While the 2031 EPC requirements are technically more achievable than they were for much of the UK logistics sector, financial viability is highly variable. For prime assets and portfolios, the business case is strengthened by market demand and risk mitigation. For older or marginal assets, significant capital investment may not be justifiable, leading to potential asset obsolescence and the sector may need to continue to lobby for clearer guidance and financial support to bridge the gap.
In summary, achieving compliance with tightening EPC requirements in the sector requires substantial investment, collaboration between stakeholders, and a strategic approach to property management. Without coordinated action, the sector risks regulatory penalties, asset obsolescence, and missed opportunities in the transition to a low-carbon economy.
Preparation for EPC 2031 for those in the logistics sector should take a proactive, strategic approach and will require a blend of technical, legal, financial, and operational actions. Early engagement, strategic planning, and legal review are critical to mitigate compliance risk and maximise asset value.
Here are key steps, supported by relevant legal and practical considerations:
1. Audit and assess current portfolio - Conduct a comprehensive EPC audit across all assets to establish baseline ratings for Larger Properties and identify those at risk of non-compliance and review lease terms to determine landlord/tenant responsibilities for energy efficiency works.
2. Strategic planning and budgeting - Develop a phased plan for upgrades, prioritising assets with the lowest EPC ratings and highest business value and set budgets for retrofit works, considering capital expenditure, operational disruption, and potential funding sources.
3. Technical upgrades - Typical interventions include improving insulation (walls, roof, doors), upgrading lighting to LED, installing efficient heating, ventilation, and air conditioning (HVAC) systems, incorporating renewable energy solutions (solar PV, battery storage) and enhancing building controls and automation.
4. Lease and contract review - Review lease agreements to clarify who bears responsibility for upgrades and how costs can be recovered and consider negotiating “green lease” clauses that incentivise energy efficiency and clarify obligations.
5. Stakeholder engagement - Communicate plans with tenants, investors, and lenders—especially as ESG requirements are increasingly important in procurement and investment decisions and collaborate with occupiers to minimise disruption and maximise operational benefits.
6. Seek exemptions and legal advice - In some cases, buildings may not be capable of cost-effective improvement to EPC B. Apply for exemptions where eligible, such as “all improvements made” or “devaluation” exemptions under the Energy Efficiency (Private Rented Property) (England and Wales) Regulations 2015 and obtain legal advice on compliance, risk, and exemption applications.
7. Monitor regulatory developments - The government’s proposals are not yet final and may be subject to change. Stay updated via official sources and industry bodies.
8. Consider asset strategy - For assets where upgrade is not viable, consider repurposing, selling, or redeveloping to avoid “stranded asset” risk.
9. Explore funding and incentives - Investigate government grants, green loans, and enhanced capital allowances for energy efficiency works and consider partnerships with occupiers or utility companies to co-fund improvements.
10. Embed energy performance in investment decisions - Integrate EPC compliance and energy efficiency into acquisition, disposal, and development strategies to future-proof portfolios.