CROSS-STANDARD public interest · Air-source heat pump
China-to-EU 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 EU CE marking, Ecodesign Regulation (EU) 813/2013, F-gas Regulation (EU) 2024/573, Pressure Equipment Directive 2014/68/EU, and related EU safety and EMC requirements.
Dataset 2026-06-11
Last verified 2026-06-12
12 rows
GAP MATRIX
Compliance Gap Matrix
| Compliance item | Common China baseline | European Union (CE / Ecodesign) | Gap / action | Source + verification date |
|---|---|---|---|---|
| CE Marking — Multi-Directive Framework for Air-source Heat Pumps | CCC (China Compulsory Certification), administered by CNCA, covers safety and EMC for domestic appliances in China. CCC does not have an Ecodesign equivalent, an F-gas refrigerant restriction equivalent, or a pressure equipment category/Notified Body system equivalent to PED. The CCC mark is not recognised in the EU and cannot substitute CE marking.CCC (China Compulsory Certification — CNCA) GB 4706.32-2012 GB 4343.1-2018 |
Air-source heat pumps placed on the EU market require CE marking under multiple directives simultaneously: (1) Low Voltage Directive 2014/35/EU for electrical safety; (2) EMC Directive 2014/30/EU for electromagnetic compatibility; (3) Ecodesign Regulation (EU) 813/2013 (not CE marking per se, but mandatory compliance blocking market placement for non-compliant products); (4) Pressure Equipment Directive 2014/68/EU for refrigerant pressure circuits where pressure/volume thresholds are met (Category II+ requires Notified Body); (5) F-gas Regulation (EU) 2024/573 (refrigerant restrictions apply independently of CE marking). A single Declaration of Conformity must cover all applicable directives. CE marking must appear on the product, packaging, and accompanying documentation.Directive 2014/35/EU (LVD) Directive 2014/30/EU (EMC Directive) Regulation (EU) 813/2013 (Ecodesign — space heaters) Directive 2014/68/EU (PED) Regulation (EU) 2024/573 (F-gas Regulation) |
CCC certification does not substitute CE marking. Separate EU conformity assessment under each applicable directive is required. The multi-directive nature of heat pump CE marking (LVD + EMC + Ecodesign + PED) means that a Chinese manufacturer must address each directive independently, compile a Technical File, and issue an EU Declaration of Conformity before the first unit is shipped to the EU.Major gap — CCC certification does not substitute CE marking; separate EU conformity assessment under each applicable directive (LVD, EMC, Ecodesign, PED) required; F-gas compliance also mandatory and separate. | European Commission — Single Market2026-06-12 · unverified |
| Notified Body Requirements — PED Category II and Above | For pressure vessels requiring registration in China, a designated special equipment inspection body (特种设备检验机构) issues an inspection certificate under the SAMR/SELO framework. The Chinese inspection certificate and SELO registration are not recognised as equivalent to EU Notified Body certification or EC Type Examination under PED.TSG 21-2016 (SAMR/SELO) Special Equipment Safety Law of the PRC (2013) |
For heat pump refrigerant circuits classified as PED Category II or higher (typically commercial or larger residential systems, particularly those using Group 1 refrigerants such as R290, or systems meeting relevant pressure and volume thresholds), a Notified Body (NB) must be involved in the conformity assessment. The NB issues an EC Type Examination Certificate or approves the manufacturer's Quality Assurance system. The list of EU Notified Bodies is maintained on the NANDO database (ec.europa.eu/growth/tools-databases/nando/).Directive 2014/68/EU (PED), Articles 14–17 (conformity assessment procedures) NANDO database (Notified Body register) |
Chinese SELO inspection certificates and special equipment inspection body certificates are not recognised as equivalent to EU Notified Body involvement under PED. For PED Category II+ heat pump systems, a EU Notified Body must be engaged, an EC Type Examination Certificate or equivalent must be obtained, and the Notified Body's identification number must appear on the CE marking declaration.Major gap — Chinese SELO inspection certificates not recognised; EU Notified Body involvement mandatory for PED Category II+ systems; NANDO-listed NB must be engaged before CE marking can be issued. | European Commission — NANDO (New Approach Notified and Designated Organisations)2026-06-12 · unverified |
| Ecodesign Requirements — Space Heaters and Combination Heaters | 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) 813/2013 (implementing Ecodesign Directive 2009/125/EC) sets minimum seasonal space heating energy efficiency (ηs) thresholds for space heaters (≥10 kW up to 400 kW) and combination heaters. 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. Current minimum ηs is approximately 100% for average climate conditions (A+ equivalent on the energy label for newer products).Regulation (EU) 813/2013 (Ecodesign — space heaters) 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. Full re-testing to EN 14511 and seasonal performance calculation to EN 14825 is required.Major gap — no SCOP equivalent in Chinese standards; re-testing to EN 14511 and EN 14825 required for EU Ecodesign compliance. | EUR-Lex / Official Journal of the European Union2026-06-12 · unverified |
| Energy Labelling — Heat Pumps (Regulation (EU) No 811/2013) | 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 EU market and cannot substitute the required EU label.GB 12021 series (energy efficiency labelling) MIIT/SAMR energy label scheme |
Energy Labelling Regulation (EU) 811/2013 (delegated act under Regulation 2017/1369) requires an A+++ to G energy efficiency scale for space heaters. Heat pumps must display a seasonal efficiency class on a mandatory EU energy label on the product and in the product fiche. A temperature-dependent label format applies for heat pumps reflecting heating output at different outdoor temperatures.Regulation (EU) 811/2013 (energy labelling — space heaters) Regulation (EU) 2017/1369 (Energy Labelling Framework) |
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.Gap — new EU energy label required; Chinese label not accepted; seasonal efficiency must be recalculated to EN 14825. | EUR-Lex / Official Journal of the European Union2026-06-12 · unverified |
| 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 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. Heat pump compressors, motors, and inverter drives are significant emission sources covered by this standard.Directive 2014/30/EU (EMC Directive) 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 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.Gap — re-testing to EN 55014-1:2021 required; GB 4343.1 CCC test reports not accepted as EU EMC Directive conformity evidence. | EUR-Lex / Official Journal of the European Union2026-06-12 · unverified |
| 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 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 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. 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) EN 55014-2:2021 EN 61000-3-2 EN 61000-3-3 |
Separate EU 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.Gap — separate EU conformity assessment required; existing Chinese test reports do not substitute for EU EMC Directive Technical File evidence. | EUR-Lex / Official Journal of the European Union2026-06-12 · unverified |
| Pressure Equipment Directive — Refrigerant Circuit Classification | 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) 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) EN 378-1:2016+A1:2020 (system safety, used with PED) |
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. 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.Major gap — PED classification 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 Union2026-06-12 · unverified |
| 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 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.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 |
EU legal compliance must be assessed against PED where the refrigerant circuit falls within PED scope. EN 378 documentation, leak detection, and flammable refrigerant charge-limit methods differ from GB 9237, so using the voluntary EN 378 route may require a full system re-assessment, but an alternative technical solution may also be justified if it satisfies the mandatory EU requirements.Gap — PED 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 Union2026-06-12 · unverified |
| F-gas Regulation — Refrigerant Restrictions and Phase-down | 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. Heat pumps using R410A (GWP ~2088) face restrictions from 2025 onwards; R32 (GWP 675) and R290 (propane, GWP 3) are preferred compliant refrigerant options. A bulk HFC quota system limits supply of high-GWP refrigerants within the EU. Equipment with HFC refrigerants above applicable GWP limits may not be legally placed on the EU market.Regulation (EU) 2024/573 (F-gas Regulation) Regulation (EU) 517/2014 (superseded) |
R410A-charged heat pumps face EU market restrictions from 2025. Chinese manufacturers must switch to R32, R290, or other low-GWP refrigerants for EU export. No Chinese national quota system exists that aligns with the EU F-gas bulk HFC quota; EU importers must source F-gas quota separately.Major gap for R410A units — EU market placement restricted from 2025. Compliant if R32 or R290 (or other refrigerant below applicable GWP limit) is used and F-gas obligations are met. | EUR-Lex / Official Journal of the European Union2026-06-12 · unverified |
| 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 come from applicable legislation, including Pressure Equipment Directive 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 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) 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 |
PED 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, but compliance can also be demonstrated by another technically justified route that satisfies the mandatory EU legislation.Gap — assess mandatory PED applicability first; EN 378 and EN 14276 are voluntary harmonised standards for presumption of conformity and are not mandatory, but their safety and pressure-equipment methods differ from Chinese equivalents. | EUR-Lex / Official Journal of the European Union2026-06-12 · unverified |
| 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 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. 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. Re-testing to the applicable EN 60335-2-40 edition at an EU-accredited or recognised laboratory is required.Gap — re-testing to EN 60335-2-40 under EU LVD required; GB 4706.32 certification not accepted as equivalent. | EUR-Lex / Official Journal of the European Union2026-06-12 · unverified |
| 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, Pressure Equipment Directive 2014/68/EU 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.Directive 2014/68/EU (PED) EN 14276-1:2021 EN 14276-2:2021 |
EU legal compliance must be assessed against PED 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, but the mandatory obligation remains PED conformity.Major gap — PED classification and conformity assessment drive the mandatory obligation; 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 Union2026-06-12 · unverified |
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SOURCES
Official-source register.
- European Commission — Single Market · accessed 2026-06-12 · unverified · used in 1 rows
- European Commission — NANDO (New Approach Notified and Designated Organisations) · accessed 2026-06-12 · unverified · used in 1 rows
- EUR-Lex / Official Journal of the European Union · accessed 2026-06-12 · unverified · used in 1 rows
- EUR-Lex / Official Journal of the European Union · accessed 2026-06-12 · unverified · used in 1 rows
- EUR-Lex / Official Journal of the European Union · accessed 2026-06-12 · unverified · used in 2 rows
- EUR-Lex / Official Journal of the European Union · accessed 2026-06-12 · unverified · used in 4 rows
- EUR-Lex / Official Journal of the European Union · accessed 2026-06-12 · unverified · used in 1 rows
- EUR-Lex / Official Journal of the European Union · accessed 2026-06-12 · unverified · used in 1 rows