CROSS-STANDARD public interest · Air-source heat pump

China-to-Japan 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 Japan's PSE / DENAN electrical safety framework, Top Runner energy efficiency rules under the Energy Conservation Act, fluorocarbon controls, JIS B 8615, JIS C 9612, and METI-administered market obligations.

Dataset 2026-06-11 Last verified 2026-06-12 5 rows

GAP MATRIX

Compliance Gap Matrix

Gap matrix
Compliance item Common China baseline Japan (PSE / Top Runner) Gap / action Source + verification date
JIS Performance Standards — JIS B 8615 and JIS C 9612 Chinese heat-pump and room-air-conditioner documentation often relies on GB/T 7725, GB 21455, GB/T 25127, and related GB methods. These Chinese standards may cover similar capacity, COP, APF, and safety objectives, but they do not create automatic equivalence to Japanese JIS test conditions, classification, or consumer-facing performance declarations.GB/T 7725
GB 21455
GB/T 25127 series		 Japan market documentation for air-source heat pumps and air conditioners commonly references Japanese Industrial Standards such as JIS B 8615 for package air conditioners / heat pumps and JIS C 9612 for room air conditioners. These standards support Japanese performance declarations, capacity ratings, APF-related calculations, noise and test-condition disclosures, and customer-facing catalogues. The applicable JIS edition and product scope must be confirmed for each model.JIS B 8615
JIS C 9612
Japanese Industrial Standardization framework		 Chinese test reports should be mapped clause-by-clause against JIS B 8615 or JIS C 9612 before reuse. Where test conditions, seasonal calculation, sound measurement, rated capacity bands, or catalogue disclosure requirements differ, Japan-specific retesting or recalculation is needed.Gap — JIS B 8615 and JIS C 9612 references must be checked for the model; GB reports are not automatically reusable without JIS mapping, retesting, or recalculation. Japanese Industrial Standards Committee (JISC), Ministry of Economy, Trade and Industry2026-06-12 · unverified
METI Market Access Duties — Importer, Labelling, and Japanese Documentation Chinese domestic-market products commonly carry CCC, China Energy Label, Chinese GB-rated values, and Chinese-language manuals. These documents do not meet Japan-market importer, notification, recordkeeping, Japanese-language labelling, or product category classification duties without conversion and local responsibility assignment.CCC documentation
China Energy Label
Chinese GB product manuals and nameplates		 Japan compliance for imported air-source heat pumps is usually executed through a Japanese importer, notifying supplier, or distributor that can maintain local records and respond to METI or consumer-safety inquiries. Product labels, manuals, rated values, refrigerant information, installer warnings, energy-efficiency information, and PSE markings where applicable must be prepared in a Japan-market format, generally in Japanese.METI product safety administration
DENAN notification and recordkeeping where applicable
Energy Conservation Act labelling and reporting where applicable
Fluorocarbons Emission Control Act documentation where applicable		 The market-access gap is operational as well as technical: exporters must appoint or support a Japan-side responsible party, convert markings and manuals to Japanese, align rated values to JIS / Top Runner methods, and preserve evidence for PSE, energy efficiency, and refrigerant obligations. English or Chinese catalogues are not sufficient for retail or installer-facing Japan documentation.Gap — Japan-market responsible-party, Japanese documentation, and recordkeeping duties must be built before sale; Chinese domestic labels and manuals are not enough. Ministry of Economy, Trade and Industry (METI), Japan2026-06-12 · unverified
PSE / DENAN Electrical Safety — Air Conditioners and Heat Pump Appliances China's CCC regime covers many household and similar electrical appliances, using Chinese GB safety and EMC standards such as GB 4706.32 for heat pumps, air conditioners, and dehumidifiers. CCC certificates and Chinese factory inspection records are domestic-market evidence and are not accepted as Japanese PSE evidence under DENAN.CCC (China Compulsory Certification)
GB 4706.32
GB 4343.1		 Japan's Electrical Appliance and Material Safety Act (DENAN), administered by METI, requires in-scope electrical appliances and materials to satisfy technical requirements and bear the applicable PSE mark before sale. Air conditioners and heat-pump appliances must be checked against the DENAN designated product scope, rated-voltage limits, power-supply configuration, and component list. Importers or notifying suppliers generally carry the Japanese compliance duties, including notification, conformity confirmation, inspection record retention, and proper PSE marking.電気用品安全法 (Electrical Appliance and Material Safety Act, DENAN)
METI technical requirements for electrical appliances and materials
PSE marking requirements for applicable DENAN products		 CCC does not substitute PSE. Chinese exporters must determine whether the finished unit, power supply, compressor motor, cord set, plug, or other components are DENAN-scope products and then support the Japanese notifying supplier with test evidence, inspection records, Japanese markings, and technical files. Where a specified electrical appliance route applies, a METI-recognised conformity assessment body may be needed.Major gap where DENAN applies — PSE scope and marking must be confirmed for the unit and relevant components; CCC evidence does not substitute Japanese DENAN compliance. Ministry of Economy, Trade and Industry (METI), Japan2026-06-12 · unverified
Refrigerant Controls — Fluorocarbons Emission Control Act China applies refrigerant identification and safety standards, and participates in HFC phase-down obligations under the Montreal Protocol / Kigali Amendment framework, but the domestic equipment-level labelling, leakage management, and recovery obligations differ from Japan's fluorocarbon regime. Chinese product labels and refrigerant declarations do not substitute Japanese fluorocarbon documentation.GB/T 7725
GB/T 25127 series
Montreal Protocol / Kigali Amendment implementation in China		 Japan regulates fluorocarbons through the Act on Rational Use and Proper Management of Fluorocarbons and related METI / MOE measures. Heat pumps and air-conditioning equipment using HFC refrigerants may trigger obligations across product design, labelling, leakage management, charging and recovery, and downstream owner or installer duties. Exporters must identify refrigerant type, GWP, charge amount, product category, and whether low-GWP alternatives or designated product targets apply.フロン類の使用の合理化及び管理の適正化に関する法律 (Fluorocarbons Emission Control Act)
METI / MOE fluorocarbon management measures
Japan HFC phase-down and designated product measures		 R410A, R32, R290, and other refrigerant designs require Japan-specific review. The gap is not only GWP value: Japanese labels, charge and recovery information, installer or owner instructions, and leakage-management documentation may be required. Export documentation should separate product refrigerant content, shipment classification, and post-sale fluorocarbon obligations.Gap — refrigerant selection and documentation must be reviewed against Japan's Fluorocarbons Emission Control Act; Chinese refrigerant markings and GB reports are not sufficient by themselves. Ministry of Economy, Trade and Industry (METI), Japan2026-06-12 · unverified
Top Runner Energy Efficiency — Air Conditioners and Applicable Heat Pumps China uses mandatory energy efficiency standards and the China Energy Label scheme for room air conditioners and heat-pump products, including GB 21455 for room air conditioners. Chinese seasonal or rated efficiency data are not automatically equivalent to Japan's Top Runner classification, APF calculation, or labelling requirements.GB 21455
China Energy Label scheme		 Japan's Energy Conservation Act uses the Top Runner Program for designated energy-consuming equipment. Air conditioners are an adopted Top Runner category, and applicable heat-pump products sold as air conditioners must meet target standard values, measurement methods, labelling, and reporting obligations set by METI / ANRE. Compliance analysis must identify the exact product class, cooling/heating capacity range, APF or applicable performance metric, and Japanese calculation conditions.Act on Rationalizing Energy Use and Shifting to Non-fossil Energy (Energy Conservation Act)
Top Runner Program for air conditioners
METI / Agency for Natural Resources and Energy energy efficiency rules		 Japan Top Runner is mandatory where the product falls within an adopted category such as air conditioners. Chinese GB 21455 data should be treated as a starting point only; exporters need Japan-specific classification, test data, APF or applicable efficiency calculation, Japanese label content, and importer reporting support.Major gap — Top Runner is mandatory for applicable air conditioner / heat-pump categories; Chinese energy-label data must be reclassified and recalculated under Japan's METI / ANRE method. e-Gov Law Search / Government of Japan (Energy Conservation Act)2026-06-12 · unverified

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