CROSS-STANDARD public interest · Air-source heat pump
China-to-Czechia Air-source Heat Pump 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 China air-source heat pump documentation against Czechia CE marking, Ecodesign Regulation (EU) 2016/2281, F-gas Regulation (EU) 2024/573 and Czech Act No. 73/2012 Sb., Pressure Equipment Directive 2014/68/EU (NV 2016/208 Sb.), and related Czech safety, EMC, and consumer protection requirements.
GAP MATRIX
Compliance Gap Matrix
| Compliance item | Common China baseline | Czechia (ÚNMZ / MŽP / ERÚ) | Gap / action | Source + verification date |
|---|---|---|---|---|
| CE Marking — Declaration of Conformity and Technical Documentation | China Compulsory Certification (CCC) is the Chinese mandatory product certification scheme for domestic market access. CCC covers electrical safety and EMC requirements for applicable categories. The CCC mark and supporting Chinese test reports are not recognised as CE marking equivalents and do not satisfy EU Declaration of Conformity requirements. Chinese-language documentation does not fulfil Czech-language documentation obligations.CCC (China Compulsory Certification) GB 4706.32-2012 GB 4343.1-2018 |
CE marking is mandatory for heat pumps placed on the Czech market. As an EU member state, Czechia requires CE marking under all applicable EU directives and regulations, including the Low Voltage Directive 2014/35/EU, EMC Directive 2014/30/EU, Ecodesign Regulation (EU) 2016/2281, and Pressure Equipment Directive 2014/68/EU (NV 2016/208 Sb.). The manufacturer or EU-based authorised representative must issue an EU Declaration of Conformity (DoC) and maintain a Technical File for at least 10 years. Czech-language instructions and safety documentation are required under Czech Act No. 634/1992 Sb. (Consumer Protection) and Act No. 22/1997 Sb. (Technical Requirements on Products). ÚNMZ oversees standards adoption; SZÚ is involved in product safety oversight.Directive 2014/35/EU (LVD) Directive 2014/30/EU (EMC Directive) Directive 2014/68/EU (PED) Regulation (EU) 2016/2281 (Ecodesign) NV 2016/208 Sb. (Czech PED implementation) Czech Act No. 634/1992 Sb. (Consumer Protection) Czech Act No. 22/1997 Sb. (Technical Requirements on Products) |
CCC certification and Chinese test reports are not accepted as CE marking equivalents in Czechia. A full EU conformity assessment process is required covering all applicable directives. An EU Declaration of Conformity must be issued by the manufacturer or EU-based authorised representative. Czech-language user instructions, safety warnings, and installation documentation are mandatory under Czech consumer protection and product safety law.[INFORMATIONAL] Major gap — CCC certification not accepted as CE marking equivalent; full EU conformity assessment and EU Declaration of Conformity required; Czech-language user and installation documentation mandatory under Czech law. | ÚNMZ — Czech Office for Standards, Metrology and Testing2026-06-15 · reference |
| CE Marking — EU Authorised Representative and Market Surveillance | Chinese CCC certification is managed domestically by CCCF-certified bodies and does not require an EU-based responsible party. Chinese manufacturers selling only in China do not need an EU Authorised Representative. There is no Chinese equivalent to the EU Authorised Representative obligation for cross-border market access.CCC (China Compulsory Certification) SAMR market supervision (domestic only) |
Non-EU manufacturers placing heat pumps on the Czech market must appoint an EU-based Authorised Representative (AR) to act on their behalf under EU product regulation. The AR takes legal responsibility for EU Declaration of Conformity, Technical File maintenance, and market surveillance liaison. Czech Trade Inspection Authority (ČOI) is the primary market surveillance authority for CE-marked products in Czechia and can require access to Technical Files and test reports. The EU General Product Safety Regulation (GPSR) (EU) 2023/988 from December 2024 also mandates a responsible person established in the EU.Regulation (EU) 2019/1020 (EU Market Surveillance Regulation) Regulation (EU) 2023/988 (GPSR — General Product Safety Regulation) Czech Act No. 22/1997 Sb. (Technical Requirements on Products) |
Chinese manufacturers exporting heat pumps to Czechia must appoint an EU Authorised Representative before product placement. Under GPSR (EU) 2023/988, a responsible person established in the EU is additionally required from December 2024. ČOI market surveillance may request Technical Files in Czech or English; Chinese-language-only documentation is non-compliant.[INFORMATIONAL] Gap — EU Authorised Representative required before Czech market placement; GPSR (EU) 2023/988 requires EU-established responsible person from December 2024; Technical Files must be accessible to ČOI in Czech or English. | ÚNMZ — Czech Office for Standards, Metrology and Testing2026-06-15 · reference |
| Ecodesign Requirements — Space Heaters and Combination Heaters (Regulation (EU) 2016/2281) | GB 21455-2019 is the mandatory energy efficiency standard for room air conditioners and multi-split systems, specifying COP at rated conditions. For dedicated space-heating heat pumps, GB/T 25127-2010 series covers low-ambient heating performance. Neither standard employs the SCOP methodology used in EU Ecodesign, and seasonal efficiency calculation methods are not equivalent.GB 21455-2019 GB/T 25127-2010 series |
Ecodesign Regulation (EU) 2016/2281 (implementing Ecodesign Directive 2009/125/EC) sets minimum seasonal space heating energy efficiency (ηs) thresholds for heat pump space heaters and combination heaters sold in Czechia and all EU member states. For heat pumps, efficiency is expressed via SCOP (seasonal coefficient of performance). Testing at rated conditions uses EN 14511; seasonal performance calculation uses EN 14825. Compliance is required for all products placed on the Czech market; the Czech Trade Inspection Authority (ČOI) enforces Ecodesign requirements.Regulation (EU) 2016/2281 (Ecodesign — air heating products) Directive 2009/125/EC (Ecodesign Directive) EN 14511 (rated condition testing) EN 14825 (seasonal performance calculation) |
No SCOP methodology equivalent in Chinese standards. Chinese efficiency test data (COP at rated condition) cannot be directly used to demonstrate compliance with EU Ecodesign ηs thresholds under Regulation (EU) 2016/2281. Full re-testing to EN 14511 and seasonal performance calculation to EN 14825 is required. The Czech heat pump market is fast-growing and ČOI enforcement of Ecodesign is active.[INFORMATIONAL] Major gap — no SCOP equivalent in Chinese standards; re-testing to EN 14511 and EN 14825 required for Ecodesign (EU) 2016/2281 compliance in Czechia. | EUR-Lex / Official Journal of the European Union2026-06-15 · reference |
| Energy Labelling and Nová zelená úsporám Subsidy Eligibility | China's energy efficiency labelling is governed by the GB 12021 series and the MIIT/SAMR energy label scheme. The Chinese label format, efficiency tier definitions, and rating methodology differ from the EU energy label. Chinese energy labels are not recognised in the Czech or EU market and cannot substitute the required EU label or satisfy Nová zelená úsporám subsidy criteria.GB 12021 series (energy efficiency labelling) MIIT/SAMR energy label scheme |
EU energy labelling regulations require an A+++ to G efficiency scale for space heaters sold in Czechia. Heat pumps must display seasonal efficiency class on a mandatory EU energy label. Additionally, Czechia's Nová zelená úsporám (New Green Savings) programme, administered by the State Environmental Fund (SFŽP), grants subsidies for heat pump installations meeting minimum SCOP and technical requirements. Eligibility requires CE-marked products with documented EU-standard efficiency data.Regulation (EU) 811/2013 (energy labelling — space heaters) Regulation (EU) 2017/1369 (Energy Labelling Framework) Nová zelená úsporám programme (novazelenadusporam.cz) |
A new EU energy label complying with Regulation (EU) 811/2013 is required. Seasonal efficiency must be re-calculated using EN 14825 methodology. Chinese energy label data cannot be directly transposed. To access Nová zelená úsporám subsidies (a major market driver in Czechia), the product must meet Czech programme-specific SCOP thresholds and carry full EU-compliant documentation.[INFORMATIONAL] Gap — new EU energy label required; Chinese label not accepted; seasonal efficiency must be recalculated to EN 14825; Nová zelená úsporám subsidy eligibility requires CE-marked product with EU-standard efficiency documentation. | ERÚ — Energy Regulatory Office of the Czech Republic2026-06-15 · reference |
| EMC — Emissions (EN 55014-1) | GB 4343.1-2018 (Electromagnetic disturbance characteristics of household electrical appliances, electric tools and similar apparatus — Part 1: Emission) is China's national adoption of CISPR 14-1. EMC emission testing is included under CCC certification for domestic appliances, conducted at CNAS/CMA accredited laboratories.GB 4343.1-2018 CISPR 14-1 (basis) CCC (EMC emission testing) |
EMC Directive 2014/30/EU, implemented in Czechia as NV 2016/117 Sb., requires heat pumps to comply with electromagnetic emission limits. Harmonised standard EN 55014-1:2021 (Electromagnetic compatibility — Requirements for household appliances, electric tools and similar apparatus — Part 1: Emission) specifies conducted and radiated emission limits. ÚNMZ oversees adoption of harmonised EN standards in Czechia. Heat pump compressors, motors, and inverter drives are significant emission sources covered by this standard.Directive 2014/30/EU (EMC Directive) NV 2016/117 Sb. (Czech national implementation) EN 55014-1:2021 |
Although GB 4343.1-2018 and EN 55014-1:2021 share a common CISPR 14-1 lineage, Chinese CCC test reports under GB 4343.1 are not accepted as evidence of EU/Czech EMC Directive conformity. Re-testing to EN 55014-1:2021 at an EU-recognised laboratory is required, along with a new EU Declaration of Conformity. Czech-language documentation required under Act No. 634/1992 Sb. (Consumer Protection) must also be prepared.[INFORMATIONAL] Gap — re-testing to EN 55014-1:2021 required; GB 4343.1 CCC test reports not accepted as Czech/EU EMC Directive conformity evidence; Czech-language documentation required. | ÚNMZ — Czech Office for Standards, Metrology and Testing2026-06-15 · reference |
| EMC — Immunity and Power Quality (EN 55014-2 / EN 61000 Series) | GB/T 17625.1 (harmonic current emissions — national adoption of IEC 61000-3-2), GB/T 17625.2 (voltage fluctuations — national adoption of IEC 61000-3-3), and GB/T 4343.2-2020 (immunity — adoption of CISPR 14-2) are the Chinese equivalents. These share IEC/CISPR lineage with the EU harmonised standards but Chinese test reports are not accepted for Czech/EU market conformity.GB/T 17625.1 (IEC 61000-3-2 adoption) GB/T 17625.2 (IEC 61000-3-3 adoption) GB/T 4343.2-2020 (CISPR 14-2 adoption) |
EMC Directive 2014/30/EU (implemented in Czechia as NV 2016/117 Sb.) covers immunity as well as emissions. EN 55014-2:2021 specifies immunity requirements for household appliances. EN 61000-3-2 limits harmonic currents injected into the public supply network. EN 61000-3-3 limits voltage fluctuations and flicker. The Czech grid operates at 230/400 V 50 Hz. Conformity assessment is via manufacturer self-declaration with a Technical File (Annex II of the EMC Directive); no third-party body is mandatory, but test evidence must be retained.Directive 2014/30/EU (EMC Directive) NV 2016/117 Sb. (Czech national implementation) EN 55014-2:2021 EN 61000-3-2 EN 61000-3-3 |
Separate EU/Czech conformity assessment is required. Existing Chinese immunity and power-quality test reports do not substitute for EU Technical File evidence. A new EU Declaration of Conformity must be issued covering all applicable EMC Directive requirements. Czech-language user documentation is required under Czech Act No. 634/1992 Sb. (Consumer Protection).[INFORMATIONAL] Gap — separate EU/Czech conformity assessment required; existing Chinese test reports do not substitute for EU EMC Directive Technical File evidence; Czech-language documentation required. | ÚNMZ — Czech Office for Standards, Metrology and Testing2026-06-15 · reference |
| Pressure Equipment Directive — Refrigerant Circuit Classification (NV 2016/208 Sb.) | TSG 21-2016 (Special Equipment Safety Technical Supervision Regulations for Boilers and Pressure Vessels, administered by SAMR) and GB 150.1-150.4-2011 (Pressure vessels) govern pressure vessels in China. SELO (Special Equipment Licensing Office) registration is required for certain pressure vessels. The Chinese risk classification methodology differs from PED: different boundary conditions, different inspection body roles, and SELO registration is not a CE marking equivalent.TSG 21-2016 (SAMR/SELO pressure vessel supervision) GB 150.1-150.4-2011 (Pressure vessels) |
Pressure Equipment Directive 2014/68/EU (PED), implemented in Czechia as Government Decree NV 2016/208 Sb., applies to heat pump refrigerant circuits as pressure equipment. Classification depends on fluid group (Group 1 = flammable or toxic refrigerants such as R290; Group 2 = non-flammable, non-toxic refrigerants such as R32 and R410A), maximum allowable pressure, and volume. Category I (lowest risk) allows manufacturer self-declaration; Categories II, III, and IV require involvement of a Notified Body. EN 378 also applies for system-level refrigerating system safety.Directive 2014/68/EU (PED) NV 2016/208 Sb. (Czech national implementation of PED) EN 378-1:2016+A1:2020 (system safety, used with PED) |
PED classification (as implemented in Czechia via NV 2016/208 Sb.) and Notified Body requirements differ substantially from the Chinese SELO/TSG system. Chinese pressure vessel approvals (TSG/SELO certificates) are not recognised under PED/NV 2016/208 Sb. For heat pump circuits classified as PED Category II or higher, a Notified Body must be engaged. Refrigerant circuit re-design or re-certification to PED categories may be required.[INFORMATIONAL] Major gap — PED classification (NV 2016/208 Sb. in Czechia) and Notified Body requirements differ substantially from Chinese SELO/TSG system; existing Chinese pressure vessel approvals not recognised under PED. | EUR-Lex / Official Journal of the European Union2026-06-15 · reference |
| Refrigerant Circuit Safety — EN 378 System Safety Requirements | GB 9237-2008 (Safety requirements for refrigerating systems) is China's national adoption of ISO 5149:1993. The current revision status of GB/T 9237 should be verified at time of compliance assessment. Charge limits for flammable refrigerants in indoor environments, room ventilation thresholds, and system documentation requirements differ from EN 378. GB 9237 does not cover the same scope of leak detection obligations as EN 378.GB 9237-2008 (ISO 5149:1993 adoption) ISO 5149 (basis) |
Pressure Equipment Directive 2014/68/EU (Czech NV 2016/208 Sb.) is the mandatory legal framework for refrigerant circuits that meet its pressure, volume, and fluid-group thresholds. EN 378-1:2016+A1:2020, EN 378-2:2016+A1:2019, EN 378-3:2016, and EN 378-4:2016 are voluntary harmonised standards for refrigerating systems and heat pumps; applying them can support a presumption of conformity with relevant EU essential requirements, but the standards themselves are not mandatory. Czech installations must also comply with applicable Czech installation codes.Directive 2014/68/EU (PED) NV 2016/208 Sb. (Czech national implementation of PED) EN 378-1:2016+A1:2020 EN 378-2:2016+A1:2019 EN 378-3:2016 EN 378-4:2016 |
EU/Czech legal compliance must be assessed against PED (NV 2016/208 Sb.) where the refrigerant circuit falls within PED scope. EN 378 documentation, leak detection, and flammable refrigerant charge-limit methods differ from GB 9237; using the voluntary EN 378 route may require a full system re-assessment. An alternative technical solution may also be justified if it satisfies mandatory EU/Czech requirements.[INFORMATIONAL] Gap — PED (NV 2016/208 Sb.) applicability must be classified first; EN 378 is a voluntary harmonised route to presumption of conformity, not a mandatory standard, and differs from GB 9237 in documentation, leak detection, and charge-limit methods. | EUR-Lex / Official Journal of the European Union2026-06-15 · reference |
| F-gas Regulation — Refrigerant Restrictions, Phase-down, and Czech Act No. 73/2012 Sb. | GB/T 7725 covers refrigerant labelling requirements. China has no equivalent GWP-based phase-down quota system. R410A remains widely used in Chinese air-source heat pumps. GB/T 25127 series addresses low-ambient-temperature heating performance but does not restrict refrigerant GWP.GB/T 7725 GB/T 25127-2010 series |
F-gas Regulation (EU) 2024/573 (superseding 517/2014) prohibits or restricts placing equipment containing certain HFCs on the market across all EU member states including Czechia. Heat pumps using R410A (GWP ~2088) face restrictions from 2025 onwards; R32 (GWP 675) and R290 (propane, GWP 3) are preferred compliant refrigerant options. Czech Act No. 73/2012 Sb. (on fluorinated greenhouse gases and ozone-depleting substances) supplements EU law with national certification, licensing, and reporting requirements administered by the Ministry of Environment (MŽP). Technicians handling F-gas refrigerants in Czechia must hold valid Czech F-gas certificates.Regulation (EU) 2024/573 (F-gas Regulation) Regulation (EU) 517/2014 (superseded) Czech Act No. 73/2012 Sb. (F-gas and ODS national law) |
R410A-charged heat pumps face EU/Czech market restrictions from 2025. Chinese manufacturers must switch to R32, R290, or other low-GWP refrigerants for Czech/EU export. Czech Act No. 73/2012 Sb. adds national certification and technician licensing requirements beyond the EU Regulation. Czech MŽP administers F-gas enforcement; importing parties must ensure local technician F-gas certification before installation.[INFORMATIONAL] Major gap for R410A units — EU/Czech market placement restricted from 2025. Czech Act No. 73/2012 Sb. adds national technician certification requirements administered by MŽP. Compliant if R32 or R290 is used and all F-gas obligations are met. | MŽP — Ministry of the Environment of the Czech Republic2026-06-15 · reference |
| Refrigerant Safety — Flammable Refrigerant Handling (EN 378 Series) | GB 9237-2008 (Safety requirements for refrigerating systems) is China's national adoption of ISO 5149:1993. The current status of GB/T 9237 revisions should be verified. Charge limits for flammable refrigerants, indoor ventilation thresholds, and system documentation requirements differ from EN 378.GB 9237-2008 ISO 5149:1993 (basis) |
EU legal obligations for flammable refrigerant heat-pump circuits in Czechia come from applicable legislation, including Pressure Equipment Directive 2014/68/EU (Czech NV 2016/208 Sb.) where pressure, volume, and fluid-group thresholds are met. EN 378-1:2016+A1:2020 to EN 378-4 and EN 14276-1:2021/EN 14276-2:2021 are voluntary harmonised standards that may be used to support a presumption of conformity for relevant safety and pressure-equipment requirements; they are not themselves mandatory legal requirements.Directive 2014/68/EU (PED) NV 2016/208 Sb. (Czech national implementation of PED) EN 378-1:2016+A1:2020 EN 378-2:2016+A1:2019 EN 378-3:2016 EN 378-4:2016 EN 14276-1:2021 EN 14276-2:2021 |
Czech/PED (NV 2016/208 Sb.) classification must be checked for the refrigerant circuit where pressure-equipment thresholds apply. EN 378 and EN 14276 methods for charge limits, ventilation, leak detection, documentation, vessels, and piping differ from GB 9237/GB 150/TSG practice; using those voluntary harmonised standards may require re-assessment. Czech F-gas technician certification (Act No. 73/2012 Sb.) is additionally required for installation and servicing.[INFORMATIONAL] Gap — assess mandatory PED (NV 2016/208 Sb.) applicability first; EN 378 and EN 14276 are voluntary harmonised standards for presumption of conformity; Czech Act No. 73/2012 Sb. requires national F-gas technician certification for installation/servicing. | MŽP — Ministry of the Environment of the Czech Republic2026-06-15 · reference |
| Product Safety — Household Heat Pumps (LVD / EN 60335-2-40) | GB 4706.32-2012 (Safety of household and similar electrical appliances — Particular requirements for heat pumps, air conditioners and dehumidifiers) is China's national adoption of IEC 60335-2-40:2005. CCC (China Compulsory Certification) includes testing to GB 4706.32. The Chinese standard is based on an earlier IEC edition and Chinese test reports under GB 4706.32 are not accepted as equivalent to EU LVD conformity.GB 4706.32-2012 CCC (China Compulsory Certification) |
Low Voltage Directive 2014/35/EU, implemented in Czechia as NV 2016/106 Sb., requires electrical safety compliance for heat pumps operating within 50–1000 V AC or 75–1500 V DC. The harmonised standard EN 60335-2-40 (Safety of household and similar electrical appliances — Particular requirements for electrical heat pumps, air-conditioners and dehumidifiers) covers insulation, overcurrent protection, earthing, and refrigerant-related electrical hazards. Czech grid supply is 230/400 V 50 Hz. Note: IEC 60335-2-40:2022 (Edition 4) is the current IEC edition; CENELEC adoption status should be verified at time of compliance assessment. SZÚ (National Institute of Public Health) is involved in electrical safety oversight in Czechia.Directive 2014/35/EU (LVD) NV 2016/106 Sb. (Czech national implementation of LVD) EN 60335-2-40 (harmonised standard — CENELEC adoption status to be verified) IEC 60335-2-40:2022 (Edition 4, current IEC) |
GB 4706.32-2012 is based on IEC 60335-2-40:2005 (older edition); the EU harmonised standard references a later edition. CCC certification under GB 4706.32 is not accepted as EU/Czech LVD (NV 2016/106 Sb.) conformity evidence. Re-testing to the applicable EN 60335-2-40 edition at an EU-accredited or recognised laboratory is required. Czech grid voltage (230/400 V 50 Hz) must be verified in product specifications.[INFORMATIONAL] Gap — re-testing to EN 60335-2-40 under EU LVD (Czech NV 2016/106 Sb.) required; GB 4706.32 certification not accepted as equivalent; product must be verified for 230/400 V 50 Hz Czech grid. | EUR-Lex / Official Journal of the European Union2026-06-15 · reference |
| Commercial/Industrial Heat Pump Safety — EN 14276 Pressure Accessories | GB 150 series (Pressure vessels — design and manufacture) and TSG 21-2016 (Special Equipment Safety Technical Supervision Regulations for Boilers and Pressure Vessels, administered by SAMR/SELO) govern pressure vessels in China. The classification methodology, inspection regime, and registration requirements differ substantially from the EU PED and EN 14276 system.GB 150.1-150.4-2011 (Pressure vessels) TSG 21-2016 (SAMR/SELO pressure vessel supervision) |
For commercial and industrial heat pumps in Czechia, Pressure Equipment Directive 2014/68/EU (Czech NV 2016/208 Sb.) is the mandatory legal framework for vessels and piping that meet its pressure, volume, and fluid-group thresholds. EN 14276-1:2021 (vessels) and EN 14276-2:2021 (piping) are voluntary harmonised standards for refrigerating systems and heat pumps; applying them can support a presumption of conformity with relevant PED essential safety requirements, but the standards themselves are not mandatory. Czech installations must comply with applicable local installation codes.Directive 2014/68/EU (PED) NV 2016/208 Sb. (Czech national implementation of PED) EN 14276-1:2021 EN 14276-2:2021 |
Czech/EU legal compliance must be assessed against PED (NV 2016/208 Sb.) for pressure equipment within scope. EN 14276 vessel and piping methods differ from Chinese GB 150/TSG 21 classification, inspection, and registration practice; using the voluntary EN 14276 route may require re-design, re-inspection, and Notified Body involvement. The mandatory obligation remains PED conformity; Chinese SELO/TSG certificates are not recognised under PED/NV 2016/208 Sb.[INFORMATIONAL] Major gap — PED (NV 2016/208 Sb.) classification and conformity assessment drive the mandatory obligation in Czechia; EN 14276 is a voluntary harmonised route to presumption of conformity, while Chinese SELO/TSG certificates are not recognised under PED. | EUR-Lex / Official Journal of the European Union2026-06-15 · reference |
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SOURCES
Official-source register.
- ÚNMZ — Czech Office for Standards, Metrology and Testing · accessed 2026-06-15 · reference · used in 4 rows
- EUR-Lex / Official Journal of the European Union · accessed 2026-06-15 · reference · used in 1 rows
- ERÚ — Energy Regulatory Office of the Czech Republic · accessed 2026-06-15 · reference · used in 1 rows
- EUR-Lex / Official Journal of the European Union · accessed 2026-06-15 · reference · used in 3 rows
- MŽP — Ministry of the Environment of the Czech Republic · accessed 2026-06-15 · reference · used in 2 rows
- EUR-Lex / Official Journal of the European Union · accessed 2026-06-15 · reference · used in 1 rows