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Do workshops, industrial sites and farm buildings need an EPC?

Updated 19 October 2026 · SEO Dons Editorial

Workshops, industrial sites and farm buildings are exempt from EPCs only when they have low energy demand. The exemption is narrower than it sounds: it is about whether the space is heated or cooled for the people in it, not about how much energy the processes inside use. A heated office, a warm-shell fit-out or a farm diversification project can each bring a building back into scope. For the general triggers, see do I need a commercial EPC?

What does the exemption say?

GOV.UK's page on EPCs for business premises says you do not need an EPC if you can demonstrate that the building is "an industrial site, workshop or non-residential agricultural building that does not use much energy".

The legal source, regulation 5 of the Energy Performance of Buildings (England and Wales) Regulations 2012, uses slightly different words. It covers "industrial sites, workshops and non-residential agricultural buildings with low energy demand", plus non-residential agricultural buildings in use by a sector covered by a national sectoral agreement on energy performance.

What does low energy demand mean?

The 2012 Regulations give no number. The Building Regulations 2010, which contain the same category for their own energy rules, say these terms have the same meaning as in the 2010 EU Directive on the energy performance of buildings. In practice the working definition comes from government guidance.

The guide to EPCs for non-dwellings describes industrial sites and workshops with low energy demand as buildings, or separately used parts, that accommodate industrial activities in spaces where the air is not conditioned. Its examples are foundries, forging and other hot processes, chemical processes, food and drinks packaging, heavy engineering, and storage and warehouses, in each case where the air is not fully heated or cooled.

The guide also allows some local heating. These buildings may have local appliances such as plaque or air heaters, or air conditioners, serving people at work stations dispersed among the industrial activities, without losing their status.

Does heat from the process count?

No. The non-dwellings guide says energy used directly for heating or cooling a process is not taken to mean conditioning the indoor climate, and that buildings without any other conditioning would not require an EPC.

Approved Document L, the government's guidance on the Building Regulations energy rules in England, puts it the same way: low energy demand only relates to energy used by fixed heating or cooling systems, not to energy required for or created by process needs. So a hypothetical foundry warmed only by its furnaces can have low energy demand in this sense, even though its energy bills are large.

It also helps to know what makes something a building for EPC purposes. Regulation 2 defines a building as a roofed construction having walls, for which energy is used to condition the indoor climate. The guide says that means fixed heating, mechanical ventilation or air conditioning, and that hot water and electric lighting are not triggers.

When does heating bring the building back into scope?

Three situations change the answer.

Space heating for the people working there

Once the space itself is heated or cooled for comfort by fixed systems, for example a warm-shell workshop with heaters designed to warm the whole floor, the low energy demand description no longer fits. The building then needs an EPC when it is sold or let, like any other.

A heated office or welfare area inside the unit

The non-dwellings guide works through industrial units with mixed spaces. A unit with only unconditioned space needs no EPC. A unit with unconditioned space and a heated office needs one EPC, which reflects the conditioned space, and the unconditioned space is included in the calculation. In other words, a small heated office can bring the whole unit into the certificate. The industrial and warehouse EPC page explains how those buildings are then assessed.

An empty shell that will be fitted out

If there is no intention to install fixed services and no ability to do so, no EPC is required. If a building is sold or let without fixed services but they are intended to be installed, the guide says the EPC should be based on the building's planning use class, assuming the most energy-intensive fit-out allowed under Part L.

Which farm buildings are exempt?

Non-residential agricultural buildings with low energy demand are exempt. The non-dwellings guide describes them as buildings, or separately used parts, that are heated for a few days each year to enable plants to germinate but are otherwise unheated. Approved Document L adds egg hatching and very severe weather to the examples of short heating periods that still count as low demand.

A barn, livestock shed or store with no fixed space heating, ventilation or cooling is not a building for EPC purposes in the first place. The question changes with farm diversification. A barn converted into heated offices, a farm shop or a let workshop is no longer a low-energy agricultural building, so when it is let or sold it is likely to need an EPC. Conversions are covered in more detail in EPCs and change of use.

Does MEES apply to an exempt workshop or farm building?

Not if it is genuinely exempt. The government's non-domestic landlord guidance (last updated 5 May 2026) says the minimum standard applies to non-domestic rented properties that are legally required to have an EPC, and that where a property is not legally required to have one, an exemption will not be required.

The reverse also holds. If a let unit has a heated office or warm-shell heating and so needs an EPC, MEES applies in full: at least EPC E, and from 1 April 2023 for existing lettings as well as new ones, unless a valid exemption is registered.

How do you show the exemption applies?

As with every EPC exemption, the onus is on the seller or landlord to demonstrate it. A short record helps: what heating, ventilation or cooling exists and what it serves, photographs of any local heaters at work stations, and confirmation that there is no plan to install space heating. Remember the separate size rule too: GOV.UK exempts a detached building with a total floor space under 50 square metres, whatever its use.

If the building has a heated office, welfare block or planned fit-out, check what triggers the requirement and use the form on this page to request quotes from accredited assessors.

Sources

Common questions

Does a workshop with a few radiant heaters over the benches need an EPC?

Not necessarily. Government guidance says low energy demand buildings may have local appliances such as plaque or air heaters serving people at work stations among the industrial activities. Heating designed to warm the whole space is a different matter.

Is an unheated warehouse exempt from needing an EPC?

It can be. The non-dwellings guide lists storage and warehouses where the air is not fully heated or cooled among its low energy demand examples. If the warehouse has a heated office, that office can bring the unit into the EPC requirement.

Do I need an EPC to sell an empty industrial unit with no heating?

Not if there is no intention and no ability to install fixed heating, ventilation or air conditioning. If such services are intended, the guide says the EPC should be based on the building's planning use class and an assumed fit-out.

Does a heated glasshouse used only for germination need an EPC?

Government guidance describes low energy demand agricultural buildings as those heated for a few days each year so that plants can germinate, but otherwise unheated. A building used that way falls within the exemption.

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