CROSS-STANDARD public interest · Data-center liquid cooling (cold plate / CDU)

China-to-EU Data-center Liquid Cooling Compliance Gap Matrix

AI-compiled from official public sources — cross-checked by multiple AI models, not human-verified. Informational only; see disclaimer. Public-interest, source-linked comparison of common China data-center liquid cooling documentation against EU CE, environmental, coolant, server ecodesign, and energy-reporting expectations.

Dataset 2026-06-11 Last verified 2026-06-11 9 rows

GAP MATRIX

Compliance Gap Matrix

Gap matrix
Compliance item Common China baseline European Union (CE) Gap / action Source + verification date
Ecodesign requirements for servers and data storage products [UNVERIFIED] China addresses server energy efficiency through GB 40879-2021 (Energy efficiency limits and grades for data centres) and GB/T 51409-2021 (Technical standard for green data centres). These set PUE limits and energy efficiency grades for data centre infrastructure, but do not directly impose product-level ecodesign obligations equivalent to EU 2019/424. Server product energy efficiency is partially addressed under separate GB standards for IT equipment (e.g., GB 28380 series [UNVERIFIED]). No single mandatory CN regulation mirrors the EU server ecodesign product registration and reporting mechanism.[object Object]
[object Object]		 Regulation (EU) 2019/424 sets mandatory ecodesign requirements for servers and data storage products placed on the EU market, covering energy efficiency metrics (idle power, active efficiency), product information requirements, and mandatory reporting of energy performance data. Manufacturers must ensure servers meet minimum energy efficiency thresholds and provide technical documentation. Applies to enterprise servers, microservers, and data storage products.[object Object]
[object Object]		 EU Regulation 2019/424 imposes product-level mandatory ecodesign requirements (idle power, active efficiency, product information disclosure, technical documentation) on servers and data storage equipment sold in the EU. China has no direct equivalent product-level ecodesign regulation for servers; GB 40879 and GB/T 51409 target data-centre-level PUE and infrastructure efficiency rather than individual server product performance. Chinese liquid-cooling products for data centres destined for the EU market must comply with EU 2019/424 product obligations, which currently have no CN regulatory mirror. Exporters face a gap in mandatory product-level energy labelling and efficiency documentation requirements.Products (servers, data storage) sold in the EU must comply with Regulation (EU) 2019/424 ecodesign requirements — this is a mandatory product obligation. Chinese manufacturers exporting servers or data-centre cooling equipment to the EU must meet EU energy efficiency thresholds and documentation requirements. No equivalent product-level CN regulation exists; compliance requires EU-specific conformity assessment. This information is provided for general reference only and does not constitute legal or regulatory advice. EUR-Lex / European Commission2026-06-12 · unverified
EU data-centre energy performance reporting — PUE disclosure and EN 50600 facility standards [UNVERIFIED] China requires PUE reporting for large data centres under national and provincial policies. GB 40879-2021 sets mandatory PUE energy efficiency limits (e.g., PUE ≤ 1.4 for new data centres in most regions [UNVERIFIED]). The Ministry of Industry and Information Technology (MIIT) issued guidelines requiring new large data centres to meet PUE ≤ 1.3 in hot climates and ≤ 1.25 in cold climates [UNVERIFIED — figures vary by year and region]. China does not have a direct equivalent to EN 50600 as a harmonised facility standard; GB/T 51400 series [UNVERIFIED] may partially address data-centre engineering. Voluntary green data-centre certification schemes exist (e.g., MIIT green data-centre list). Reporting to a central EU-style public database is not required under current CN law.[object Object]
[object Object]		 Energy Efficiency Directive (EU) 2023/1791 Article 12 requires operators of data centres with IT load ≥500 kW to report energy performance data (incl. PUE, renewable energy use, water usage, waste heat) to a designated EU database annually from 15 May 2024. Commission Delegated Regulation (EU) 2024/1364 specifies the exact data points and reporting format. EN 50600 series (IEC/EN 50600-1 to 50600-4) is a voluntary European technical standard family for data-centre facilities and infrastructure, including cooling efficiency and PUE-related metrics; it may support compliance evidence or contractual specifications but is not itself the mandatory legal obligation. The EU Code of Conduct on Data Centre Energy Efficiency (voluntary) provides best-practice guidance on cooling optimisation.[object Object]
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[object Object]		 EU EED Article 12 + Delegated Regulation 2024/1364 create a mandatory annual PUE and energy-data reporting obligation to an EU public database for data centres ≥500 kW operating in the EU — this has no CN equivalent obligation. EN 50600 provides voluntary technical classifications for cooling efficiency and facility performance that differ from the CN GB framework; it may be used as supporting evidence or a contractual benchmark, but the mandatory duty comes from the Directive and Delegated Regulation. Chinese liquid-cooling equipment suppliers whose products are installed in EU data centres may be asked to provide performance data compatible with EN 50600 cooling metrics. The CN PUE approach is directionally similar but the specific thresholds, reporting format, and public disclosure obligations diverge significantly from the EU regime.Data centres operating in the EU with IT load ≥500 kW are subject to mandatory annual energy performance reporting under EED (EU) 2023/1791 Article 12 and Delegated Regulation (EU) 2024/1364 from May 2024. Cooling equipment and liquid-cooling solutions supplied into these facilities should be capable of providing PUE-compatible performance data, and may use EN 50600-aligned metrics as voluntary support for operator compliance or contract specifications. Chinese manufacturers face a gap: CN regulatory frameworks do not require equivalent public reporting or EN 50600-format documentation. EU-market compliance requires understanding and supporting the legal reporting obligations. This information is provided for general reference only and does not constitute legal or regulatory advice. EUR-Lex / European Parliament and Council2026-06-12 · unverified
CE Marking — Combined LVD, EMC, Machinery Directive, PED, WEEE and EU Responsible Person There is no single Chinese certification equivalent to the EU multi-directive CE bundle for data-centre cooling assemblies. China Compulsory Certification (CCC) — administered by CNCA/CQC — covers certain electrical products (e.g. household appliances, IT equipment power supplies) listed in the CCC Catalogue but does not generally extend to industrial cooling units, CDUs or liquid-cooling infrastructure used in data centres; such products typically fall outside the CCC Catalogue scope. Pressure-vessel components may be subject to the Safety Technical Supervision Regulation for Special Equipment (TSG 21) administered by SAMR, which requires a Manufacturing Licence and periodic inspection — this is a domestic safety licence, not an export conformity mark. EMC for relevant sub-systems may be assessed under GB/T 9254 / GB 17625 series (harmonised with CISPR/IEC). There is no Chinese mandatory take-back or producer-registration scheme equivalent to WEEE for this product category, and no equivalent to the EU responsible-person requirement under Regulation 2019/1020. [UNVERIFIED: exact CCC Catalogue exclusion for CDUs — manufacturers should verify the current CCC product list published by CNCA.]Regulations on Compulsory Product Certification (State Council Order No. 117, 2001, amended) — CCC Catalogue scope
Safety Technical Supervision Regulation for Pressure Vessels (TSG 21-2016, SAMR) — domestic special-equipment licence only
GB/T 9254.1-2021 / GB 17625 series (EMC, harmonised with CISPR 32 / IEC 61000)
GB/T 19001 (ISO 9001 equivalent, voluntary quality management — not a market-access requirement)		 A data-centre cooling unit (CDU) or liquid-cooling assembly placed on the EU market must bear the CE mark demonstrating conformity with every applicable New Approach directive. For a typical CDU the applicable directives are: (1) Low Voltage Directive (LVD 2014/35/EU) — covers the electrical components and controls; (2) EMC Directive (2014/30/EU) — covers electromagnetic emissions and immunity of the electronic drive and controls; (3) Machinery Directive (2006/42/EC, to be replaced by Machinery Regulation (EU) 2023/1230 from 20 January 2027) — covers the mechanical assembly including pumps, compressors and moving parts; (4) Pressure Equipment Directive (PED 2014/68/EU) — applies where refrigerant circuits or hydraulic loops exceed the category I pressure/volume thresholds of Art. 4(1); below those thresholds, Article 4(3) good-engineering-practice applies and the PED CE mark is not affixed, but fluid safety must still be addressed. Additionally, Regulation (EU) 2019/1020 on market surveillance requires an identifiable economic operator established in the EU — manufacturer (if EU-based), importer, or mandated authorised representative — who holds the technical file and is identified on the product. The WEEE Directive (2012/19/EU) applies to the electronic sub-assemblies; the producer (or their EU importer/representative) must register in national WEEE registers in each member state of sale. The exact PED category and the choice of Notified Body involvement depend on the refrigerant group (Group 1 or 2 per PED Annex II) and the pressure-volume product; these must be calculated for the specific design. [UNVERIFIED: that all four directives simultaneously apply to every CDU model — applicability of PED and Machinery Directive depends on design parameters and must be confirmed for the specific product.]Directive 2014/35/EU (LVD) — Art. 6–10, Annex III (EU DoC), Annex IV (technical documentation)
Directive 2014/30/EU (EMC Directive) — Art. 7–14, Annex III (EU DoC), Annex II (technical documentation)
Directive 2006/42/EC (Machinery Directive) — Art. 5, Annex II (EC Declaration of Conformity), Annex VII (technical file); to be superseded by Regulation (EU) 2023/1230 from 20 January 2027
Directive 2014/68/EU (PED) — Art. 4 (scope and thresholds), Annex II (fluid groups), Annex III (conformity assessment modules); Category I–IV determines Notified Body involvement
Regulation (EU) 2019/1020 — Art. 4 (responsible economic operator), Art. 5 (authorised representative tasks)
Directive 2012/19/EU (WEEE) — Art. 16–17 (producer registration and reporting)
Decision No 768/2008/EC — Module A (internal production control), Module B+D/E/F (third-party routes for higher PED categories)
EN ISO 4126 series (safety devices for protection against excessive pressure — supporting PED assessment)
EN 55032 / EN 55035 (EMC for multimedia equipment — applicable to embedded electronics)		 Chinese manufacturers exporting data-centre cooling assemblies to the EU face a substantially heavier compliance bundle than their domestic regime requires. The key gaps are: (1) a multi-directive CE mark (LVD + EMC + Machinery Directive + PED where applicable) must be obtained — no Chinese domestic certification satisfies any of these legal obligations; (2) an EU Declaration of Conformity covering all applicable directives and a directive-compliant technical file must be compiled from scratch; (3) for PED Category II or above, a EU Notified Body must be engaged — no Chinese body substitutes; (4) an EU responsible person (manufacturer, importer or authorised representative) must be identified on the product under Regulation 2019/1020 — no domestic analogue exists; (5) WEEE producer registration in each EU member state of sale is required for the electronic sub-assemblies; (6) the Machinery Directive (2006/42/EC) will be replaced by Machinery Regulation (EU) 2023/1230 from 20 January 2027, requiring re-assessment of conformity routes for products placed on the market after that date. Voluntary harmonised standards may be used to create a presumption of conformity for relevant essential requirements, but alternative technical specifications are allowed if compliance with the applicable directives/regulations is demonstrated.Gap identified. A data-centre cooling assembly (CDU) exported from China to the EU requires a combined CE mark spanning LVD, EMC Directive, Machinery Directive and (where pressure thresholds are met) PED — none of which is satisfied by any Chinese domestic certification. An EU Declaration of Conformity, directive-compliant technical file, EU responsible person (Reg 2019/1020), and WEEE producer registration are all additionally required where in scope. Harmonised standards can support a presumption of conformity but are not the sole mandatory route. PED category and Notified Body requirements must be determined for the specific product design. This is an informational summary only and does not constitute legal or regulatory advice. [UNVERIFIED: exact PED category classification and precise Machinery Regulation transition obligations — verify against current EUR-Lex text and consult a qualified EU conformity consultant for product-specific determination.] European Commission2026-06-12 · unverified
RoHS — Restriction of Hazardous Substances in Electronic Equipment GB/T 26572-2011 is the Chinese equivalent, restricting the same 6 original RoHS substances (Pb, Hg, Cd, Cr(VI), PBB, PBDE) in electrical and electronic products. The four phthalates (DEHP, BBP, DBP, DIBP) added by EU Directive 2015/863/EU are not yet mandatorily restricted under CN GB/T 26572 as of 2026-06-12, creating a gap. SJ/T 11364 governs labelling (orange logo with component table).GB/T 26572-2011 (restricted substances in EEE)
SJ/T 11364-2014 (hazardous substance labelling)		 Directive 2011/65/EU (RoHS 2), as amended by Directive 2015/863/EU, restricts 10 substances (Pb, Hg, Cd, Cr(VI), PBB, PBDE, DEHP, BBP, DBP, DIBP) in electrical and electronic equipment (EEE). Data-centre liquid cooling units that contain electronic sub-assemblies (power boards, sensors, controllers, pumps with electronic drives) fall within Category 4 (consumer) or Category 5 (IT/telecom) EEE scope. Maximum concentration values apply at the homogeneous material level. CE marking under RoHS is required for EU market access. EN IEC 63000:2018 is a voluntary harmonised standard for RoHS technical documentation that can confer a presumption of conformity; alternative evidence may be used if it demonstrates compliance with the Directive.Directive 2011/65/EU (RoHS 2)
Directive 2015/863/EU (amending Annex II — adds DEHP, BBP, DBP, DIBP)
EN IEC 63000:2018 (technical documentation for RoHS assessment)		 EU RoHS 2 mandates restriction of 10 substances including 4 phthalates; CN GB/T 26572 covers only the original 6. Products compliant with CN RoHS may still fail EU RoHS if phthalate content in plastic or elastomer parts exceeds 0.1% wt. Exporters must conduct homogeneous-material testing for DEHP, BBP, DBP, DIBP specifically.Gap exists on phthalates. CN-manufactured cooling units are typically compliant on the 6 original substances but require additional evidence, testing and possible material substitution to meet the 4 EU-added phthalate restrictions before EU export. EN IEC 63000 may be used voluntarily for the technical documentation route, but RoHS compliance itself is required by the Directive. Informational only — verify with accredited test lab. EUR-Lex / European Parliament and Council2026-06-12 · unverified
REACH — SVHC and Chemical Registration for Coolant Fluids and Structural Materials China does not have a direct REACH equivalent. The closest instruments are: MEE Order No. 12 (2020) — New Chemical Substance Environmental Management Registration Measures (similar to REACH registration for new substances); GB 30000 series (hazardous chemical classification, aligned with GHS/UN); and GB 15258 (SDS requirements). Existing substances in China do not require registration under an SVHC-equivalent Candidate List system. The REACH Candidate List obligation (0.1% SVHC communication) has no direct CN analogue.MEE Order No. 12 (2020) — New Chemical Substance Environmental Management Registration
GB 30000 series (chemical hazard classification, GHS-aligned)
GB 15258-2009 (Safety Data Sheets)		 Regulation (EC) No 1907/2006 (REACH) requires registration of substances manufactured or imported into the EU above 1 tonne/year, and imposes supply chain communication (Safety Data Sheets) for substances of very high concern (SVHC) on the Candidate List at concentrations above 0.1% w/w in articles. For data-centre liquid cooling: (1) structural materials (metals, polymers, seals) must be checked against the REACH Candidate List (250+ SVHCs as of 2026-06-12); (2) single-phase coolants (water-glycol mixtures, synthetic esters) are chemical preparations subject to REACH mixture classification; (3) two-phase dielectric coolants (fluorinated fluids, hydrofluoroethers) may contain PFAS substances — many of which are under active restriction proposals via REACH Annex XV (see row 03). Importers into the EU act as downstream users and must ensure upstream suppliers provide up-to-date SDSs.Regulation (EC) No 1907/2006 (REACH), Title II (Registration), Title IV (SVHC/Candidate List communication), Annex XV (restriction dossiers)
ECHA Candidate List of SVHCs (updated periodically — 250+ entries as of 2026-06-12)
ECHA Guidance on requirements for substances in articles (2011, rev. 2017)		 Significant gap. EU REACH requires proactive SVHC screening of every material and component against a growing Candidate List, plus SDS obligations flowing through the supply chain. CN has no equivalent system for existing substances. CN-manufactured cooling systems exported to EU require full SVHC Candidate List screening of all articles; coolant fluid suppliers must provide EU-compliant SDSs. The gap is especially acute for specialty polymers, seals, and thermal interface materials that may contain legacy SVHCs (e.g., PFOS, certain phthalates, boric acid compounds).Gap is structural and ongoing. CN supply chains rarely maintain EU-format SDSs or conduct SVHC Candidate List screening. Exporters must obtain REACH-compliant SDSs from coolant and material suppliers and should commission SVHC screening using suitable methods; IEC 62321-series methods may support evidence where relevant but are not the legal obligation. Informational only — verify with REACH legal counsel and accredited laboratory. EUR-Lex / European Parliament and Council2026-06-12 · unverified
PFAS Restriction and F-gas Regulation — Dielectric Coolant Fluids for Immersion and Two-Phase Cooling [PROPOSED — not yet adopted, not in force] China has no PFAS-specific restriction equivalent for dielectric coolants as of 2026-06-12. China is a signatory to the Stockholm Convention (which restricts legacy PFOS/PFOA under POPs), implemented via MEE/MEP regulations (e.g., Order No. 41 — PFOS restriction). However, the broad PFAS category targeted by the EU proposal (including short-chain PFAS and fluorinated ethers used as dielectric fluids) is not restricted under CN regulations. For F-gases: China has HFC phase-down obligations under the Kigali Amendment to the Montreal Protocol (ratified 2021), implemented via the MIIT/MEE HFC phase-down plan, but no direct equivalent to the EU F-gas equipment-level restrictions.Stockholm Convention (PFOS/PFOA legacy POPs) — CN implementing Order No. 41 (PFOS restriction)
Kigali Amendment to the Montreal Protocol (HFC phase-down, ratified by CN 2021)
MIIT/MEE HFC Phase-Down Implementation Plan		 [UNVERIFIED — restriction under development] Two converging EU regulatory pressures apply to fluorinated dielectric coolants used in immersion and two-phase liquid cooling: (1) REACH Annex XV PFAS Restriction — ECHA received a universal PFAS restriction proposal from DE/DK/NL/NO/SE in January 2023 covering ~10,000 PFAS substances. An updated proposal was published August 2025, expanding derogations from 26 to 74 uses across additional sectors. RAC adopted its final opinion on 3 March 2026 supporting an EU-wide restriction with limited derogations. SEAC agreed a draft opinion on 11 March 2026; the 60-day public consultation closed 25 May 2026. SEAC final opinion is expected by end 2026; the European Commission is then expected to draft a REACH Annex XVII amendment, with a Commission decision unlikely before Q3 2027 and restrictions not applying before 2029. Many dielectric coolants (e.g., perfluorocarbon fluids, hydrofluoroethers such as HFE-7100, Novec-type) are PFAS and would be captured. The restriction text and exemption list are not yet finalised — status is [UNVERIFIED — proposal not yet adopted]. (2) F-gas Regulation (EU) 2024/573 — repeals and replaces Regulation (EU) 517/2014; in force 11 March 2024. Applies to fluorinated greenhouse gases (F-gases: HFCs, PFCs, SF6, HFOs and their blends). Two-phase cooling systems using fluorinated refrigerants with GWP > 1 may be subject to phase-down obligations and equipment restrictions under the revised F-gas Regulation. Dielectric fluids that are not refrigerants (e.g., perfluorocarbon liquids used in single-pass immersion) may fall outside F-gas scope but within the PFAS restriction scope — the regulatory boundary depends on fluid classification.REACH Regulation (EC) No 1907/2006, Annex XV — PFAS Universal Restriction Proposal (updated proposal published Aug 2025; RAC final opinion adopted 3 Mar 2026; SEAC draft opinion 11 Mar 2026, public consultation closed 25 May 2026; SEAC final opinion expected end 2026; EC decision expected Q3 2027 at earliest; restrictions not applying before 2029) [UNVERIFIED — not yet in force]
F-gas Regulation (EU) 2024/573 (replaces (EU) 517/2014; in force 11 March 2024; applies to fluorinated GHGs)
ECHA PFAS restriction dossier (reference: https://echa.europa.eu/registry-of-restriction-intentions/-/dislist/details/0b0236e18663449b)		 [UNVERIFIED — EU restriction pending] This is the highest-risk emerging gap for immersion and two-phase cooling exports to the EU. Fluorinated dielectric fluids (Novec-type, HFE series, perfluorocarbon liquids) widely used in CN-manufactured liquid cooling systems are PFAS and may face a broad EU ban under REACH once the restriction is finalised. CN has no equivalent restriction. If the EU PFAS restriction proceeds without sector-specific derogation for data-centre cooling fluids, products using these coolants cannot be placed on the EU market. Vendors should monitor ECHA dossier progress and evaluate PFAS-free alternatives (synthetic esters, PAO oils, water-glycol) now. F-gas GWP-based restrictions add a parallel risk for two-phase vapour-compression systems.[UNVERIFIED — monitor closely] EU PFAS restriction on dielectric coolant fluids is the single largest emerging compliance risk for immersion/two-phase cooling systems targeting the EU market. No CN regulatory equivalent exists. Exporters should: (1) inventory all fluorinated fluids in their cooling systems; (2) monitor ECHA dossier and EC decision timeline; (3) evaluate PFAS-free coolant alternatives proactively. F-gas compliance requires GWP documentation for any fluorinated refrigerant used. Informational only — verify current restriction status with ECHA directly and legal counsel before any compliance decision. ECHA — European Chemicals Agency2026-06-12 · unverified
Electrical Safety — Low Voltage Directive China does not have a single LVD-equivalent directive. Electrical safety for data-centre liquid-cooling equipment is addressed through GB/T 51409-2021 (technical standard for data-centre liquid cooling) and, for telecom data centres, YD/T 2378. Compulsory CCC certification under GB 4943.1 applies to IT/AV equipment, and GB 5226.1 (equivalent to IEC 60204-1) applies to electrical equipment of machines. National-standard compliance is self-declared or third-party tested; there is no unified CE-style single-point EU declaration.GB/T 51409-2021
GB 4943.1-2022
GB 5226.1-2019
YD/T 2378		 CDUs containing pumps, controls, fans, or power supplies operating at 50–1000 V AC / 75–1500 V DC must satisfy LVD 2014/35/EU and bear CE marking before EU market placement. A Declaration of Conformity (DoC) and technical file are mandatory legal requirements. Harmonised standards such as EN 62368-1 (audio/video/IT equipment) or EN 60204-1 (safety of machinery — electrical equipment) may be used voluntarily to confer a presumption of conformity for relevant LVD safety objectives; alternative technical solutions are allowed if the manufacturer demonstrates compliance with the Directive.LVD 2014/35/EU
EN 62368-1:2020
EN 60204-1:2018		 EU law requires LVD conformity, CE marking, an EU Declaration of Conformity and a technical file. Harmonised LVD standards are voluntary presumption-of-conformity tools, not mandatory or sole standards, and the LVD generally uses manufacturer self-assessment rather than Notified Body approval. China's CCC covers only certain product categories and does not satisfy EU LVD. Exporters must build EU-specific evidence, testing and documentation, and ensure an EU economic operator where required.[INFORMATIONAL] A CDU with electrical components operating within LVD voltage ranges must comply with LVD 2014/35/EU and be CE marked. EN 60204-1 or EN 62368-1 may be used voluntarily to support presumption of conformity, but they are not the mandatory legal obligation or the sole route. Chinese CCC certification does not substitute for EU CE marking. Independent gap assessment and suitable EU evidence/testing are required. EUR-Lex / European Parliament and Council2026-06-12 · unverified
Machinery Safety — Pumps and Mechanical Assemblies China regulates pump machinery safety primarily through GB/T 3216 (centrifugal pump testing), GB/T 51409-2021 (data-centre liquid cooling), and general machinery safety standards under GB/T 15706 (equivalent to ISO 12100). There is no single mandatory CE-equivalent machinery directive; compliance is demonstrated through product standards and, where applicable, special equipment supervision under TSG regulations administered by SAMR.GB/T 3216-2016
GB/T 15706-2012
GB/T 51409-2021
TSG 21-2016 (pressure vessels — SAMR)		 Pumps integrated into a CDU may be machinery under Machinery Directive 2006/42/EC and, where the Directive applies, must satisfy the Essential Health and Safety Requirements (EHSRs), carry CE marking and have a DoC. EN ISO 12100 (risk assessment) and EN 809 (pumps for liquids) are voluntary harmonised standards that may support presumption of conformity; alternative risk-assessment and design evidence can be used if it demonstrates compliance with the Directive. From 20 January 2027, Machinery Regulation (EU) 2023/1230 replaces the Directive and introduces digital instructions and updated EHSRs. Incomplete machinery (e.g., a pump sub-assembly) requires a Declaration of Incorporation instead of a full CE mark.Machinery Directive 2006/42/EC
Machinery Regulation (EU) 2023/1230
EN ISO 12100:2010
EN 809:1998+A1:2009		 China has no machinery-directive equivalent requiring a DoC and risk-assessment dossier in the EU format. Chinese pump standards cover performance and basic safety but do not produce an EU-format technical file or CE mark. Exporters must demonstrate compliance with EU machinery EHSRs where the machinery rules apply; EN ISO 12100 can be used voluntarily for risk assessment and presumption support, but it is not the mandatory legal obligation. From January 2027, products placed on the EU market must be assessed against Machinery Regulation 2023/1230 requirements including digital instructions.[INFORMATIONAL] CDU pumps may fall under 2006/42/EC and, where in scope, require CE marking and technical documentation showing EHSR compliance. From 20 January 2027, Machinery Regulation 2023/1230 applies. EN ISO 12100 and EN 809 may be used voluntarily to support presumption of conformity, but Chinese GB/T standards do not produce equivalent EU compliance documentation by themselves. EUR-Lex / European Parliament and Council2026-06-12 · unverified
Pressure Safety — Pressure Equipment Directive (PED) China regulates pressure equipment through the TSG framework administered by SAMR (State Administration for Market Regulation). TSG 21-2016 covers pressure vessels; TSG D0001 covers pressure piping. Pressure vessels above defined thresholds require a manufacturing licence (manufacturing permit) issued by SAMR and periodic inspection by a licensed inspection body. GB 150 (pressure vessels) and GB/T 20801 (pressure piping) are the principal design standards. Liquid-cooling CDU loops using glycol coolants at typical data-centre pressures (2–6 bar) may trigger TSG registration requirements.TSG 21-2016 (pressure vessels — SAMR)
TSG D0001-2009 (pressure piping — SAMR)
GB 150-2011 (pressure vessels)
GB/T 20801-2020 (pressure piping)		 If the CDU coolant loop contains pressure-bearing components (pipes, vessels, heat exchangers) with a maximum allowable pressure above 0.5 bar, the Pressure Equipment Directive 2014/68/EU applies. Equipment is classified into Categories I–IV based on pressure, volume/DN, and fluid group (most water-glycol coolants are Group 2 fluids). Category I may use manufacturer self-certification; Categories II–IV require a Notified Body. PED classification must be performed per Article 13 before CE marking. Equipment below PED thresholds (SEP — sound engineering practice) requires no PED CE mark but must still meet LVD and Machinery requirements.PED 2014/68/EU
EN 13480 (metallic industrial piping)
EN 13445 (unfired pressure vessels)
AD 2000 Merkblatt (common German harmonised standard)		 Both regimes mandate pressure safety but use different classification matrices, design codes, and conformity routes. A CDU pressure vessel certified under GB 150 and TSG 21 does NOT automatically satisfy PED 2014/68/EU; the design must be re-evaluated against PED essential safety requirements, and harmonised standards such as EN 13445 may be used voluntarily to support presumption of conformity. A EU Notified Body must be engaged for PED categories requiring third-party conformity assessment. Conversely, EU PED CE marking is not recognised in China — TSG manufacturing permits and periodic inspections remain required for Chinese market or manufacture. Exporters must run dual certification tracks.[INFORMATIONAL] CDU coolant loops above 0.5 bar must be assessed for PED scope and category under 2014/68/EU before CE marking where PED applies. Chinese TSG/GB certification does not satisfy EU PED requirements. EN 13445/EN 13480 may support presumption of conformity, but the mandatory obligation is PED compliance and any required Notified Body route. Classification outcome depends on actual pressure, volume, DN, and fluid group, which must be assessed per product. EUR-Lex / European Parliament and Council2026-06-12 · unverified

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