Consultation outcome

Summary of responses

Updated 11 December 2023

Foreword

The government welcomed the sector’s positive response to the expansion of the VAT relief on energy-saving materials (ESMs) announced at Spring Statement 2022. As well as bringing more ESMs into the scope of the relief, last year’s reforms made the relief easier for consumers to access and, crucially, zero rated qualifying ESMs for VAT purposes. This will enable more households to install ESMs, improve the energy efficiency of their homes, and thereby reduce their energy bills. By focusing on reducing costs on UK families, it will help to deliver on the government’s pragmatic, proportionate, and realistic path to reach net zero by 2050.

The government also listened to calls from industry to go further still in order to ensure that government support remains in step with the rapidly evolving ESMs landscape. Subsequently, at Spring Budget 2023, the government launched a Call for Evidence (CfE) seeking views on potential areas of further reform. In particular, the government sought views on expanding the relief to additional technologies, and capitalising on our Brexit freedoms by re-instating the relief for the installation of qualifying materials in buildings used solely for a relevant charitable purpose. As announced at Autumn Statement, I am delighted that the government will be making further reforms to this relief as a result of this CfE. All of these reforms will be implemented across the UK thanks to the Windsor Framework.

I would like to express my gratitude to all those who took the time and effort to contribute to the CfE process, whether that be by providing a written submission or meeting with my officials. I was delighted to see such a breadth of proposals put forward throughout this process, all of which were considered in depth ahead of any policy decisions being taken. The high levels of engagement with this CfE reaffirms the fact that improving the energy efficiency of the UK’s building stock and bringing down people’s energy bills is a commitment shared by the government, industry, and the public alike.

While I am confident that the reforms we will be implementing as a result of this CfE will be welcomed by the sector, I recognise that some stakeholders may be disappointed that some of the reforms they suggested will not be taken forward. In particular, owing to the large number of suggestions received, we are unable to extend VAT relief to all of the additional technologies suggested in response to the CfE. I would like to reiterate that the government thoroughly scrutinised all proposed technologies against the stated objectives of the relief before making any decisions. As a result, I am confident that the technologies we are extending the relief to are the right ones.

Thank you once again for your engagement on this important topic.

Nigel Huddleston MP, Financial Secretary to the Treasury

Introduction

The government has made a commitment to support improvements in energy efficiency across the economy to bring down bills for households, businesses, and the public sector. Improving the energy efficiency of the UK’s housing stock and increasing the proportion of energy provided from low-carbon, renewable energy sources will be a key part of meeting our legally binding commitment to reach net zero greenhouse gas emissions by 2050.

To help fulfil this commitment, the installation of certain ESMs in residential accommodation benefits from a VAT relief, helping households to improve the energy efficiency of their homes by reducing the VAT due on installations of qualifying materials.

At Spring Statement 2022, the government expanded this relief by re-instating wind and water turbines as qualifying materials and removing complex eligibility conditions. It was also announced that qualifying installations would benefit from a temporary VAT zero rate (having previously benefitted from the reduced rate of VAT at 5%) in Great Britain until 31 March 2027. Following the ratification of the Windsor Framework, this VAT relief was extended to Northern Ireland on 1 May 2023.

While the expansion of this VAT relief in 2022 was welcomed by the sector, there were requests for further changes to make the relief more effective and easier to access. At Spring Budget 2023, the government therefore launched a CfE seeking views on potential reforms to this VAT relief. In particular, the CfE sought views on:

• potentially expanding the relief to additional technologies that meet the government’s objectives for the relief, and

• re-instating the relief for the installation of qualifying materials in buildings used solely for a relevant charitable purposes (Annex B contains a full list of questions asked in the CfE). 

The CfE was published on 23 March and closed on 31 May 2023. In total, the government received 125 written submissions from a range of individuals, businesses, charities, and trade associations (Annex A contains a list of respondents). To supplement these written submissions, government officials also held meetings with certain stakeholders.

The government is grateful to all those who contributed to the CfE process and recognises the time and effort that went into the submissions.

All reforms suggested in the CfE were evaluated against the following objectives:

1. Improving energy efficiency and reducing carbon emissions
2. Cost effectiveness
3. Alignment with broader VAT principles

As stated in the CfE document, regardless of whether a proposed reform meets these three objectives, the government retains its discretion to make decisions on tax policy reform as part of the Budget process, taking account of the wider fiscal context.

On this basis, Chapter 2 summarises the responses received to the CfE and the government’s response to these, while next steps can be found in Chapter 3.

Responses

Expanding the scope of the relief – electrical battery storage

Questions 1-6 of the CfE sought views on whether the retrofitting of batteries that store electricity generated by solar panels, wind turbines, and water turbines should be included in the relief. The CfE also sought views on the inclusion of batteries as a standalone technology connected to the National Grid (“the grid”). The questions requested information on how these technologies meet the objectives of the relief, how they operate, the cost of a typical installation, and the advantages and disadvantages of an installation.

A large number of responses to these questions were received, all of which supported the inclusion of such batteries: 63 responses for batteries retrofitted to ESMs and 60 for standalone batteries.

Respondents were in agreement that including both types of installations of batteries would meet each of the government’s three objectives of the CfE. They noted that the primary function of these batteries is to enable households to store energy generated by ESMs for later use, thus avoiding the need to draw electricity from the grid at peak times. In the case of standalone batteries, it was noted that these can be used to store electricity at off-peak times, when the electricity being generated is typically greener. It was also felt that extending the relief to these batteries would be a cost-effective investment for government and was consistent with broader VAT principles. No significant downsides were identified, and no negative responses were received.

Government response

The government recognises the integral role that electrical battery storage can play in reducing households’ reliance on the grid, both when retrofitted to a qualifying ESM and when used as a standalone technology connected to the grid.

This technology already qualifies for VAT relief when installed alongside a qualifying ESM, as it is ancillary to a zero-rated supply. The government agrees with respondents, though, that this technology meets all of the stated objectives for this VAT relief in its own right, and will therefore bring electrical battery storage within the scope of the relief. This means that the technology will now also qualify for VAT relief when either retrofitted to a qualifying ESM, or installed as a standalone technology connected to the grid.

The government hopes this reform will enable more consumers to retrofit electrical battery storage to existing ESMs, allowing households to maximise the efficiency of their solar panels, wind turbines, and water turbines.

Expanding the scope of the relief – other technologies

Questions 7-11 of the CfE sought views on whether there were any further technologies that also met the 3 objectives, and should therefore be eligible for the relief. A range of additional technologies were proposed, a full list of which can be found in Annex C.   

10 respondents proposed that the installation of water-source heat pumps should fall within scope of the relief. Respondents highlighted that this technology’s primary function is to generate renewable energy. They also noted that this type of heat pump is at least as efficient as ground-source and air-source heat pumps – both of which are already included within the scope of the relief. Respondents felt that their inclusion would be a cost-effective investment for the government, as well as a logical extension of the current VAT relief and consistent with broader VAT principles. No downsides to this technology were identified. 

Respondents also suggested the inclusion of diverters retrofitted to ESMs such as solar panels and wind turbines (diverters) and thermal storage. There was a clear view that both of these technologies enable a consumer to both retain energy within a property, and to connect to other renewables, such as solar panels. This allows for optimum usage of green energy being generated. There was a consensus within the responses that these technologies meet the objectives of the relief, and their installation is for the purpose of saving energy.

Some respondents proposed technologies that are not commonly installed in residential buildings, or buildings used solely for relevant charitable purposes. These included non-residential solar panels for installation in car parks or solar farms, district heating, small scale flywheel technology, supercapacitors, and thermal-driven heat pumps. There was no evidence provided by respondents regarding these technologies’ suitability for installation in a domestic setting.

Other respondents proposed technologies the primary purpose of which is not to save energy or reduce carbon emissions. These included: insulation protection; heat pump crates/covers; mechanical and non-mechanical ventilation; windows, doors and rooflights; blinds, shutters and awnings; light emitting diode (LED) low voltage lighting; voltage optimisers; water efficiency technologies; home energy management/monitoring systems; and electric vehicle (EV) charging points.

There were also proposals for technologies that have some energy saving qualities, but remain reliant on fossil fuels to work. These included: high-recovery hot water cylinders, radiant and infrared heating, hybrid heat pumps, and heat interface units.

Finally, some respondents suggested technologies that already qualify for the relief. Specifically: wet retrofit underfloor heating insulation, thermostatic radiator valves, and low embodied carbon insulation.   

Government response

The government is grateful to respondents for proposing such a wide range of technologies, including some that had not previously been considered in the context of this relief. While the government is always pleased to see innovative energy-saving materials being bought to market, to ensure this VAT relief remains good value for money, it is imperative that, at a minimum, a technology meets all three objectives if it is to be brought within scope of the relief. 

Having analysed all of the proposed technologies in depth, the government has concluded that it will bring the installation of water-source heat pumps and diverters within scope of the relief.

In the case of water-source heat pumps, the government agrees that bringing this technology within scope would be a logical extension of the relief, given the similarities between this technology and air-source and ground-source heat pumps. Moreover, considering that the government already supports the installation of this technology via the Boiler Upgrade Scheme, this reform will help to ensure that tax policy remains in step with broader environmental policy. 

Again, the government views the inclusion of diverters in the relief as a logical extension, as this technology helps to maximise the efficiency of ESMs that are already within scope. The government hopes that extending the relief to diverters will incentivise households with ESMs that are compatible with this technology to install these products. This will subsequently allow households to use excess energy generated by their ESM to power other appliances in their home, rather than opting for the less efficient alternative of exporting it back to the grid.          

As one of the most frequently requested technologies to be included within the relief, the government gave significant consideration to thermal storage. On balance, the government has concluded not to bring this technology within scope of the relief at this time for 2 primary reasons. First, the term “thermal storage” encompasses a wide range of products, not all of which meet the 3 objectives of this relief. The government is grateful for the potential definitions of this technology proposed by stakeholders through the CfE process. However, the government was unable to identify a single definition of thermal storage that would be suitable for tax legislation. In particular, the government was unable to identify a definition that encompassed all of the products in this category of technology that meet the objectives of this relief, yet excluded those that do not (e.g., insulated hot water storage tanks). Secondly, the government was unable to identify sufficient independent data regarding the efficiency the type of thermal storage that meets the 3 objectives of this relief, making it difficult to assess the technology’s energy-saving properties objectively. 

For these reasons, thermal storage will not be brought within scope of the relief at this time. However, once the market for this technology has developed further and there is greater data on the technology’s efficiency available, the government may re-evaluate the VAT treatment of thermal storage. Until then, when installed at the same time as a qualifying ESM, the installation of thermal storage will continue to be zero rated for VAT purposes, as the technology is ancillary to a qualifying supply.

Given that the scope of the ESMs VAT relief is currently limited to residential buildings, the proposed technologies that are not typically installed in these settings would rarely, if ever, actually benefit from being zero rated for VAT purposes in practice. Similarly, these technologies are unlikely to be installed in buildings used solely for relevant charitable purposes. For this reason, the government will not be bringing these technologies within scope of the relief. 

A number of technologies the primary purpose of which is not to save energy or reduce carbon emissions were proposed. The government acknowledges that some of these technologies do play a part in reducing a household’s overall energy consumption. However, where the primary purpose of a technology is anything other than the improvement of energy efficiency (such as lighting, ventilation, or storage), it is the government’s view that this zero rate should not apply, as not all objectives of the relief are met.  

Similarly, the government acknowledges that those technologies that have some energy-saving qualities, but remain reliant on fossil fuels to work, go some way to helping to reduce a household’s energy consumption. However, bringing these technologies within scope of the relief may incentivise the take up of inefficient systems, such as gas boilers, which would be contrary to the objectives of the relief and broader government environmental commitments. As this is not the intention of these reforms, the government will not be bringing these technologies within the scope of this VAT relief. It is worth noting, however, that in the case of hybrid heat pumps, where a heat pump is retrofitted to an existing fossil fuel heating system, the installation of the heat pump element already falls within scope of this relief and is therefore zero rated.

Limiting the scope of the relief

Questions 12 and 13 of the CfE sought views on technologies that do not meet the objectives of the relief and should no longer, therefore, qualify.

4 respondents indicated that wood-fuelled boilers should no longer benefit from the relief owing to the negative impact they can have on air quality. Respondents also noted that the collection of the wood burned by this technology can cause deforestation and unnecessary emissions, both of which are ecologically damaging.

However, one respondent highlighted the valuable role that these technologies can play in rural, off-grid areas, and set out that, in such locations, households’ options for sustainable heating sources are more limited. The respondent also noted that, in these rural areas, the fuel source is more readily available and the impact that this technology has on air quality is less acute.      

It was not suggested that any other technologies should be removed from the relief.

Government response

The government recognises respondents’ concerns regarding the negative impact that wood-fuelled boilers can have on air quality, and therefore human health. However, the government also understands that wood-fuelled boilers can play a key role in reducing carbon emissions in rural, off-grid locations. The government also acknowledges that, given their cost, this VAT relief can make a material difference to households’ ability to install wood-fuelled boilers.

Therefore, for now, wood-fuelled boilers will remain in scope of this VAT relief. However, the government will continue to consider the right VAT treatment for wood-fuelled boilers. This will include undertaking further analysis on the impacts of this technology to build on the evidence provided through the CfE.

Charities

Questions 14-17 of the CfE sought views on reinstating the VAT relief for the installation of qualifying technologies in buildings intended for use solely for a relevant charitable purpose. In particular, these questions sought insight into charities’ intentions to install ESMs in their premises and the impact a VAT relief would have on their decision to do so. These questions also sought views on the advantages and disadvantages of this re-instatement.

42 responses were received to these questions, all of which were supportive of the relief being re-instated for the installation of qualifying ESMs in relevant charitable buildings. Respondents highlighted, in particular, that charities often rely on fundraising to install ESMs, and noted that this relief could therefore make a material difference to the speed at which charities are able to install ESMs.

9 respondents suggested that the definition of a charity building proposed in the CfE should be broadened to ensure that buildings such as village halls and multipurpose spaces also benefit from the relief should it be reintroduced.

The only disadvantage to this reform noted by respondents was the potential cost to the Exchequer.

Government response

Prior to August 2013, UK legislation provided a VAT relief for the installation of ESMs in a building intended for use solely for a relevant charitable purpose. However, discussions with the European Commission identified that the UK’s application of the ESM relief to charitable buildings was not compatible with European Union (EU) law, and the relief was subsequently narrowed to exclude charitable buildings. Since 2013, the relief has therefore only applied to installations of qualifying materials in residential and domestic accommodation.

The government was encouraged to hear from respondents, including charities themselves, that this VAT relief would make a material difference to charities’ ability to install ESMs, and thus improve the energy efficiency of their premises. Therefore, now that the UK has left the EU and agreed the Windsor Framework, the government will reinstate this relief for the installation of qualifying ESMs in buildings used solely for a relevant charitable purpose. This means that qualifying charities will be able to install all ESMs within scope of this relief VAT free until 31 March 2027, helping them to improve the energy efficiency of their properties and bring down their energy bills.   

The government considered respondents’ concerns that the definition of a charity building proposed in the CfE did not capture all intended buildings – such as village halls, where the owners can let these spaces out for commercial purposes. The term “relevant charitable purpose” is defined as “use by a charity otherwise than in the course or furtherance of business”. However, an extra-statutory 5% de minimis threshold is applied to the word “solely”, meaning that, providing a building is 95% used for non-business purposes, it is deemed a qualifying building. Given that this definition already exists in VAT legislation and was explicitly designed to include village halls and similar buildings (such as sports pavilions, church halls and community centres), the government intends to retain the definition of a charity building proposed in the CfE.

Other issues

Questions 18 and 19 of the CfE welcomed any miscellaneous suggestions for making the relief more effective and efficient. A variety of responses were given to these questions. Outlined below are the most common proposals raised by stakeholders through both CfE responses and engagement with government officials. A full list of additional suggestions can be found in Annex D.

3 respondents suggested that groundworks necessary for the installation of certain types of heat pumps should also benefit from the relief, despite this activity typically being co-contracted for insurance reasons. Respondents argued that, because these groundworks are integral to the installation of types of heat pumps that are eligible for the relief, the groundworks should also qualify.

14 respondents suggested that this relief should be able to be apportioned when ESMs are installed as part of a wider construction project, as this would allow more people to access the relief. Respondents also highlighted other areas of the VAT system where apportionment of a relief is permitted and questioned why this VAT relief is treated differently.        

10 respondents suggested that the sunset date for this relief (currently set at 31 March 2027) should be extended, either so that the relief is perennial or so that its sunset clause aligns with broader government climate targets. 

Government response

Heat pump groundworks

The government understands that, for insurance reasons, the groundworks necessary for the installation of certain types of heat pumps are typically co-contracted to different suppliers to those who are completing the rest of the installation. As these works are being completed by two separate companies, this creates two independent supplies – only one of which currently qualifies for this VAT relief.

The government recognises that groundworks, such as the digging of trenches and/or drilling of boreholes for ground arrays, are integral to the installation of ground-source and water-source heat pumps. Therefore, as the intention of this relief is to relieve the whole installation process of VAT, the government will add a discrete list of groundworks necessary for the installation of ground-source and water-source heat pumps to the VAT relief, so that these named activities also qualify for relief, even when co-contracted to specialist suppliers.

The extension of the relief in this way will apply specifically to the groundworks that will be defined in VAT legislation, and not all co-contracted activities. 

Apportionment of the relief

Another one of the most commonly requested reforms was to allow the relief to be apportioned when an ESM is installed as part of a wider construction project, such as a house refurbishment. Having analysed this proposal in depth, the government has concluded that this reform does not satisfy all the objectives of the relief and will not, therefore, be taken forward.

Specifically, this reform does not align with broader VAT principles (objective 3 of the relief). This is because a construction project carried out by one supplier comprising of multiple different elements is a single supply, and it is a fundamental VAT principle that a single supply carries a single VAT treatment. Implementing this reform could therefore create uncertainty regarding the VAT treatment of all supplies involving multiple components. As set out in the CfE, this could lead to legal disputes – something that could ultimately be very costly to taxpayers.

The government acknowledges that there is precedent elsewhere in the VAT system for applying a different VAT liability to one component of a single supply. For instance, when disability-related adaptations are done alongside wider home renovations, these adaptations are zero rated, while the rest of the work remains standard rated. However, in order for disabled consumers to benefit from this VAT relief, evidence that they have a certified disability that the adaptations support is required. As this is a very targeted VAT relief, the government is of the view that the additional administrative burden that this places on consumers, suppliers and HMRC is proportionate.

However, a VAT relief that is available to anyone installing a qualifying ESM in a residential or charity building alongside wider building renovations would be much broader. As such, associated evidence and verification requirements would be significantly more burdensome for consumers to provide and for HMRC to process. Indeed, it would require consumers and suppliers to provide HMRC with robust evidence to ensure that the relief was being apportioned accurately, adding further complexity into the tax system. Furthermore, given the unprecedented nature of allowing VAT reliefs to be apportioned on this scale, operationalising such a reform would come at a high cost to HMRC – something that would ultimately be borne by the taxpayer. Consequently, the government’s view is that this proposal does not meet objective 2 of the relief (cost effectiveness) either.

Sunset clause

This temporary VAT zero rate was introduced for a period of 5 years from the date of its implementation. This means that it is due to expire on 31 March 2027, at which point the installation of technologies within scope of this relief (including those that are added to the relief following this CfE) will revert to the reduced rate of VAT at 5%. This reduced rate of VAT will apply to the installation of qualifying ESMs in both residential buildings and buildings used solely for relevant charitable purposes.    

The government remains committed to its longer-term objective to improve the energy efficiency of the UK’s housing stock, and ultimately, reach net zero greenhouse gas emissions by 2050. While the government recognises the key role that this relief plays in helping to achieve these objectives, it would not be fiscally prudent to take the decision to extend this zero rate beyond 31 March 2027 at this stage. However, the government retains its discretion to extend this zero rate ahead of its 2027 sunset date, at a time when the government will have richer data on the impact of this VAT relief and a clearer sense of the post-2027 fiscal picture.

Next steps

The government would like to reiterate its thanks to those who have contributed to this CfE process. It is also grateful for the breadth of reforms that were proposed, all of which were analysed in depth and considered against the relief’s stated objectives ahead of any policy decisions being taken.

To summarise, as a result of this CfE, the government will be making the following reforms to the VAT relief on the installation of qualifying ESMs.

The government will be expanding the relief by bringing the following technologies within scope:

• electrical battery storage
• water-source heat pumps
• diverters retrofitted to ESMs such as solar panels and wind turbines

The relief will also be extended to the installation of all qualifying ESMs in buildings used solely for a relevant charitable purpose and will continue to apply when these ESMs are installed in residential buildings.

A discrete list of groundworks necessary for the installation of certain types of heat pumps will also be brought within scope of the relief, thus allowing all aspects of the installation of ground-source and water-source heat pumps to be relieved of VAT, even those activities that are co-contracted.

The government intends to implement these reforms on 1 February 2024.   

All of these reforms will apply across the whole of the United Kingdom as a result of the Windsor Framework. These reforms will also be permanent, meaning that, when the zero rate aspect of this relief sunsets on 31 March 2027, the installation of all technologies in scope of this relief will revert to the reduced rate of VAT at 5%.

Annex A: List of respondents

In addition to 19 responses from individuals, responses were received from the following businesses and organisations:

Abbas and Avington Village Hall	Action with Communities in Rural England	Airex
Almhouse Charity	Anchor	Anglian Home Improvements
Ariston Group	Asthon Keynes Village Hall	Atlas Roof Solutions
British Blind and Shutter Association	British Electrotechnical and Allied Manufacturers Association	British Property Federation
British Universities Finance Directors Group	British Woodworking Federation	BSI Group
Building Engineering Services Association	Calor	Carey Hall
Cenergist	Centrica	Centurion VAT Specialists
Charities’ Property Association	Charity Finance Group	Charity Tax Group
Chartered Institute of Housing	Chartered Institute of Taxation	Churches’ Legislation Advisory Service
Cooll	Country Land and Business Association	CubeRoot Energy Ltd
Customade Group
Dave Edwards Double Glazing Ltd	Deloitte	Dimenta
E.ON	Eco-Max	EDF Energy
Energee Services	Energy and Utilities Alliance	Energy Saving Trust
Energy UK	Epwin Window Systems	Fitter Home Limited
Garnalex	Glass and Glazing Federation	Glasswin Solution Limited
Grampian Housing	Ground Source Heat Pump Association	Heat Pump Association
Heat Pump Federation	Historic Houses	Holt Village Hall
Institute of Chartered Accountants in England and Wales	Kensa	Kingfisher Plc
Kirby Joinery Limited	Knauf Insulation	LGS Windows
Liquid Gas UK	LoftZone	Mcs Charitable Foundation
Mineral Wool Insulation Manufacturers association	Mixergy Ltd	Mozark Limited
Myenergi	National Housing Federation	National Trust
Nationwide Windows Ltd	NCVO	Next Generation Rooflights
Octopus Energy	Okeford Fitzpaine Village Hall	Origin
Overton Community Association	Peabody	Places for People
Powervault Limited	R A brown Heating Services Ltd	Reynaers Aluminium
Royal Institute of British Architects	Russell Construction (Richmond) LTD	Sashed
Scottish Land and Estates Limited	Scottish Power	Sero
Solar Energy UK	Southwood Windows Limited	Square-deals Limited
Starglaze Windows and Conservatories Ltd	Sustainable Energy Association	Tepeo
Terra Energy Solutions	The Association for Decentralised Energy	The Association of Renewable Energy and Clean Technology
The Building Research Establishment Group	The Sash Window Workshop Trading Ltd	The University of Edinburgh
Thermal Storage UK	Twyford Parish Hall	UK Green Building Council
University of Glasgow	Valliant Group	Verwood Memorial Hall Trust
Whimple Victory Hall	Wilstone Village Hall	Window Plus
Yelvertoft Village Hall

Annex B: Call for evidence questions

Battery Storage

Do you think battery storage should be included in the relief when:

Question 1: Retrofitted to a solar panel or other ESMs (please provide details)?

Question 2: As a standalone technology not connected to another ESM?

If so:

Question 3: Can you explain how this type of battery storage would meet each of the 3 objectives set out in Chapter 2?

Question 4: Can you explain how this type of battery storage operates?

Question 5: What is the typical cost of installing this type of battery storage in residential accommodation?

Question 6: What are the advantages and disadvantages of including this type of battery storage within the relief?

Other Technologies

Are there any other technologies you believe meet our objectives, but do not currently qualify for the relief?

If so, for each technology, can you answer the following questions:

Question 7: How would you describe and define this technology for the purposes of the ESMs relief?

Question 8: How does the suggested technology meet each of the 3 objectives in Chapter 2?

Question 9: Can you explain how this technology operates and does it work conjunction with other technology? If so, how?

Question 10: What is the typical cost of installing this technology in residential accommodation?

Question 11: What are the advantages and disadvantages of including this technology within the relief?

Are there any technologies which currently qualify for the relief which you believe do not meet the 3 objectives and should not qualify for the relief? If so:

Question 12: Which technology does not meet the 3 objectives?

Question 13: Can you explain why you think that this technology does not meet any of the 3 objectives and therefore should not be included within the relief?

Charities

Question 14: Do you think the relief for the installation of ESMs in a building intended for use solely for a relevant charitable purpose should be reinstated? And if so, why?

Question 15: As a charity are you considering installing ESMs in your buildings?

If yes,

• what ESMs are you considering installing?
• what impact would VAT relief have on this decision?

Question 16: To what extent do you think that charities would benefit from the reinstatement of this relief?

Question 17: What are the advantages and disadvantages of reinstating the relief?

Other Issues

Question 18: Are there any other suggestions you have for making the relief more effective and efficient?

Question 19: Are there any other issues that you would like to raise?

Annex C: All proposed technologies

• blinds, shutters and awnings
• district heating
• diverters
• EV charging points
• heat interface units
• heat pump crates/covers
• high recovery hot water cylinders
• home energy management systems
• hybrid heat pumps
• insulation protection
• LED low voltage lighting
• low embodied carbon insulation
• mechanical and non-mechanical ventilation
• microgeneration units
• non-residential solar panels
• radiant and infrared lighting
• small scale flywheel
• supercapacitors
• thermal-driven heat pumps
• thermal storage
• thermostatic radiator valves
• voltage optimisers
• water efficiency products
• water-source heat pumps
• wet retrofit underfloor heating insulation
• windows, doors and rooflights

Annex D: Other issues

• extend the relief to a wider range of buildings
• extend the relief to ESMs purchased directly from retailers and then self-installed
• extend the relief to upgrades, repairs, and maintenance of ESMs that have already been installed
• take a ‘fabric first’ approach by incentivising maximising the performance of materials that make up the building fabric itself before incentivising the installation of ESMs
• mandate passthrough of this VAT relief from suppliers to consumers
• extend the relief to materials used for the installation of a qualifying ESM, such as scaffolding
• extend the relief to all ESMs to ensure the list of qualifying technologies never becomes outdated