CROSS-STANDARD public interest · Air-source heat pump
China-to-Turkey 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 Turkey's CE marking framework (adopted EU directives via Presidential Decrees), TSE type-examination, TÜRKAK-accredited conformity assessment, ErP/Ecodesign energy efficiency obligations, F-Gas refrigerant controls, and pressure vessel requirements for the Turkish market.
Dataset 2026-06-11
Last verified 2026-06-17
7 rows
GAP MATRIX
Compliance Gap Matrix
| Compliance item | Common China baseline | Turkey (CE / TSE / TÜRKAK) | Gap / action | Source + verification date |
|---|---|---|---|---|
| CE Marking and TSE Type-Examination — Mandatory Conformity for Heat Pumps | Chinese heat pumps up to 40 kW require CCC (China Compulsory Certification) under GB 4706 / GB 25454, with testing to GB/T 7725 and GB 9237. CCC is issued by CNCA-designated bodies. The CCC mark, Chinese DoC, and Chinese-language documentation are prepared for the China domestic market. None of these are recognised by Turkey or count as CE marking evidence.CCC under GB 4706 / GB 25454 GB/T 7725 performance testing GB 9237 refrigerant safety CNCA certification procedures |
Turkey has adopted EU directives via Presidential Decrees (equivalent to EU Regulations and Directives in effect). CE marking is mandatory for heat pump equipment placed on the Turkish market. Applicable directives include the Low Voltage Directive (LVD, 2014/35/EU equivalent), Electromagnetic Compatibility Directive (EMC, 2014/30/EU equivalent), and Machinery Directive (2006/42/EC equivalent) where applicable. Conformity assessment may be performed by TÜRKAK-accredited bodies or EU-recognised Notified Bodies whose assessments Turkey accepts. A Declaration of Conformity (DoC) in Turkish must accompany the product; Turkish-language labelling and user documentation are required. For products not CE-marked, TSE type-examination via the Turkish Standards Institution provides an alternative compliance route.Turkey Presidential Decree adopting LVD (2014/35/EU equivalent) Turkey Presidential Decree adopting EMC Directive (2014/30/EU equivalent) Turkey Presidential Decree adopting Machinery Directive (2006/42/EC equivalent) TSE type-examination procedures TÜRKAK accreditation framework |
CCC is not recognised in Turkey and does not substitute for CE marking. Exporters must obtain CE marking under the applicable Turkish-adopted EU directives, with conformity assessment by a TÜRKAK-accredited or accepted Notified Body, and prepare a Turkish-language DoC and product labelling. Existing Chinese test reports may be partially reusable if the testing laboratory is TÜRKAK-recognised, but scope alignment to EN / IEC standards referenced by the directives must be confirmed.[INFORMATIONAL] Gap — CE marking under Turkish-adopted EU directives is mandatory; CCC is not recognised. A full CE conformity assessment, Turkish DoC, and Turkish-language documentation package must be established before market entry. | Turkish Standards Institution (TSE)2026-06-17 · reference |
| ErP / Ecodesign — Energy Performance Requirements for Heat Pumps | Chinese heat pumps are tested to GB/T 7725 for COP and SCOP under domestic Chinese efficiency standards. The China Energy Label uses a 1–5 star scale under GB 21454. Efficiency metrics and test conditions differ from EN 14511 / EN 14825, and the Chinese label scale and thresholds are not equivalent to the EU/Turkey A+++ energy label system.GB/T 7725 — Room air conditioners and heat pumps (COP/SCOP test method) GB 21454 — Minimum allowable values of energy efficiency and grades for multi-split heat pumps China Energy Label Regulation |
Turkey has adopted the EU Ecodesign Regulation 2016/2281 (equivalent) covering space heaters and combination heaters including heat pumps. This sets minimum seasonal energy performance requirements (SCOP for heating, SEER for cooling where applicable). Products must meet the prescribed minimum efficiency thresholds before CE marking can be affixed. Testing must be conducted to EN 14511 / EN 14825 (seasonal) methods. Ecodesign non-compliance is a bar to market entry independent of the energy label.Turkey equivalent of EU Regulation 2016/2281 (Ecodesign for space heaters and combination heaters) EN 14511 — Air conditioners, liquid chilling packages and heat pumps (test method) EN 14825 — Air conditioners, liquid chilling packages and heat pumps (seasonal efficiency testing) |
Chinese efficiency test data (GB/T 7725, COP/SCOP at Chinese reference conditions) cannot be directly used to demonstrate compliance with ErP Regulation 2016/2281 thresholds. Re-testing to EN 14511 / EN 14825 at EN reference conditions is required. The China 1–5 star label is not equivalent to the A+++ EU/Turkey label and cannot substitute for it.[INFORMATIONAL] Gap — EN 14511 / EN 14825 re-testing to EU ErP thresholds is required; Chinese GB efficiency data is not transferable. Products must meet minimum SCOP/SEER thresholds before CE marking. | European Commission (Regulation 2016/2281, adopted by Turkey via Presidential Decree)2026-06-17 · reference |
| EU-Aligned Energy Label (A+++ Scale) — Mandatory Display on Heat Pumps | China's domestic energy label (1–5 star, administered by CNCA / NEA) uses a different scale, different reference conditions, and different product classification criteria than the EU A+++ label. The China Energy Label is displayed on Chinese domestic products per GB 21455 and related standards. It is not compatible with the EU/Turkey A+++ label format or regulatory submission.GB 21455 — Minimum allowable values of energy efficiency for room air conditioners China Energy Label Regulation (CNCA / NEA) |
Turkey requires the EU-aligned energy label (A+++ to D or G scale depending on product category) on heat pump space heaters and combination heaters placed on the market. The label must display the seasonal space heating energy efficiency class (SCOP-derived), noise level (where applicable), and rated output. Labels must be in Turkish or at minimum show the EU-format graphical label. The label is derived from the ErP product database (EPREL equivalent) values and must be generated from EN 14825 seasonal test results.Turkey equivalent of EU Energy Labelling Regulation 2017/1369 EU Delegated Regulation 2016/2281 product fiche and label requirements EN 14825 — seasonal energy efficiency calculation method |
The Chinese 1–5 star energy label cannot be used in Turkey. Manufacturers must generate an EU-format A+++ energy label from EN 14825 seasonal test data, register product data in the applicable Turkish or EU EPREL-equivalent product database, and display the label at point of sale and in product documentation. This is a separate obligation from meeting the ErP minimum efficiency thresholds.[INFORMATIONAL] Gap — An EU-format A+++ energy label generated from EN 14825 seasonal test results is mandatory; the Chinese 1–5 star label is not transferable to Turkey. | European Commission (Energy Labelling Regulation 2017/1369, adopted by Turkey via Presidential Decree)2026-06-17 · reference |
| Turkey Market Access Duties — Importer, Turkish Documentation, and EPDK / TÜRKAK Administration | Chinese domestic-market products carry CCC, China Energy Label, Chinese GB-rated values, and Chinese-language manuals. The CCC certificate names a China-registered manufacturer and a China-market responsible party. These documents, labels, and certificates do not satisfy Turkish market responsible-party, CE marking, Turkish-language labelling, EPDK, or F-Gas administration duties without full reconstruction for the Turkish market.CCC documentation and certificate China Energy Label Chinese GB product manuals and nameplates CNCA certification framework |
Compliance for imported heat pumps in Turkey is typically executed through a Turkish importer or authorised representative who can maintain local records and respond to regulatory inquiries from TSE, TÜRKAK, ÇEVRE, or EPDK (Energy Market Regulatory Authority). Product labels, manuals, rated values, refrigerant information, installer warnings, energy efficiency labels, CE markings, and DoC must be prepared in Turkish. EPDK oversees energy-related market obligations. The authorised representative must be established in Turkey and named in the DoC. Customs clearance requires the CE marking and accompanying documentation; products without CE marking may be seized at the Turkish border.Turkey CE Marking Framework Law and Presidential Decrees (CE market surveillance) EPDK energy market regulations TÜRKAK accreditation and conformity assessment administration Turkish Customs Law — CE documentation requirements at border Turkish Consumer Protection Law — Turkish-language labelling obligations |
The market-access gap is both operational and technical: exporters must appoint a Turkish authorised representative, obtain CE marking under all applicable directives, prepare a full Turkish-language DoC and product documentation package, register with EPDK where energy-related obligations arise, align refrigerant labelling to F-Gas rules, and ensure customs-ready CE documentation before shipment. English or Chinese catalogues are not sufficient for retail, installer, or regulatory-facing Turkish documentation. The 50 Hz / 400 V grid alignment between China and Turkey reduces electrical re-engineering risk, but does not reduce documentation or conformity obligations.[INFORMATIONAL] Gap — A Turkish authorised representative, full CE documentation in Turkish, EPDK registration where applicable, and CE-ready customs documentation must be established before first shipment; Chinese domestic documentation and labels are not sufficient. | Energy Market Regulatory Authority (EPDK), Republic of Turkey2026-06-17 · reference |
| Pressure Equipment Directive (PED) — Pressure Vessels and Refrigerant Circuits in Heat Pumps | Chinese heat pump pressure vessels and refrigerant circuits are regulated under GB 150 (pressure vessels), GB/T 15042 (pressure vessel design), and AQSIQ / SAMR pressure vessel safety supervision regulations. Pressure-bearing components in Chinese heat pumps are inspected and registered with local TSB (Technical Supervision Bureau) offices. This regulatory framework, documentation, and inspection records do not satisfy PED requirements and are not recognised by Turkey.GB 150 — Pressure vessels SAMR / AQSIQ Pressure Vessel Safety Supervision Regulations GB 9237 — refrigerant circuit safety provisions |
Turkey has adopted the EU Pressure Equipment Directive (PED, 2014/68/EU equivalent) via Presidential Decree. Heat pump refrigerant circuits containing pressure-bearing components (compressors, heat exchangers, vessels, pipework) must be assessed under PED where the product exceeds the defined pressure and volume thresholds. Components classified as Category I or above require a conformity assessment; Category II and above require involvement of a TÜRKAK-accredited Notified Body. CE marking under PED must appear on the pressure equipment or assembly. For assemblies below PED thresholds, the Simple Pressure Vessels Directive (SPVD, 2014/29/EU equivalent) or EN 378 provisions may apply instead. The PED technical file must include design calculations, material traceability, and pressure testing records.Turkey Presidential Decree adopting PED (2014/68/EU equivalent) Turkey Presidential Decree adopting SPVD (2014/29/EU equivalent) where applicable EN 378-2 — Safety and environmental requirements for refrigerating systems (pressure equipment provisions) TÜRKAK accreditation for PED Notified Bodies |
Chinese pressure vessel documentation (GB 150, AQSIQ registration) is not recognised under Turkey's PED framework. Exporters must: (1) determine whether the heat pump's refrigerant circuit components exceed PED thresholds by pressure x volume product; (2) classify components into PED categories; (3) engage a TÜRKAK-accredited Notified Body for Category II+ components; (4) prepare PED-compliant design calculations, material certificates, and test records; and (5) affix CE marking under PED where required. Many small residential heat pumps fall below PED Article 4(3) thresholds and are covered by EN 378 instead — threshold assessment is the critical first step.[INFORMATIONAL] Gap — PED threshold assessment is the critical first step; Chinese GB 150 / AQSIQ pressure vessel documentation is not recognised in Turkey. TÜRKAK-accredited Notified Body involvement is required for Category II+ components. | European Commission (PED 2014/68/EU, adopted by Turkey via Presidential Decree)2026-06-17 · reference |
| Turkey F-Gas Regulation — HFC Refrigerant Controls and Quota System | China follows the Montreal Protocol HCFC phaseout schedule under SEPA / MEE regulations. R-22 is being phased out for new equipment under China's HCFC phaseout plan. China does not operate an HFC quota system equivalent to EU/Turkey F-Gas Regulation 517/2014. Chinese products exported with R-32 or R-410A refrigerants do not carry GWP labelling or F-Gas compliance documentation in the EU/Turkey format. GB 9237 sets refrigerant safety requirements for Chinese domestic products.GB 9237 — Refrigerating systems and heat pumps — Safety and environmental requirements China HCFC Phaseout Management Plan (HPMP) MEE (Ministry of Ecology and Environment) ODS regulations |
Turkey has adopted an F-Gas Regulation aligned to EU Regulation 517/2014, administered by the Ministry of Environment and Urbanisation (ÇEVRE). The regulation imposes HFC quota restrictions on producers, importers, and equipment manufacturers. R-22 is banned (HCFC phaseout completed). HFC refrigerants (R-32, R-410A, R-134a) are permitted but subject to quota allocation. Equipment containing F-gases must be labelled with the refrigerant type, GWP value, and charge quantity. Installers and service technicians handling F-gas equipment must hold certificates issued by TÜRKAK-accredited bodies. Leak detection requirements apply to larger systems.Turkey F-Gas Regulation aligned to EU Regulation No 517/2014 ÇEVRE (Ministry of Environment and Urbanisation) implementing regulations TÜRKAK accreditation for F-gas technician certification bodies |
Chinese exported heat pumps do not include GWP labelling or F-Gas compliance documentation in the Turkish/EU format. Exporters must: (1) ensure the refrigerant used is permitted under Turkey's F-Gas quota system; (2) add refrigerant type, GWP, and charge quantity labelling to the product in Turkish; (3) confirm importer compliance with HFC quota allocation; and (4) ensure downstream installers hold TÜRKAK-recognised F-Gas handling certificates. R-32 (GWP 675) and R-410A (GWP 2088) are permitted but subject to quota — R-410A faces phase-down pressure under the HFC quota trajectory.[INFORMATIONAL] Gap — Turkish F-Gas Regulation requires GWP labelling, refrigerant charge disclosure, HFC quota compliance, and TÜRKAK-certified installers. Chinese products must be re-labelled and importers must confirm quota eligibility before market placement. | Republic of Turkey Ministry of Environment, Urbanisation and Climate Change (ÇEVRE)2026-06-17 · reference |
| Refrigerant Safety Standards — EN 378 vs GB 9237 Alignment | China uses GB 9237 (equivalent to an older ISO 5149 baseline) for refrigerant safety in heat pumps and refrigerating systems. GB 9237 covers similar ground to EN 378 but with differing charge limits, classification references, and documentation requirements. Chinese products are not tested or documented to EN 378, and the technical file prepared for CCC does not map directly to EN 378 CE technical file requirements.GB 9237 — Refrigerating systems and heat pumps — Safety and environmental requirements CCC technical documentation |
Turkey requires heat pump refrigerant safety compliance under EN 378 (Refrigerating systems and heat pumps — Safety and environmental requirements), consistent with EU practice. EN 378 covers refrigerant classification, charge limits, safety relief, machinery room requirements (where applicable), and marking. CE marking under the applicable directives incorporates EN 378 as a referenced harmonised standard. Refrigerant classification under EN 378 / ISO 817 (safety groups A1, A2L, B2L, etc.) must be documented and referenced in the technical file.EN 378-1/2/3/4 — Refrigerating systems and heat pumps (Safety and environmental requirements) ISO 817 — Refrigerants — Designation and safety classification CE Machinery Directive technical file requirements |
EN 378 compliance documentation must be prepared separately from GB 9237. Key differences include: refrigerant classification per ISO 817 vs Chinese GB classification; charge limit calculations per EN 378 room-size rules; and technical file structure. For A2L refrigerants (e.g. R-32), additional EN 378 Part 2 safety provisions apply. Exporters should have the CE technical file explicitly reference EN 378 parts and confirm charge limits and classification under the EN system.[INFORMATIONAL] Gap — EN 378 refrigerant safety documentation must be prepared independently of GB 9237. Charge limit calculations, ISO 817 classification, and technical file structure must align to EN 378 requirements before CE marking. | CEN (European Committee for Standardization) — EN 378 series2026-06-17 · 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.
- Turkish Standards Institution (TSE) · accessed 2026-06-17 · reference · used in 1 rows
- European Commission (Regulation 2016/2281, adopted by Turkey via Presidential Decree) · accessed 2026-06-17 · reference · used in 1 rows
- European Commission (Energy Labelling Regulation 2017/1369, adopted by Turkey via Presidential Decree) · accessed 2026-06-17 · reference · used in 1 rows
- Energy Market Regulatory Authority (EPDK), Republic of Turkey · accessed 2026-06-17 · reference · used in 1 rows
- European Commission (PED 2014/68/EU, adopted by Turkey via Presidential Decree) · accessed 2026-06-17 · reference · used in 1 rows
- Republic of Turkey Ministry of Environment, Urbanisation and Climate Change (ÇEVRE) · accessed 2026-06-17 · reference · used in 1 rows
- CEN (European Committee for Standardization) — EN 378 series · accessed 2026-06-17 · reference · used in 1 rows