CROSS-STANDARD public interest · Water electrolyzer (green hydrogen, AEM/PEM)

China-to-EU Water Electrolyzer 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 water electrolyzer documentation against EU CE, pressure equipment, ATEX, hydrogen safety, and ISO 22734 expectations.

Dataset 2026-06-11 Last verified 2026-06-11 7 rows

GAP MATRIX

Compliance Gap Matrix

Gap matrix
Compliance item Common China baseline European Union (CE) Gap / action Source + verification date
Explosive Atmosphere (ATEX) Equipment Certification for Hydrogen Electrolyzers China requires Ex certification under the GB 3836 series (Electrical apparatus for explosive gas atmospheres), administered by CESI or other CNEX-accredited bodies. The GB 3836 series is technically aligned with IEC 60079 but constitutes a separate national certification regime. Products must obtain a Chinese Ex certificate and explosion-proof mark before sale or use in China. GB/T 3836.1 covers general requirements; subsequent parts mirror IEC 60079 sub-series for specific protection methods.GB 3836.1-2021 (爆炸性环境 第1部分：设备 通用要求)
GB 3836.2 (隔爆型 'd')
GB 3836.4 (本质安全型 'i')
GB 3836.8 (正压型 'p')
GB/T 3836 series (additional parts mirroring IEC 60079 sub-series)		 Equipment and protective systems intended for use in potentially explosive atmospheres (including hydrogen gas zones) must comply with ATEX Directive 2014/34/EU. Hydrogen electrolyzer electrical components in or adjacent to hydrogen-producing zones must be classified and certified under the appropriate equipment category (e.g., Category 1G or 2G for gas/vapour explosive atmospheres). Conformity assessment for Categories 1 and 2 requires involvement of an EU Notified Body; Category 3 allows manufacturer self-declaration. Harmonised standards such as the EN IEC 60079 series (Explosive Atmospheres) are voluntary technical routes that may confer a presumption of conformity with ATEX essential health and safety requirements; alternative evidence is allowed.ATEX Directive 2014/34/EU
EN IEC 60079-0:2018 (Explosive atmospheres — General requirements)
EN IEC 60079-1 (Flameproof enclosures 'd')
EN IEC 60079-11 (Intrinsic safety 'i')
EN IEC 60079-15 (Type of protection 'n')
EN 1127-1 (Explosive atmospheres — Basic concepts and methodology)		 Chinese GB 3836 Ex certificates issued by CNEX-accredited bodies are NOT accepted in the EU. For EU market entry, a separate ATEX conformity assessment under 2014/34/EU is mandatory for equipment in scope, including EU-type examination by a Notified Body for Category 1 and 2 equipment. The CE marking (ATEX) and EU Declaration of Conformity must be obtained. EN IEC 60079 standards may support presumption of conformity but are not the mandatory or sole route. Hydrogen electrolyzer manufacturers holding only Chinese Ex marks must complete the applicable ATEX assessment and affix the specific ATEX Ex marking (including notified body number for categories 1 and 2) before placing equipment on the EU market.[INFORMATIONAL] Equipment for use in hydrogen explosive-atmosphere zones entering the EU market must carry ATEX CE marking under Directive 2014/34/EU. EN IEC 60079 series standards can support presumption of conformity but are voluntary and not exclusive. Chinese GB 3836 Ex certification is a parallel national regime and is not mutually recognised. A separate EU Notified Body assessment is required for Category 1 and 2 equipment. This is informational only and does not constitute legal advice. EUR-Lex / Official Journal of the European Union2026-06-12 · unverified
Machinery Safety Directive (CE) for Hydrogen Electrolyzers China does not have a single direct equivalent to the EU Machinery Directive for electrolyzers. Relevant national requirements include GB standards for pressure vessels (GB 150 series, supervised by SAMR/TSB for special equipment licensing), electrical safety standards (GB 4706 series for household appliances; GB/T standards for industrial equipment), and EMC standards (GB/T 17626 series). Hydrogen-generating equipment may also be subject to special equipment (特种设备) registration under the Special Equipment Safety Law. Industrial water electrolyzers do not appear in the current CCC mandatory product catalogue per CNCA announcements through 2025; CCC applies only to product categories expressly listed.GB 150-2011 (压力容器 Pressure vessels)
Special Equipment Safety Law (特种设备安全法) 2013
GB/T 37563-2019 (质子交换膜燃料电池发电系统安全要求 — adjacent reference)
GB/T 17626 series (EMC, IEC 61000 equivalent)
GB 4943.1 (IT equipment safety, IEC 60950/62368 equivalent) — applies to IT and audio/video equipment; does not apply to industrial electrolyzer systems as complete units		 Water electrolyzers constitute machinery under the EU Machinery Directive 2006/42/EC (replaced by Machinery Regulation (EU) 2023/1230 from 20 January 2027). Manufacturers must conduct a risk assessment covering mechanical, electrical, and hydrogen-specific hazards; prepare a technical file; issue an EU Declaration of Conformity; and affix CE marking before placing the product on the EU market. Harmonised standards, including EN ISO 22734 for hydrogen generators, are voluntary routes that may confer a presumption of conformity for covered EHSRs; alternatives are allowed if conformity is demonstrated. Electrical risks of the complete machine are addressed by the Machinery Directive / Regulation Essential Health and Safety Requirements (EHSRs); the Low Voltage Directive 2014/35/EU (LVD) applies only where a product or sub-assembly is independently within LVD scope (not simply because it contains electrical parts covered by the Machinery EHSRs). The EMC Directive 2014/30/EU applies to electrical/electronic sub-assemblies within its scope.Machinery Directive 2006/42/EC
Machinery Regulation (EU) 2023/1230 (replaces 2006/42/EC; applicable from 20 January 2027)
Low Voltage Directive 2014/35/EU (applies where product/sub-assembly is independently within LVD scope)
EMC Directive 2014/30/EU
EN ISO 22734:2019 (Hydrogen generators using water electrolysis — Industrial, commercial and residential applications; superseded at ISO level by ISO 22734-1:2025 Part 1: Safety, July 2025; EN ISO 22734-1:2025 not yet published in EU Official Journal as harmonised standard as of mid-2026)
EN ISO 13849-1 (Safety of machinery — Safety-related parts of control systems)		 China lacks a unified machinery CE-equivalent certification pathway. For EU market entry, manufacturers must demonstrate conformity and affix CE marking under Machinery Directive 2006/42/EC (or successor Regulation 2023/1230 once effective), LVD 2014/35/EU (where sub-assemblies are independently within LVD scope), and EMC Directive 2014/30/EU as applicable. Chinese national certifications (GB standards, special equipment licences) and any voluntary CCC marks do not substitute for EU CE marking. Manufacturers must compile an EU-format technical file and perform an EU-compliant risk assessment; EN ISO 12100 and EN ISO 22734 may support presumption of conformity where harmonised and applicable, but they are not mandatory or exclusive. Certain machinery categories may need a Notified Body.[INFORMATIONAL] Hydrogen water electrolyzers sold in the EU must carry CE marking under the Machinery Directive 2006/42/EC or, from 20 January 2027, Machinery Regulation (EU) 2023/1230; LVD 2014/35/EU and EMC Directive 2014/30/EU apply where independently in scope. EN ISO 22734 can support presumption of conformity but is voluntary and not exclusive. Chinese GB-based certifications and special equipment licences do not fulfil EU CE marking obligations. Where the electrolyzer also operates in an explosive atmosphere zone, ATEX Directive 2014/34/EU compliance (see row eleceu-atex-explosive-atmosphere) is additionally required. This is informational only and does not constitute legal advice. EUR-Lex / Official Journal of the European Union2026-06-12 · unverified
Water Electrolyzer Safety and Performance (Industrial / Commercial / Residential) China uses GB/T 19774-2005 (Water electrolysis hydrogen generation systems — general requirements) as the primary national standard for water electrolyzers. This GB/T standard covers general technical and safety requirements but has not been harmonized with ISO 22734 and is not directly recognized for CE conformity. Testing and certification typically go through CNCA-accredited bodies; an export product still requires separate ISO 22734 conformity assessment for the EU market.GB/T 19774-2005 (水电解制氢系统) ISO 22734 specifies safety, performance, and test requirements for hydrogen generators using water electrolysis for industrial, commercial, and residential applications. It is a voluntary international standard; it is not itself a legal mandate for EU market access, but EN ISO 22734 may support conformity assessment and risk documentation under applicable EU directives. CE-marking in the EU is mandatory under the applicable EU directives — primarily Machinery Directive 2006/42/EC (replaced by Machinery Regulation (EU) 2023/1230 from 20 January 2027), Pressure Equipment Directive 2014/68/EU where applicable, and other directives depending on product scope. Manufacturers must produce technical documentation and issue a Declaration of Conformity.ISO 22734:2019 (Hydrogen generators using water electrolysis — voluntary technical reference; EN ISO 22734:2019 may support conformity assessment under applicable EU directives; superseded at ISO level by ISO 22734-1:2025 Part 1: Safety, July 2025, but EN ISO 22734-1:2025 not yet listed in EU Official Journal as harmonised standard as of mid-2026)
EU Machinery Directive 2006/42/EC
EU Machinery Regulation (EU) 2023/1230 (replaces 2006/42/EC; applicable from 20 January 2027)
EU Pressure Equipment Directive 2014/68/EU		 Chinese GB/T 19774 is not harmonized with ISO 22734 and is not accepted for EU CE conformity. CE marking for EU market access is mandatory under applicable EU directives (Machinery Directive / Machinery Regulation, PED, and others as applicable) — not under ISO 22734 itself, which is a voluntary standard. EN ISO 22734 may, however, be used to support the technical risk assessment and conformity documentation required by those directives. Exporters must comply with applicable EU machinery and pressure-equipment directives; the conformity assessment route (self-declaration vs. Notified Body) depends on hazard category under each directive. Technical documentation, EU Declaration of Conformity, and CE marking are required — none of which are mandated under the domestic GB/T regime.[INFORMATIONAL] Chinese-manufactured electrolyzers built to GB/T 19774 alone are unlikely to satisfy EU CE-marking requirements. CE marking is mandatory under applicable EU directives (Machinery Directive 2006/42/EC / Machinery Regulation (EU) 2023/1230 from 20 January 2027, PED 2014/68/EU, and others). EN ISO 22734:2019 is a voluntary standard that may support risk assessment and technical documentation under those directives but is not itself the source of the CE obligation; note that ISO 22734-1:2025 (July 2025) supersedes ISO 22734:2019 at the ISO level, though the EN version of the 2025 edition has not yet been listed in the EU Official Journal as a harmonised standard as of mid-2026. Manufacturers targeting the EU market should review which directives apply to their specific product and determine the appropriate conformity assessment route. This is informational only and does not constitute legal or certification advice. International Organization for Standardization (ISO)2026-06-12 · unverified
Hydrogen Fuel Quality and Renewable Hydrogen (RFNBO) Criteria China uses GB/T 37244-2018 (Hydrogen for proton exchange membrane fuel cell vehicles) as the primary national standard for hydrogen purity, covering similar contaminant limits to ISO 14687 for vehicular use. There is no Chinese equivalent to the EU RFNBO green-hydrogen certification framework. Hydrogen produced under GB/T 37244 is not automatically recognized as meeting ISO 14687 specifications without cross-validation, and no bilateral recognition agreement exists with the EU for green-hydrogen certification.GB/T 37244-2018 (质子交换膜燃料电池汽车用燃料氢气) ISO 14687 specifies hydrogen fuel quality characteristics (purity grades and contaminant limits) for fuel cell and other applications; the current edition is ISO 14687:2025 (February 2025, replacing ISO 14687:2019), which adds Grade F for hydrogen internal combustion engine applications. ISO 14687 is a voluntary international standard and may be imposed by contract, offtake specification, station operator rules, or sector schemes, but it is not mandated by Delegated Regulation (EU) 2023/1184. For the EU renewable-energy market, Delegated Regulation (EU) 2023/1184 under the Renewable Energy Directive (RED III / Directive 2023/2413/EU) defines RFNBO eligibility criteria, including additionality, temporal and geographic correlation requirements for electricity used in electrolysis, and a greenhouse-gas saving threshold of at least 70%. RFNBO status governs subsidy, quota, and green-claim eligibility; it is not a product fuel-quality or product-safety mandate.ISO 14687:2025 (Hydrogen fuel quality — Product specification; second edition, February 2025, cancels and replaces ISO 14687:2019; adds Grade F for hydrogen internal combustion engine applications)
EU Delegated Regulation 2023/1184 (RFNBO criteria under RED III)
EU Directive 2023/2413 (RED III — recast Renewable Energy Directive)		 GB/T 37244 covers vehicular hydrogen purity and is broadly comparable to ISO 14687 for that application, but cross-certification is not automatic and ISO 14687 remains a voluntary or contractual fuel-quality specification unless another binding instrument or contract incorporates it. Separately, the EU RFNBO framework (Delegated Reg. 2023/1184) has no Chinese equivalent: exporters or project developers seeking EU green-hydrogen subsidies, quotas, green claims, or RFNBO-labelled offtake must demonstrate compliance with RFNBO additionality, temporal/geographic correlation, and GHG-saving criteria — a compliance pathway absent from the domestic Chinese regulatory environment.[INFORMATIONAL] Chinese hydrogen producers exporting to or seeking EU green-hydrogen recognition face separate commercial and regulatory gaps: (1) ISO 14687:2025 fuel-quality conformity may need independent verification where customers, station operators, or schemes require that voluntary specification — it is not mandated by RFNBO Delegated Reg. 2023/1184; (2) RFNBO status under Delegated Reg. 2023/1184 requires a bespoke eligibility assessment with no Chinese domestic equivalent. This is informational only and does not constitute legal or certification advice. EUR-Lex / Official Journal of the European Union2026-06-12 · unverified
CE Multi-Directive Bundle — PED + ATEX + Machinery Directive + LVD + EMC, EU Declaration of Conformity, Technical File, Notified Body, and EU Responsible Person (Reg 2019/1020) China has no single unified CE-equivalent regime for electrolyzers. The Chinese regulatory patchwork for a water electrolyzer typically involves: (1) TSG (Special Equipment Safety) regulations administered by the State Administration for Market Regulation (SAMR) — pressure vessels and piping in electrolyzers are classified as special equipment; manufacturers must hold a Special Equipment Manufacturing Licence (SEML) and each pressure-bearing component must pass TSG inspection by a government-authorised inspection body; (2) China Compulsory Certification (CCC) — applies to certain electrical components and control systems; industrial water electrolyzers as complete units do not appear in the current CCC mandatory product catalogue per CNCA announcements through 2025; (3) Explosion-proof certification (Ex certification) from CNEX-designated laboratories if the equipment is used in hazardous areas — China's Ex regime follows GB/T 3836 series (equivalent to IEC 60079) but is administered separately from product safety certification; (4) GB standards compliance for hydrogen production equipment: GB/T 19774-2005 (water electrolysis hydrogen production system) is the primary standard — it is a recommended (GB/T) voluntary standard and has not been revised since 2005; GB/T 37562-2019 covers safety requirements for pressure-type systems. Unlike the EU multi-directive CE bundle, Chinese requirements are administered by separate authorities with separate certificates and separate inspection bodies.TSG 21 (Safety Technical Supervision Regulations for Stationary Pressure Vessels, SAMR)
TSG R0005-2011 (Supervision Regulation on Safety Technology for Transportable Pressure Vessels) — applies to transportable/mobile vessels (tank cars, tank containers) ONLY; stationary electrolyzer pressure vessels fall under TSG 21, not TSG R0005
Special Equipment Safety Law of the PRC (2013)
GB/T 19774-2005 (Water electrolysis hydrogen production system) — recommended (voluntary) national standard; current edition is 2005, no revision published as of 2026; GB/T 37562-2019 covers safety requirements for pressure-type water electrolysis hydrogen production systems
GB/T 3836 series (Explosive atmospheres — Ex certification, equivalent to IEC 60079)
CNEX explosion-proof certification (SAMR-authorised)
CCC (China Compulsory Certification, CNCA) — for applicable electrical sub-systems		 A water electrolyzer placed on the EU market is a complex pressure-bearing assembly that typically falls under multiple CE directives simultaneously. The applicable bundle commonly includes: (1) Pressure Equipment Directive 2014/68/EU (PED) — for pressure vessels, piping, and safety accessories operating above 0.5 bar gauge; manufacturers must perform PED classification under Art. 4 / Annex II based on the actual PS×V (or PS×DN) and fluid group — the resulting category (SEP, I, II, III, or IV) determines whether and which Notified Body module applies; do not assume a fixed category without product-specific classification; (2) ATEX Directive 2014/34/EU — applies to equipment and protective systems INTENDED FOR USE in potentially explosive atmospheres (ignition-source based); whether the electrolyzer itself is ATEX-scoped depends on whether it is designed and placed as equipment for use in such atmospheres, not merely on the fact that hydrogen is produced; workplace zoning is a separate employer duty under Directive 1999/92/EC (ATEX workplace); equipment category depends on zone classification where applicable; NB involvement mandatory for categories 1G/2G; (3) Machinery Directive 2006/42/EC (or Regulation (EU) 2023/1230 from 20 January 2027) — the electrolyzer as an assembly of mechanical, electrical, and fluidic components constitutes machinery; Annex IV products (e.g., certain pressure-related machinery) may require NB; (4) Low Voltage Directive 2014/35/EU (LVD) — for electrical components or sub-assemblies independently within LVD scope (50–1000 V AC or 75–1500 V DC); note that electrical risks of the complete machine are also addressed by the Machinery Directive EHSRs; (5) EMC Directive 2014/30/EU — for electrical/electronic sub-assemblies. The manufacturer must draw up a single EU Declaration of Conformity (DoC) referencing all applicable directives, affix the CE mark, compile and retain a technical file for 10 years, and — where directives require a Notified Body — engage an EU-designated NB for type-examination or production quality assurance. Under Regulation (EU) 2019/1020 Art. 4, a non-EU manufacturer must ensure an EU-established responsible economic operator (which may be the manufacturer itself if EU-established, an importer, an authorised representative, or a fulfilment service provider) is designated before placing the product on the EU market.Directive 2014/68/EU (PED — Pressure Equipment Directive)
Directive 2014/34/EU (ATEX — Equipment and protective systems intended for use in potentially explosive atmospheres)
Directive 1999/92/EC (ATEX workplace — minimum requirements for improving health/safety protection of workers at risk from explosive atmospheres; employer zoning duty, separate from product ATEX)
Directive 2006/42/EC (Machinery Directive)
Regulation (EU) 2023/1230 (new Machinery Regulation — replaces 2006/42/EC, applies from 20 January 2027)
Directive 2014/35/EU (LVD — Low Voltage Directive; applies to products/sub-assemblies independently within LVD scope)
Directive 2014/30/EU (EMCD — Electromagnetic Compatibility Directive)
Regulation (EU) 2019/1020 (Market Surveillance and Product Compliance — EU responsible economic operator, Art. 4)
Decision 768/2008/EC (modular conformity assessment framework)
EN ISO 22734:2019 (hydrogen generators using water electrolysis) — voluntary harmonised standard under Machinery Directive 2006/42/EC that may confer presumption of conformity for covered EHSRs; superseded at ISO level by ISO 22734-1:2025 (Part 1: Safety, July 2025) but EN ISO 22734-1:2025 not yet published in EU Official Journal as harmonised reference as of mid-2026; alternatives are allowed with evidence
EN 60079 series (ATEX — explosive atmospheres)
EN 13445 series (unfired pressure vessels) — voluntary harmonised standard under PED 2014/68/EU that may confer presumption of conformity; alternatives are allowed with evidence		 The EU CE bundle for an electrolyzer is structurally heavier than the Chinese TSG+CCC patchwork in four key ways. First, scope integration: the EU requires a single coordinated conformity assessment covering pressure, explosion (where applicable), machinery, electrical, and EMC simultaneously — with one DoC referencing all directives, one CE mark, and one technical file. China administers each domain separately (TSG, CCC, Ex, GB), with no single integrating document or mark. Second, Notified Body burden: PED categories above SEP/I and ATEX Category 1G/2G mandate EU Notified Body involvement for type-examination (Module B) and production surveillance (Modules D/F/H) — the specific PED category must be determined by product-specific Art. 4 / Annex II classification; a multi-year, multi-audit process not required under Chinese TSG inspection, which is government-body-led. Third, EU responsible person: Regulation 2019/1020 Art. 4 requires a legally accountable EU-established responsible economic operator (manufacturer, importer, authorised representative, or fulfilment service provider); China has no equivalent outbound requirement. Fourth, technical file and DoC retention: the manufacturer must compile a comprehensive EU technical file and retain it 10 years, in EU-language format, structured to each directive's annexes — none of this is generated by the Chinese certification processes. The net result is that a Chinese electrolyzer manufacturer exporting to the EU faces a compliance lead time of 18–36 months (indicative; actual duration depends on product category, NB queue, and existing test data) and significant engineering, testing, and administrative investment to satisfy the full CE bundle.[INFORMATIONAL] A water electrolyzer exported from China to the EU requires a coordinated CE conformity assessment bundle covering, as applicable: PED (with product-specific Art. 4 / Annex II category classification — do not assume Category II–IV without classification), ATEX 2014/34/EU (only where the equipment is intended for use in explosive atmospheres; workplace zoning is a separate employer duty under 1999/92/EC), Machinery Directive / Machinery Regulation, LVD, and EMC — plus a single EU Declaration of Conformity, a 10-year technical file, Notified Body involvement where required by the applicable directive/module, and an EU-established responsible economic operator under Regulation 2019/1020 Art. 4. EN/EN ISO/EN IEC harmonised standards can support presumption of conformity but are voluntary and not exclusive. The Chinese TSG+CCC+Ex patchwork does not map onto and cannot substitute for any part of this bundle. This multi-directive CE requirement is the headline market-access gap for Chinese electrolyzer manufacturers entering the EU. Consult a qualified EU conformity assessment body to determine the exact applicable directives, categories, and NB modules for a specific product. EUR-Lex / European Parliament and Council2026-06-12 · unverified
Pressure Equipment Directive — Pressure Vessels and Piping In China, electrolyzer pressure vessels fall under the Special Equipment Safety Law (2013) and the TSG (特种设备安全技术规范) pressure-vessel regime administered by SAMR (formerly AQSIQ). Design and manufacture require registration and approval by provincial or national TSG authorities. The principal manufacturing standard is GB 150 (Steel Pressure Vessels). A TSG design approval certificate (设计文件鉴定) and manufacturing licence (制造许可证) are mandatory before production. Periodic inspection by a government-designated inspection body is also required.Special Equipment Safety Law of the PRC (2013)
TSG 21 (Supervision Regulation on Stationary Pressure Vessels)
GB 150 (Steel Pressure Vessels)		 Electrolyzer pressure vessels and associated piping above the thresholds in PED 2014/68/EU (Article 4) must bear CE marking and comply with the Directive. Conformity assessment follows risk-based categories (I–IV): higher-risk equipment (Category III/IV) requires a Notified Body under modules such as B+D (Type Examination plus Quality Assurance of Production) or equivalent. Harmonised standards such as EN 13445 (unfired pressure vessels) and EN 13480 (metallic industrial piping) are voluntary routes that may confer a presumption of conformity with PED essential safety requirements; alternative technical solutions are allowed if conformity is demonstrated. The manufacturer must compile a Technical File and issue an EU Declaration of Conformity.Directive 2014/68/EU (PED)
EN 13445 (unfired pressure vessels)
EN 13480 (metallic industrial piping)		 Chinese TSG pressure-vessel certificates and GB 150 compliance are not recognised under PED 2014/68/EU. To export to the EU, manufacturers must obtain CE marking under PED and, where the PED category requires it, involve an EU-authorised Notified Body — there is no mutual recognition agreement covering pressure equipment between China and the EU. The new conformity assessment may use EN 13445 or other harmonised standards as voluntary presumption-of-conformity routes, or alternative solutions with equivalent evidence, creating additional compliance cost and lead time.[INFORMATIONAL] Chinese electrolyzer manufacturers holding TSG/GB 150 certifications must additionally demonstrate conformity with PED 2014/68/EU and affix CE marking before EU market entry; EU Notified Body involvement depends on the PED category. EN 13445 / EN 13480 can support a presumption of conformity but are not mandatory or exclusive. Existing Chinese pressure-vessel approvals do not substitute for PED conformity assessment. EUR-Lex / Official Journal of the European Union2026-06-12 · unverified
Machinery Directive — Mechanical Safety of Electrolyzer Systems China does not have a single machinery safety directive equivalent to 2006/42/EC. Electrolyzer mechanical safety is covered by a combination of: GB/T 37562 (safety requirements for pressure-type water electrolysis hydrogen production systems), the Special Equipment Safety Law for pressure-containing components, and sector-specific standards from the National Energy Administration (NEA). China Compulsory Certification (CCC) under the Certification and Accreditation Administration (CNCA) applies to certain categories of electrical machinery but does not directly map to the Machinery Directive's EHSR framework. Industrial water electrolyzers do not appear in the current CCC mandatory product catalogue (CNCA-22C-037); CCC scope does not extend to this product category based on CNCA announcements through 2025.GB/T 37562 (Safety requirements for pressure-type water electrolysis hydrogen production systems)
Special Equipment Safety Law of the PRC (2013)
CCC (China Compulsory Certification, CNCA) — industrial water electrolyzers not in current mandatory catalogue per CNCA announcements through 2025		 Electrolyzer systems constitute machinery under Directive 2006/42/EC (Machinery Directive) and must meet its Essential Health and Safety Requirements (EHSRs) before CE marking can be affixed. Key legal obligations include: risk assessment documented in the Technical File, safe design for pressure-related mechanical hazards (including hydrogen containment under pressure), and an EU Declaration of Conformity. Harmonised standards such as EN ISO 22734 for hydrogen generators are voluntary tools that may confer a presumption of conformity with relevant EHSRs; they are not mandatory or exclusive if an alternative technical solution demonstrates conformity. Note: from 20 January 2027 Directive 2006/42/EC will be replaced by Regulation (EU) 2023/1230 (Machinery Regulation), which introduces stricter digital documentation requirements including digital instructions and cybersecurity obligations.Directive 2006/42/EC (Machinery Directive)
Regulation (EU) 2023/1230 (Machinery Regulation, applies from 20 January 2027)
EN ISO 22734:2019 (Hydrogen generators using water electrolysis — harmonised reference; superseded at ISO level by ISO 22734-1:2025, July 2025; EN ISO 22734-1:2025 not yet published in EU Official Journal as of mid-2026)		 Chinese mechanical safety approvals (GB/T 37562, CCC where applicable) are not accepted as equivalents to Machinery Directive 2006/42/EC CE conformity. EU market entry requires a full EHSR-based risk assessment, technical file, and Declaration of Conformity under the Directive. Self-declaration is possible for most electrolyzer configurations (no Notified Body mandatory under the Machinery Directive itself, unless combined with PED obligations), but the documentation burden is substantial. EU harmonised standards may be used voluntarily for presumption of conformity; Chinese GB standards do not create that presumption under EU law.[INFORMATIONAL] Chinese electrolyzer manufacturers must conduct an independent EHSR risk assessment and produce EU-compliant technical documentation under Directive 2006/42/EC. EN ISO 22734 can support presumption of conformity but is not mandatory or exclusive. Chinese GB/T 37562 or CCC approvals do not satisfy Machinery Directive requirements for EU market access. EUR-Lex / Official Journal of the European Union2026-06-12 · unverified

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