CROSS-STANDARD public interest · Air-source heat pump
China-to-Finland 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 Finland/EU CE marking, Ecodesign Regulation (EU) 2016/2281, F-gas Regulation (EU) 2024/573, Pressure Equipment Directive 2014/68/EU, and related Finnish safety and EMC requirements enforced by Tukes (Finnish Safety and Chemicals Agency) and SFS (Finnish Standards Association).
Dataset 2026-06-11
Last verified 2026-06-15
12 rows
GAP MATRIX
Compliance Gap Matrix
| Compliance item | Common China baseline | Finland (SFS / Tukes / Energiavirasto) | Gap / action | Source + verification date |
|---|---|---|---|---|
| CE Marking — Multi-Directive Framework with Finnish/Swedish Language Declaration of Conformity | CCC (China Compulsory Certification, administered by CNCA) covers safety and EMC for domestic appliances in China. CCC does not have equivalents for Ecodesign efficiency thresholds, F-gas refrigerant restrictions, or the PED Notified Body system. CCC mark is not recognised in Finland and cannot substitute CE marking. There is no Finnish or Swedish language requirement for CCC documentation.CCC (China Compulsory Certification — CNCA) GB 25131 GB 4343.1-2018 |
CE marking is mandatory for air-source heat pumps placed on the Finnish market under multiple EU directives simultaneously: (1) Low Voltage Directive 2014/35/EU for electrical safety; (2) EMC Directive 2014/30/EU for electromagnetic compatibility; (3) Pressure Equipment Directive 2014/68/EU for refrigerant pressure circuits meeting pressure/volume thresholds; and (4) Ecodesign Regulation (EU) 2016/2281 (mandatory market access requirement independent of CE marking symbol). An EU Declaration of Conformity (DoC) must be provided in Finnish (and Swedish, as Finland has two official languages) as required by Finnish language law. The Technical File must be retained for 10 years. CE marking must appear on the product, packaging, and accompanying documentation.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 Finland. Separate EU conformity assessment under each applicable directive (LVD, EMC, PED) is required. The EU Declaration of Conformity must be provided in Finnish and/or Swedish per Finnish language law — English-only DoC is not sufficient. F-gas compliance is also mandatory and assessed separately from CE marking.[INFORMATIONAL] Major gap — CCC certification does not substitute CE marking; DoC must be in Finnish and/or Swedish; separate EU conformity assessment under LVD, EMC, PED required; F-gas compliance mandatory and separate. | tukes.fi2026-06-15 · reference |
| Notified Body Requirements — PED Category II+ and NANDO-listed Bodies | In China, CQC (China Quality Certification Centre) and CNAS-accredited inspection bodies conduct third-party conformity assessment for CCC. For pressure vessels, SAMR-designated special equipment inspection bodies issue inspection certificates under the TSG/SELO framework. Neither CQC nor Chinese inspection bodies are listed on the EU NANDO register and have no legal standing for CE conformity assessment under PED.CQC (China Quality Certification Centre) 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, a NANDO-listed EU 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 NB identification number must appear on the EU Declaration of Conformity and CE marking documentation. The NANDO database (New Approach Notified and Designated Organisations) at ec.europa.eu/growth/tools-databases/nando/ is the authoritative register of recognised EU Notified Bodies.Directive 2014/68/EU (PED), Articles 14-17 (conformity assessment procedures) NANDO database (Notified Body register) |
Chinese CCC third-party bodies (CQC) and SELO inspection bodies are not recognised as EU Notified Bodies and have no legal standing for PED conformity assessment in Finland. For PED Category II+ heat pump systems, a NANDO-listed EU Notified Body must be engaged, an EC Type Examination Certificate or equivalent must be obtained, and the NB identification number must appear on the CE marking declaration before Finland market entry.[INFORMATIONAL] Major gap — Chinese CCC certification bodies and SELO inspection bodies not recognised as EU Notified Bodies; NANDO-listed NB mandatory for PED Category II+ systems in Finland; NB number must appear on EU DoC. | ec.europa.eu2026-06-15 · reference |
| Ecodesign — Seasonal Space Heating Efficiency and Cold-Climate Test Points (-15°C / -22°C) for Finland | GB 25454-2010 (Heat pumps for heating) specifies integrated part-load value (IPLV) and heating seasonal performance factor (HSPF) metrics for Chinese heat pumps. Low-ambient-temperature performance is addressed in GB/T 25127-2010 series. Neither standard employs the EU ηs seasonal efficiency metric nor the EN 14825 cold-climate test protocol with -15°C and -22°C test points. Chinese test data to GB 25454 cannot be directly used to demonstrate EU Ecodesign compliance.GB 25454-2010 (IPLV/HSPF metric) GB/T 25127-2010 series (low ambient temperature) |
Ecodesign Regulation (EU) 2016/2281 (implementing Ecodesign Directive 2009/125/EC) sets minimum seasonal space heating energy efficiency (ηs) thresholds for heat pumps. For medium-temperature applications, ηs ≥ 125% is required. Performance must be tested to EN 14825, which defines cold-climate test points at -15°C and -22°C — these are critical for Finland, where outdoor temperatures regularly fall below -20°C. Chinese heat pumps tested only at standard EN 14511 conditions (A7/W35) may not have -15°C/-22°C performance data available, and CN IPLV/HSPF metrics are not equivalent to EU ηs.Regulation (EU) 2016/2281 (Ecodesign — air heating products) Directive 2009/125/EC (Ecodesign Directive) EN 14511 (rated condition testing) EN 14825 (seasonal performance calculation, cold-climate test points) |
EU ηs metric and cold-climate EN 14825 test points (-15°C and -22°C) differ fundamentally from CN IPLV/HSPF metrics. -15°C/-22°C performance data is essential for Finland due to its climate. Chinese test reports to GB 25454 are insufficient for EU Ecodesign compliance. Full re-testing to EN 14511 and seasonal performance calculation to EN 14825 including cold-climate test points is required before Finland market entry.[INFORMATIONAL] Major gap — EU ηs metric and EN 14825 cold-climate test points (-15°C/-22°C) required for Finland; CN IPLV/HSPF test data not accepted; full re-testing to EN 14511/EN 14825 required. | energiavirasto.fi2026-06-15 · reference |
| Energy Labelling — EPREL Registration and EU A+++ to G Scale Mandatory for Finland | China's energy efficiency labelling is governed by the GB 21454-2021 (Air-to-air heat pumps — Minimum allowable values of energy efficiency and energy efficiency grades) and the MIIT/SAMR China Energy Label scheme. The Chinese label format, efficiency tier definitions, grade calculation methodology, and rating scale differ fundamentally from the EU energy label. Chinese energy labels are not recognised in Finland and cannot substitute the required EU label or EPREL registration.GB 21454-2021 (China energy efficiency grades for air-to-air heat pumps) MIIT/SAMR China Energy Label scheme |
Energy Labelling Framework Regulation (EU) 2017/1369 and its delegated acts require an A+++ to G energy efficiency scale for heat pumps. Registration in the EPREL (European Product Registry for Energy Labelling) product database is mandatory before any product can be placed on the Finnish (or any EU) market. The EU energy label must appear on the product and in product documentation. The EPREL registration number must be accessible via QR code or equivalent.Regulation (EU) 2017/1369 (Energy Labelling Framework) EPREL product database registration |
EPREL registration is mandatory before Finland market entry; Chinese products without EPREL registration cannot be legally sold in Finland. Label format and efficiency scale differ; CN label not recognised. Seasonal efficiency must be recalculated to EN 14825 including Finnish cold-climate performance, and an EPREL entry must be created with the EU-compliant efficiency class before the first unit is shipped.[INFORMATIONAL] Gap — EPREL registration mandatory before Finland market entry; CN energy label not recognised; EU A+++ to G label required with efficiency class based on EN 14825 recalculation. | ec.europa.eu2026-06-15 · reference |
| EMC Directive — Emissions (EN 55014-1) for Finnish 230/400 V 50 Hz Grid | 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/T 4343.2 covers immunity. China's grid also operates at 220 V single-phase / 380 V three-phase, 50 Hz, which is nominally similar but below EU standard voltages.GB 4343.1-2018 GB/T 4343.2 CCC (EMC emission testing) |
EMC Directive 2014/30/EU applies in Finland and is enforced by Tukes (Finnish Safety and Chemicals Agency). Heat pumps must comply with electromagnetic emission limits under harmonised standard EN 55014-1:2021. The Finnish electricity grid operates at 230 V single-phase / 400 V three-phase, 50 Hz — the same nominal frequency as the rest of the EU. Compressors, inverter drives, and fan motors are principal emission sources covered by EN 55014-1.Directive 2014/30/EU (EMC Directive) EN 55014-1:2021 |
CE marking under the EMC Directive is mandatory for Finland market entry; CCC mark does not substitute CE. 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. Tukes conducts market surveillance and can withdraw non-compliant products.[INFORMATIONAL] Gap — CE marking under EMC Directive required for Finland; GB 4343.1 CCC test reports not accepted; re-testing to EN 55014-1:2021 required. | tukes.fi2026-06-15 · reference |
| Power Quality — EN 61000-3-2 Harmonics and EN 61000-3-3 Flicker on Finnish 230/400 V 50 Hz Grid | GB 17625.1 is China's national adoption of IEC 61000-3-2 (harmonic current emissions) and GB/T 17625.2 adopts IEC 61000-3-3 (voltage fluctuations and flicker). China's grid operates at 220 V/380 V 50 Hz — nominally the same frequency as Finland but slightly lower voltage. Despite the shared IEC lineage, Chinese test reports to GB 17625.1 and GB/T 17625.2 are not accepted as EU Technical File evidence for Finland market conformity.GB 17625.1 (IEC 61000-3-2 adoption) GB/T 17625.2 (IEC 61000-3-3 adoption) |
EMC Directive 2014/30/EU requires compliance with EN 61000-3-2 (limits for harmonic current emissions) and EN 61000-3-3 (limits for voltage changes, voltage fluctuations and flicker) for equipment connected to the Finnish public low-voltage supply network at 230/400 V 50 Hz. EN 55014-2:2021 covers immunity requirements for household appliances. Conformity is demonstrated via manufacturer self-declaration with a Technical File; no mandatory third-party certification is required, but test evidence must be retained for 10 years.Directive 2014/30/EU (EMC Directive) EN 61000-3-2 EN 61000-3-3 EN 55014-2:2021 |
Finnish grid is 230/400 V 50 Hz; Chinese products tested at 220/380 V may need additional verification at EU nominal voltages. Separate EU conformity assessment is required — existing Chinese 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 before Finland market entry.[INFORMATIONAL] Gap — EN 61000-3 series compliance mandatory for Finland; GB 17625.1 tests not accepted as EU Technical File evidence; voltage verification at 230/400 V may be required. | sfs.fi2026-06-15 · reference |
| Pressure Equipment Directive — Refrigerant Circuit Classification (Tukes Market Surveillance) | TSG ZB001-2016 (Special Equipment Safety Technical Supervision Regulations for Refrigerating System 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 ZB001 (SAMR/SELO refrigerant pressure vessel supervision) GB 150.1-150.4-2011 (Pressure vessels) |
Pressure Equipment Directive 2014/68/EU (PED) applies in Finland and is enforced by Tukes (Finnish Safety and Chemicals Agency) as the national market surveillance authority. Heat pump refrigerant circuits meeting PED pressure, volume, and fluid-group thresholds must be classified: Group 1 covers flammable or toxic refrigerants (e.g. R290); Group 2 covers non-flammable, non-toxic refrigerants (e.g. R32, R410A). Category I allows manufacturer self-declaration; Categories II, III, and IV require a NANDO-listed EU Notified Body. EN 378 harmonised standards apply for system-level safety.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 |
PED conformity assessment by an EU Notified Body is mandatory for Category II+ refrigerant circuits; Chinese pressure vessel certificates (TSG/SELO) are not accepted under PED. Tukes enforces PED in Finland. Refrigerant circuit re-design or re-certification to PED categories may be required before Finland market entry.[INFORMATIONAL] Major gap — PED conformity assessment by EU Notified Body mandatory for Category II+ circuits; CN pressure vessel certificates (TSG/SELO) not accepted; Tukes enforces PED in Finland. | tukes.fi2026-06-15 · reference |
| Refrigerant Circuit Safety — EN 378 System Safety Requirements (Finland Application) | GB/T 18430.1 (Vapor compression liquid chilling packages — Testing and rating for performance — Part 1: Water-cooled liquid chilling packages) and GB/T 18430.2 cover performance testing for heat pumps. GB 9237-2008 (Safety requirements for refrigerating systems, adopting ISO 5149:1993) addresses system safety. Charge limits for flammable refrigerants in indoor environments and leak detection obligations differ from EN 378.GB/T 18430.1 GB/T 18430.2 GB 9237-2008 (ISO 5149:1993 adoption) |
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 under PED 2014/68/EU. Applying them supports presumption of conformity with relevant EU essential requirements. EN 378 is the harmonised standard recognised in Finland; SFS publishes Finnish-language adoptions. Note: EN 378 addresses refrigerant charge limits for occupied spaces — especially relevant in Finnish residential construction where heat pumps are often installed in utility rooms with limited ventilation.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 378 is the harmonised standard recognised in Finland; CN equivalent (GB/T 18430, GB 9237) is not recognised for CE compliance. Indoor refrigerant charge limits under EN 378 may require re-assessment for Finnish residential installation conditions. Full system re-assessment against EN 378 may be needed; Chinese test reports to GB/T 18430 or GB 9237 are not accepted as evidence of EN 378 conformity.[INFORMATIONAL] Gap — EN 378 is the harmonised standard for Finland; CN equivalent not recognised for CE compliance; refrigerant charge limits for Finnish residential installations require re-assessment against EN 378. | sfs.fi2026-06-15 · reference |
| F-gas Regulation — GWP Caps, Phase-down, and Tukes-recognised Technician Qualification | GB/T 40879-2021 (Management of fluorinated greenhouse gases in refrigerating and air-conditioning equipment) provides voluntary guidance on F-gas management in China. China has no equivalent GWP-based phase-down quota system or mandatory GWP caps for domestic heat pump sales. R410A remains widely used in Chinese air-source heat pumps. Technician certification exists under GB/T framework but is not equivalent to Tukes-recognised F-gas qualification.GB/T 40879-2021 voluntary phase-down schedule (no GWP cap mandate) |
EU F-gas Regulation (EU) 2024/573 (superseding 517/2014) applies in Finland and is enforced by Tukes. New split AC/heat pump systems ≤12 kW using HFCs with GWP ≥ 750 (e.g. R410A, GWP ~2088) are prohibited from being placed on the Finnish market from 1 January 2025. R32 (GWP 675) and R290 (propane, GWP 3) are preferred compliant options. Technicians handling F-gas refrigerants in Finland must hold a Tukes-recognised F-gas qualification certificate; untrained handling is illegal.Regulation (EU) 2024/573 (F-gas Regulation) Regulation (EU) 517/2014 (superseded) |
EU GWP caps are stricter than CN requirements — R410A-charged heat pumps ≤12 kW cannot be legally sold in Finland from 2025. Refrigerant selection must comply with (EU) 2024/573 GWP limits. Finnish F-gas technician certification (Tukes-recognised) is mandatory for installation and servicing; Chinese technician qualifications are not accepted. Chinese exporters must communicate F-gas obligations clearly to Finnish importers and installers.[INFORMATIONAL] Major gap — R410A heat pumps ≤12 kW banned in Finland from 2025; Tukes-recognised F-gas technician qualification mandatory; CN GB/T 40879 voluntary, no GWP cap equivalent. | tukes.fi2026-06-15 · reference |
| F-gas Leakage Checks and Logbook Requirements under (EU) 2024/573 Art. 6 | China has no mandatory equivalent to (EU) 2024/573 Art. 6 leakage check intervals or equipment logbook requirements. GB/T 40879-2021 provides voluntary guidance on F-gas management but does not prescribe mandatory periodic leakage inspections or logbook obligations for heat pump operators. The responsibility for leakage records falls on voluntary compliance rather than legal mandate.GB/T 40879-2021 (voluntary) No mandatory equivalent |
Under F-gas Regulation (EU) 2024/573 Article 6, operators of stationary refrigeration, air conditioning, and heat pump equipment containing fluorinated greenhouse gases equivalent to 5 tonnes of CO2 or more must ensure mandatory leakage checks at regular intervals and maintain an equipment logbook recording refrigerant quantities added/removed, technician identity, and leak check dates. In Finland, Tukes enforces these obligations and may inspect installation records.Regulation (EU) 2024/573, Article 6 Regulation (EU) 517/2014 (superseded) |
Finnish operators of qualifying heat pump systems must maintain F-gas logbooks and conduct mandatory leakage checks; there is no equivalent mandatory obligation in China. Chinese exporters must communicate maintenance intervals, refrigerant charge quantities, and logbook requirements clearly to Finnish importers and end-users to ensure downstream legal compliance.[INFORMATIONAL] Gap — mandatory F-gas leakage checks and logbook required for qualifying systems in Finland; no CN equivalent; Chinese exporters must document maintenance obligations for Finnish operators. | eur-lex.europa.eu2026-06-15 · reference |
| General Product Safety — GPSR (EU) 2023/988 and Tukes Market Surveillance / RAPEX Reporting | GB 25131-2010 (Safety of household and similar electrical appliances — Particular requirements for heat pumps, air conditioners and dehumidifiers) and GB 4706.32 cover product safety for heat pumps in China. China has a national product recall system (SAMR Quality and Safety Bureau) but no direct equivalent to GPSR's proactive RAPEX reporting obligation or the EU Safety Gate incident notification procedure. Chinese CCC certification demonstrates conformity with domestic standards but does not satisfy GPSR obligations.GB 25131-2010 GB 4706.32 SAMR product recall system (voluntary equivalence only) |
General Product Safety Regulation (EU) 2023/988 (GPSR), applicable from 13 December 2024, establishes a general product safety obligation for all consumer products placed on the EU market, including heat pumps sold to Finnish consumers. Market surveillance in Finland is conducted by Tukes (Finnish Safety and Chemicals Agency). Serious risks must be notified via the RAPEX/Safety Gate rapid alert system. Economic operators (manufacturers, importers, distributors) must have internal accident reporting procedures and cooperate with Tukes on safety investigations. Online marketplace operators also face new obligations.Regulation (EU) 2023/988 (GPSR) RAPEX / Safety Gate rapid alert system |
GPSR requires proactive incident reporting to RAPEX/Safety Gate for serious risks — there is no equivalent mandatory obligation in China. Tukes conducts inspections of heat pumps in the Finnish market and can order recalls or impose market bans. Chinese manufacturers and importers must establish GPSR-compliant internal safety procedures, designate an EU-based responsible person (required by GPSR for non-EU manufacturers), and cooperate with Tukes on any safety investigations.[INFORMATIONAL] Gap — GPSR requires proactive RAPEX/Safety Gate reporting and EU responsible person designation; Tukes enforces in Finland; CN standards (GB 25131/GB 4706.32) not directly accepted as proof of EU safety compliance. | tukes.fi2026-06-15 · reference |
| Electrical Safety — EN 60335-2-40 Harmonised under LVD 2014/35/EU (Finnish Application) | GB 25131-2010 (Safety of household and similar electrical appliances — Particular requirements for heat pumps, air conditioners and dehumidifiers) is China's national adoption of IEC 60335-2-40:2002/AMD1:2005. GB 4706.32-2012 is based on IEC 60335-2-40:2005. CCC certification includes testing to GB 25131/GB 4706.32. The Chinese standards are based on older IEC editions and may have China-specific deviations from the harmonised EN version. Chinese test reports under GB 25131 or GB 4706.32 are not accepted as equivalent to EU LVD conformity for Finland.GB 25131-2010 (IEC 60335-2-40:2002/AMD1:2005 adoption) GB 4706.32-2012 (IEC 60335-2-40:2005 adoption) CCC (China Compulsory Certification) |
Low Voltage Directive 2014/35/EU applies in Finland and 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. SFS (Finnish Standards Association) publishes Finnish-language adoptions. 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) |
EN 60335-2-40 harmonised under LVD 2014/35/EU is required for Finland; GB 25131/GB 4706.32 are based on older IEC editions with possible CN deviations. CCC certification under GB 25131 or 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 EU-recognised laboratory is required before Finland market entry. Tukes may verify compliance via market surveillance.[INFORMATIONAL] Gap — EN 60335-2-40 harmonised under LVD required for Finland; CN GB 25131/GB 4706.32 based on older IEC editions with possible deviations; re-testing at EU-recognised laboratory required; CCC certification not accepted as LVD equivalence. | sfs.fi2026-06-15 · reference |
E-E-A-T
Named editorial review
Pending named reviewer
Official regulator, standards body, notified body, customs, or primary legal source preferred. Local PDFs are not accepted.
Editorial controlsRows must include publisher, official URL, access date, verification flag, and last_verified before human_reviewed can be true.
SOURCES
Official-source register.
- tukes.fi · accessed 2026-06-15 · reference · used in 1 rows
- ec.europa.eu · accessed 2026-06-15 · reference · used in 1 rows
- energiavirasto.fi · accessed 2026-06-15 · reference · used in 1 rows
- ec.europa.eu · accessed 2026-06-15 · reference · used in 1 rows
- tukes.fi · accessed 2026-06-15 · reference · used in 1 rows
- sfs.fi · accessed 2026-06-15 · reference · used in 3 rows
- tukes.fi · accessed 2026-06-15 · reference · used in 1 rows
- tukes.fi · accessed 2026-06-15 · reference · used in 1 rows
- eur-lex.europa.eu · accessed 2026-06-15 · reference · used in 1 rows
- tukes.fi · accessed 2026-06-15 · reference · used in 1 rows