CROSS-STANDARD public interest · Air-Source Heat Pump (ASHP)

China-to-Denmark 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 Danish and EU requirements: CE marking (LVD, EMC Directive, PED), Ecodesign Regulation (EU) 2016/2281, EU F-gas Regulation (EU) 2024/573 plus Danish refrigerant order, Danish Standards (DS), Miljøstyrelsen (MST) enforcement, Sikkerhedsstyrelsen (SIK) product safety, Energistyrelsen energy policy, and cold-climate installation requirements.

Dataset 2026-06-11 Last verified 2026-06-15 12 rows

Compliance Gap Matrix

Gap matrix
Compliance item Common China baseline Denmark (DS / Miljøstyrelsen / SIK) Gap / action Source + verification date
CE Marking — Multi-Directive Framework and EU Representative for Denmark CCC (China Compulsory Certification), administered by CNCA, covers safety and EMC for domestic appliances in China. CCC has no Ecodesign equivalent, no F-gas refrigerant restriction equivalent, and no pressure equipment category/Notified Body system equivalent to PED. The CCC mark is not recognised in Denmark or the EU and cannot substitute CE marking. Chinese manufacturers exporting to Denmark must appoint an EU-authorised representative.CCC (China Compulsory Certification — CNCA)
GB 4706.32-2012
GB 4343.1-2018
Denmark is an EU member state; CE marking is mandatory for air-source heat pumps placed on the Danish market. The applicable directives are: (1) Low Voltage Directive 2014/35/EU (electrical safety); (2) EMC Directive 2014/30/EU (electromagnetic compatibility); (3) Pressure Equipment Directive 2014/68/EU (refrigerant pressure circuits where thresholds are met); (4) Ecodesign Regulation (EU) 2016/2281 (energy efficiency — mandatory compliance, not CE marking per se); (5) F-gas Regulation (EU) 2024/573 (refrigerant restrictions — independent of CE marking). A single Declaration of Conformity must cover all applicable directives. An EU-based authorised representative is required for non-EU manufacturers. Sikkerhedsstyrelsen (SIK) is the Danish market surveillance authority for product and electrical safety.Directive 2014/35/EU (LVD)
Directive 2014/30/EU (EMC Directive)
Directive 2014/68/EU (PED)
Regulation (EU) 2016/2281 (Ecodesign — air heating products)
Regulation (EU) 2024/573 (F-gas Regulation)
CCC certification does not substitute CE marking for the Danish market. Separate EU conformity assessment under each applicable directive (LVD, EMC, PED, Ecodesign) is required. An EU-authorised representative must be appointed. The Declaration of Conformity, CE mark, technical file, and user documentation in Danish must all be in place before the first unit is placed on the Danish market. SIK (Sikkerhedsstyrelsen) performs market surveillance.[INFORMATIONAL] Major gap — CCC certification does not substitute CE marking for Denmark; separate EU conformity assessment under each applicable directive (LVD, EMC, PED, Ecodesign) required; EU-authorised representative and Danish-language documentation also mandatory. Sikkerhedsstyrelsen (SIK — Danish Safety Technology Authority)2026-06-15 · reference
Technical File Retention and EU-Authorised Representative Requirements Under China's CCC system, the applicant is typically the manufacturer or an authorised Chinese representative. There is no equivalent EU-representative requirement. Chinese CCC technical documentation requirements differ in scope and language from EU Technical File requirements. Chinese product documentation is typically prepared in Chinese only.CCC technical documentation requirements (CNCA)
GB standards documentation requirements
Under EU New Legislative Framework regulations, a non-EU manufacturer placing products on the Danish market must appoint an EU-based authorised representative. The manufacturer or their EU representative must retain the Technical File and Declaration of Conformity for at least 10 years after the last product was placed on the market. The Technical File must include design documentation, test reports, risk assessments, and evidence of conformity under each applicable directive. Danish-language instructions must accompany the product.Regulation (EU) 2019/1020 (market surveillance and product compliance)
Directive 2014/35/EU (LVD) — Article 6 (authorised representative)
Directive 2014/30/EU (EMC Directive) — Article 8 (authorised representative)
Chinese manufacturers must appoint an EU-authorised representative before products reach the Danish market. A complete EU Technical File — in English or Danish — must be compiled covering all applicable directives. User instructions and safety documentation must be provided in Danish. Chinese CCC documentation does not satisfy EU Technical File requirements.[INFORMATIONAL] Gap — EU-authorised representative appointment and full Technical File compilation (covering LVD, EMC, PED, Ecodesign) in English or Danish are mandatory before Danish market placement; Chinese CCC documentation does not satisfy these requirements. EUR-Lex / Official Journal of the European Union2026-06-15 · reference
Ecodesign Requirements — Space Heaters (Regulation (EU) 2016/2281 / EN 14511 / EN 14825) GB 21455-2019 is the mandatory energy efficiency standard for room air conditioners and multi-split systems, specifying COP at rated conditions. GB/T 25127-2010 series covers low-ambient-temperature heating performance relevant to cold-climate markets. Neither standard employs the SCOP methodology or EN 14825 seasonal bin calculation 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) applies to air heating products in Denmark and sets minimum seasonal space heating energy efficiency (ηs) thresholds. For heat pumps, efficiency is expressed via SCOP (seasonal coefficient of performance). Performance at rated conditions uses EN 14511; seasonal performance calculation uses EN 14825. Cold-climate performance is particularly relevant for Denmark — the EN 14825 cold-climate bin weighting covers outdoor temperatures common in Danish winters. Energistyrelsen (Danish Energy Agency) oversees energy policy and Ecodesign enforcement in Denmark.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 for the Danish market. Full re-testing to EN 14511 and seasonal performance calculation to EN 14825, including cold-climate bins, is required.[INFORMATIONAL] Major gap — no SCOP equivalent in Chinese standards; re-testing to EN 14511 and EN 14825 (including cold-climate bins) required for Danish/EU Ecodesign compliance. Energistyrelsen (Danish Energy Agency)2026-06-15 · reference
Energy Labelling and Product Fiche — Danish-language Documentation Required 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 (1–5 star scale), and rating methodology differ from the EU energy label. Chinese energy labels are not recognised in Denmark and cannot substitute the required EU label or product fiche. Chinese product documentation is typically provided in Chinese only and requires full translation into Danish.GB 12021 series (energy efficiency labelling)
MIIT/SAMR energy label scheme
Energy Labelling Regulation (EU) 2017/1369 and its delegated regulations require a mandatory EU energy label and product fiche for heat pumps placed on the Danish market. The energy efficiency class is determined by SCOP calculated to EN 14825. Danish law additionally requires that product instructions, installation manuals, and user documentation be provided in Danish (da-DK). Energistyrelsen registers product data in the EU EPREL database. The product fiche must be available in Danish.Regulation (EU) 2017/1369 (Energy Labelling Framework)
Regulation (EU) 2016/2281 (Ecodesign — air heating products)
EU EPREL database registration requirement
A new EU energy label and product fiche complying with Regulation (EU) 2017/1369 are required. Seasonal efficiency must be re-calculated using EN 14825. Product documentation — including installation and user manuals — must be translated into Danish. EPREL database registration is required before market placement.[INFORMATIONAL] Gap — new EU energy label and Danish-language product fiche required; EPREL registration mandatory; Chinese label and documentation not accepted; seasonal efficiency must be recalculated to EN 14825. Energistyrelsen (Danish Energy Agency)2026-06-15 · reference
EMC — Emissions (EN 55014-1, DS EN 55014) 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. While GB 4343.1 and EN 55014-1 share a CISPR 14-1 lineage, Chinese CCC test reports are not accepted as EU/Danish EMC Directive conformity evidence.GB 4343.1-2018
CISPR 14-1 (basis)
CCC (EMC emission testing)
EMC Directive 2014/30/EU applies in Denmark as an EU member state. The harmonised standard EN 55014-1:2021 (Electromagnetic compatibility — Requirements for household appliances, electric tools and similar apparatus — Part 1: Emission) is adopted by Danish Standards as DS EN 55014-1. It specifies conducted and radiated emission limits for heat pumps. Compressors, inverter drives, and motor controls are primary emission sources. CE marking under the EMC Directive is mandatory before placement on the Danish market.Directive 2014/30/EU (EMC Directive)
EN 55014-1:2021
DS EN 55014-1 (Danish Standards adoption)
GB 4343.1-2018 CCC test reports are not accepted as evidence of EU EMC Directive conformity for the Danish market. Re-testing to EN 55014-1:2021 at an EU-recognised laboratory is required, and a new EU Declaration of Conformity covering Denmark must be issued. Danish Standards DS EN 55014-1 is identical in technical content to EN 55014-1:2021.[INFORMATIONAL] Gap — re-testing to EN 55014-1:2021 required for Danish market; GB 4343.1 CCC test reports not accepted as EU EMC Directive conformity evidence. Danish Standards (DS)2026-06-15 · reference
EMC — Immunity and Power Quality (EN 55014-2 / EN 61000 Series) GB/T 17625.1 (harmonic current emissions — IEC 61000-3-2 adoption), GB/T 17625.2 (voltage fluctuations — IEC 61000-3-3 adoption), and GB/T 4343.2-2020 (immunity — CISPR 14-2 adoption) are the Chinese equivalents. These share IEC/CISPR lineage with the EU harmonised standards, but Chinese test reports are not accepted for EU/Danish 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 covers immunity as well as emissions for the Danish market. EN 55014-2:2021 specifies immunity requirements for household appliances. EN 61000-3-2 limits harmonic currents injected into the Danish 230/400V 50Hz grid. EN 61000-3-3 limits voltage fluctuations and flicker. Conformity assessment is via manufacturer self-declaration with a Technical File; no third-party body is mandatory for EMC, but test evidence must be retained for 10 years.Directive 2014/30/EU (EMC Directive)
EN 55014-2:2021
EN 61000-3-2
EN 61000-3-3
Separate EU/Danish 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 for the Danish market (230/400V 50Hz grid).[INFORMATIONAL] Gap — separate EU conformity assessment required for Danish market; existing Chinese test reports do not substitute for EU EMC Directive Technical File evidence. EUR-Lex / Official Journal of the European Union2026-06-15 · reference
Pressure Equipment Directive — Refrigerant Circuit Classification (PED / EN 378) 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 equivalent to PED CE marking or a Notified Body certificate.TSG 21-2016 (SAMR/SELO pressure vessel supervision)
GB 150.1-150.4-2011 (Pressure vessels)
Pressure Equipment Directive 2014/68/EU (PED) applies in Denmark as an EU member state. Refrigerant circuits are classified by 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. DS EN 378-1 to EN 378-4 are the Danish Standards adoptions of the EN 378 refrigerating system safety series, applied alongside PED.Directive 2014/68/EU (PED)
EN 378-1:2016+A1:2020 (system safety, used with PED)
DS EN 378 series (Danish Standards adoption)
PED classification and Notified Body requirements differ substantially from the Chinese SELO/TSG system. Chinese pressure vessel approvals (TSG/SELO certificates) are not recognised under PED in Denmark. For heat pump circuits classified as PED Category II or higher, a Notified Body listed on the EU NANDO database must be engaged. Re-design or re-certification to PED categories may be required.[INFORMATIONAL] Major gap — PED classification and Notified Body requirements differ substantially from Chinese SELO/TSG system; existing Chinese pressure vessel approvals not recognised under PED in Denmark. Danish Standards (DS)2026-06-15 · reference
Refrigerant Circuit Safety — EN 378 System Safety and Leak Detection GB 9237-2008 (Safety requirements for refrigerating systems, national adoption of ISO 5149:1993) and GB/T 18430 (household and similar air conditioner standards) are the Chinese equivalents. 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 and pressure-relief valve obligations as EN 378.GB 9237-2008 (ISO 5149:1993 adoption)
GB/T 18430 series
PED 2014/68/EU is the mandatory legal framework for refrigerant circuits meeting its pressure, volume, and fluid-group thresholds in Denmark. 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, adopted by Danish Standards as DS EN 378. These voluntary standards cover pressure relief, leak detection, and refrigerant charge limits; applying them can support a presumption of PED conformity.Directive 2014/68/EU (PED)
EN 378-1:2016+A1:2020
EN 378-2:2016+A1:2019
EN 378-3:2016
EN 378-4:2016
DS EN 378 series (Danish Standards adoption)
PED applicability must be classified first. The voluntary EN 378 / DS EN 378 route for pressure relief, leak detection, charge limits, and documentation differs from GB 9237 practice; full system re-assessment may be needed. An alternative technically justified solution satisfying the mandatory PED requirements is also permissible.[INFORMATIONAL] Gap — PED applicability must be classified first; EN 378 / DS EN 378 is a voluntary harmonised route to presumption of conformity, not a mandatory standard, and differs from GB 9237 in leak detection, charge limits, and documentation. EUR-Lex / Official Journal of the European Union2026-06-15 · reference
F-gas Regulation and Danish Refrigerant Order — Restrictions, Phase-down, and KMO Certification GB/T 7778 covers refrigerant classification and labelling requirements in China. China has no equivalent GWP-based phase-down quota system aligned with EU F-gas Regulation. 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. There is no Chinese equivalent to KMO technician certification.GB/T 7778 (refrigerant classification)
GB/T 25127-2010 series
EU F-gas Regulation (EU) 2024/573 (superseding 517/2014) applies in Denmark and imposes phase-down quotas on HFCs. Heat pumps using R410A (GWP ~2088) face market restrictions from 2025 onwards. Denmark has historically applied stricter national HFC limits beyond EU minimums via domestic refrigerant orders enforced by Miljøstyrelsen (MST, the Danish Environmental Protection Agency). Technicians handling F-gas refrigerants in Denmark must hold KMO (Kølemontøruddannelse) certification, which is the Danish equivalent of EU F-gas technician certification required under the F-gas Regulation. R32 (GWP 675) and R290 (propane, GWP 3) are preferred compliant refrigerant options for Danish market entry.Regulation (EU) 2024/573 (F-gas Regulation)
Danish refrigerant order (Miljøstyrelsen enforcement)
KMO technician certification (Danish F-gas technician qualification)
R410A-charged heat pumps face EU/Danish market restrictions from 2025. Chinese manufacturers must switch to R32, R290, or other low-GWP refrigerants for Danish export. No Chinese national quota system aligns with EU F-gas bulk HFC quota. Danish installers and service technicians must hold KMO certification — this is not a product certification burden on the manufacturer but must be confirmed in the distribution and service chain before market entry.[INFORMATIONAL] Major gap for R410A units — EU/Danish market placement restricted from 2025. Compliant if R32 or R290 (or other refrigerant below applicable GWP limit) is used and F-gas obligations including KMO technician certification in the service chain are met. Miljøstyrelsen (Danish Environmental Protection Agency)2026-06-15 · reference
Refrigerant Safety — Flammable Refrigerant Handling (EN 378 / PED) GB 9237-2008 (Safety requirements for refrigerating systems, national adoption of ISO 5149:1993) is the Chinese equivalent. Charge limits for flammable refrigerants, indoor ventilation thresholds, and system documentation requirements differ from EN 378 / DS EN 378. The Chinese standard does not reflect Denmark-specific cold-climate installation conditions or Danish building code BR18 requirements.GB 9237-2008
ISO 5149:1993 (basis)
EU legal obligations for flammable refrigerant heat-pump circuits in Denmark arise from PED 2014/68/EU 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 support a presumption of PED conformity. For R290 (propane, A3 safety class), charge limits and ventilation requirements in DS EN 378 are particularly relevant to Danish residential installations. Miljøstyrelsen and Sikkerhedsstyrelsen (SIK) both have enforcement roles.Directive 2014/68/EU (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
DS EN 378 series (Danish Standards adoption)
PED classification must be checked first. DS EN 378 charge limit, ventilation, and leak detection methods differ from GB 9237; re-assessment is likely required. Cold-climate field performance at Danish outdoor temperatures (down to -20°C) must also be validated, as Chinese test conditions may not cover full Danish temperature ranges.[INFORMATIONAL] Gap — assess mandatory PED applicability first; EN 378 / DS EN 378 is a voluntary harmonised route, not mandatory, and differs from GB 9237; cold-climate performance validation at Danish outdoor temperatures is additionally required. Sikkerhedsstyrelsen (SIK — Danish Safety Technology Authority)2026-06-15 · reference
Product Safety — Electrical Safety (LVD / EN 60335-2-40 / SIK Enforcement) 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 evidence for the Danish market.GB 4706.32-2012
CCC (China Compulsory Certification)
Low Voltage Directive 2014/35/EU 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. Denmark operates a 230/400V 50Hz grid. Sikkerhedsstyrelsen (SIK) is the Danish market surveillance authority responsible for LVD and product safety enforcement. Note: IEC 60335-2-40:2022 (Edition 4) is the current IEC edition; CENELEC adoption status should be verified at time of compliance assessment.Directive 2014/35/EU (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 LVD conformity evidence for Denmark. Re-testing to the applicable EN 60335-2-40 edition at an EU-accredited or SIK-recognised laboratory is required. The 230/400V 50Hz Danish grid specification must be confirmed during testing.[INFORMATIONAL] Gap — re-testing to EN 60335-2-40 under EU LVD required for Danish market; GB 4706.32 CCC certification not accepted as equivalent; 230/400V 50Hz grid specification must be confirmed. Sikkerhedsstyrelsen (SIK — Danish Safety Technology Authority)2026-06-15 · reference
Installation Safety — Danish Building Code BR18 and Cold-Climate Requirements GB 50019-2015 (Design code for heating, ventilation and air conditioning of industrial buildings) and GB/T 18430 series cover Chinese HVAC design and heat pump installation standards. GB/T 25127 series addresses low-ambient heating performance. Chinese installation codes do not address BR18 energy performance targets, Danish climate conditions, or Danish installer qualification requirements. Cold-climate design temperatures in Chinese standards may not cover Danish conditions.GB 50019-2015 (HVAC design code)
GB/T 18430 series
GB/T 25127-2010 series
Heat pump installation in Denmark must comply with the Danish Building Regulation 2018 (BR18), which covers thermal performance, ventilation, fire safety, and HVAC system requirements for buildings. EN 378-3:2016 (Installation site and personal protection) provides guidance for refrigerating system installation, adopted by Danish Standards as DS EN 378-3. Danish building codes require that heat pump installations meet BR18 energy performance targets and that installers are qualified under Danish rules. Cold-climate performance at outdoor temperatures as low as -20°C (design temperature in some Danish regions) must be documented. Energistyrelsen sets the energy policy context; SIK oversees product safety in installed systems.Danish Building Regulation 2018 (BR18)
EN 378-3:2016 (Installation site and personal protection)
DS EN 378-3 (Danish Standards adoption)
Chinese heat pump installation codes and design standards do not satisfy Danish BR18 requirements. Cold-climate performance data at Danish design temperatures (down to -20°C) must be documented separately and may require additional testing beyond Chinese standard conditions. Danish installer qualification requirements must be met independently of Chinese credentials. EN 378-3 / DS EN 378-3 installation guidance applies in addition to BR18.[INFORMATIONAL] Gap — Chinese installation codes and standards do not satisfy Danish BR18; cold-climate performance data at Danish design temperatures (to -20°C) must be separately documented; Danish installer qualifications and EN 378-3 / DS EN 378-3 installation guidance apply independently. Trafik-, Bygge- og Boligstyrelsen (Danish Transport, Construction and Housing Authority)2026-06-15 · reference

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