Guidance

Does a Warehouse Need an EPC?

The conditioned-space test, how warehouses are zoned in assessments and what applies on sale or letting.

Note: This is a general guide for UK commercial property owners and professionals. Non-domestic EPC regulations, registers and processes differ across England & Wales, Scotland and Northern Ireland. Always check the current position on GOV.UK and the relevant national register before acting on any specific matter.

The basic position

A warehouse needs an EPC when it is sold, let or newly built — but only if it is a building that is conditioned, meaning it has fixed heating, cooling or mechanical ventilation. A warehouse that is genuinely unconditioned may fall outside the EPC requirement.

The catch is that most warehouses contain some conditioned space: an office pod, a heated welfare area or even a single fixed heater can bring the building within scope. The position depends on what is actually installed, so it is worth confirming before assuming an exemption applies.

How warehouses are assessed

In the assessment, conditioned and unconditioned zones are treated separately. The heated office block inside a distribution shed is modelled as conditioned space, while the open storage area may not be. This zoning has a significant effect on the rating, which is why an accurate site survey matters more for warehouses than for almost any other building type.

High-bay lighting is usually the largest single opportunity for improvement — replacing older discharge lighting with LEDs frequently moves a warehouse rating by a full band or more.

Selling or letting a warehouse

If the warehouse requires an EPC, it must be commissioned before marketing and the rating shown in the particulars. For lettings in England and Wales, the MEES rules apply: a rating below E generally means the building cannot be let without a registered exemption.

Next steps

If you'd like specific advice about a property or portfolio, request a quote and our in-house assessors will come back to you.

Related guidance

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