 and 20 kW, which do not have the appropriate pressure taps in the cooling circuit will also be exempt from performance measurement due to this technical impossibility.

Amendments to the RSIF 

Royal Decree 164/2025, of 4 March, approves a new fire safety regulation for industrial establishments (RSCIEI). This RD introduces changes affecting fire protection and redefines requirements that overlap with other regulations. As a result of this, a number of Supplementary Technical Instructions of the RSIF have been affected.

Meanwhile, Royal Decree 770/2025 of 2 September also includes regulatory amendments affecting the field of industrial safety, including aspects linked to the RSIF relating to the system for hiring qualified professionals. 

Ecodesign 

Regulation (EU) 2024/1103: Ecodesign Standard for Lot 20 (local space heaters) aims to establish ecodesign requirements for local heating appliances (electric radiators, stoves, etc.), in order to promote energy efficiency and reduce the environmental impact. It replaces the previous Regulation (EU) 2015/1188, which is repealed as of 1 July 2025. The new regulation applies from 1 July 2025.

Energy certification of buildings 

Another change is the amendment of the basic procedure for the energy certification of buildings (RD 659/2025). The purpose here is to adapt and amend Royal Decree 390/2021 in order to update the basic procedure for energy performance certification (EEC) of buildings to bring it into line with European regulations and to improve the accreditation system for technical officers responsible for issuing them.

Forthcoming changes

Alberto also provides us with a run-down of the drafts and regulations already set for amendment over the coming months and years, starting with the public consultation process for the amendment of the RITE, expected to take place during 2026.

The purpose of the new technical regulation on the safety of gaseous fuel infrastructures and installations is to establish the technical conditions and guarantees to be met by infrastructures and installations for the distribution, transport and use of gaseous fuels and gas appliances, with the aim of protecting the safety of people and property. The purpose of this change is to modernise and harmonise the regulation of infrastructures, transport, distribution and use of gaseous fuels; repealing and replacing RD 919/2006, updating the Supplementary Technical Instructions, incorporating new fuels and clarifying instructions. The public consultation period was held in April-May 2025.

This draft RD also introduces amendments to other regulations, including the Regulation on the Safety of Refrigeration Installations (RSIF). In particular, several paragraphs of IF-01, IF-04, IF-06 and IF-17 are amended. The most important amendment concerns the prevalence of vertical regulations over horizontal and generic rules on the same subject.

Regulation (EU) 2024/573 of the European Parliament and of the Council, of 7 February 2024, on fluorinated greenhouse gases, establishes a new regulatory framework for the use of fluorinated greenhouse gases, natural refrigerants and products and equipment containing or relying on them. This European regulation replaces Regulation (EU) 2015/2067. It will be necessary, therefore, to adapt national legislation for the correct implementation of this standard, repealing Royal Decree 115/2017, regulating the marketing and handling of fluorinated gases and equipment containing or relying on them. This new legislation must also regulate the certification of professionals who use them and establish the technical requirements for installations conducting activities that emit fluorinated gases. For this reason, a draft of this new Royal Decree was published in July 2024. The public consultation ended in September 2025.

Finally, Alberto also offers us the latest on the draft amendment of the Technical Building Code. The Royal Decree proposes a comprehensive and structural overhaul, in order to adapt Spanish regulations to Directive (EU) 2024/1275 on the energy performance of buildings; the new Regulation (EU) 2024/3110 on construction products as well technical developments, social demands and lessons learned from recent incidents.