CROSS-STANDARD public interest · Refrigerator / cold appliance

China-to-UK Refrigerator 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 common China household refrigerator documentation against UK UKCA / Ecodesign requirements: electrical safety (SI 2016/1101 / BS EN 60335-2-24), energy efficiency and energy labelling (SI 2021/1295), F-gas refrigerant controls (SI 2022/1013), electromagnetic compatibility (SI 2016/1091), and UKCA marking with UK Responsible Person requirement — including the CE-to-UKCA transition status.

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

GAP MATRIX

Compliance Gap Matrix

Gap matrix
Compliance item Common China baseline United Kingdom (UKCA / Ecodesign) Gap / action Source + verification date
Electrical Safety — Household Refrigerating Appliances China requires compliance with GB 4706.13-2014 (Household and similar electrical appliances — Safety — Particular requirements for refrigerating appliances, ice-cream appliances and ice makers), which is technically aligned with IEC 60335-2-24 but contains national deviations. Mandatory certification under the China Compulsory Certification (CCC) scheme administered by CNCA/SAMR is required for domestic market placement. CCC certification to GB 4706.13 does not satisfy the UK conformity assessment pathway under SI 2016/1101.GB 4706.13-2014 — Household and similar electrical appliances — Safety — Particular requirements for refrigerating appliances, ice-cream appliances and ice makers (SAMR/SAC)
GB 4706.1-2005 — Household and similar electrical appliances — Safety — General requirements (SAMR/SAC)		 Household refrigerating appliances (refrigerators, freezers, combined refrigerator-freezers, and similar cold appliances) placed on the UK market must comply with the Electrical Equipment (Safety) Regulations 2016 (SI 2016/1101), which is the UK retained law equivalent of the EU Low Voltage Directive 2014/35/EU. The product must meet essential safety requirements covering protection against electric shock, abnormal temperatures, mechanical hazards, insulation, clearances, and creepage distances. The primary harmonised standard conferring a presumption of conformity is BS EN 60335-2-24:2010+A11:2020 (Household and similar electrical appliances — Safety — Part 2-24: Particular requirements for refrigerating appliances, ice-cream appliances and ice makers). This standard has been adopted into the UK designated standards framework.Electrical Equipment (Safety) Regulations 2016 (SI 2016/1101)
BS EN 60335-2-24:2010+A11:2020 — Household and similar electrical appliances — Safety — Part 2-24: Particular requirements for refrigerating appliances, ice-cream appliances and ice makers
BS EN 60335-1:2012+A14:2019 — Household and similar electrical appliances — Safety — Part 1: General requirements		 Exporters must obtain fresh testing to BS EN 60335-2-24 (and BS EN 60335-1 for general requirements) from a UKAS-accredited laboratory or a conformity assessment body accepted under ILAC MRA. Existing CCC / GB 4706.13 test reports do not substitute. The UK conformity assessment route is manufacturer self-declaration with a Technical Construction File (TCF) for most household appliances; a third-party approved body is not mandatory but the designated standards must be tested. Documentation gap: a UK Declaration of Conformity (DoC), UKCA marking, and UK-English instructions are all required. Plug type must be BS 1363 (UK 3-pin) — Chinese appliances typically ship with a different plug type requiring adaptation or rewiring.[INFORMATIONAL] UKCA marking under SI 2016/1101 is mandatory for GB market placement. BS EN 60335-2-24 is the designated standard granting presumption of conformity. Chinese CCC / GB 4706.13 certification does not satisfy the UK conformity assessment pathway; independent re-testing to the BS EN standard is required. A UK-English Declaration of Conformity and BS 1363 plug adaptation are also required. UK Government / legislation.gov.uk2026-06-12 · unverified
Electromagnetic Compatibility (EMC) — Household Refrigerating Appliances China requires EMC compliance for household appliances under GB 4343.1-2018 (Household electrical appliances, electric tools and similar apparatus — Requirements for the suppression of radio interference — Part 1: Emission) and GB/T 4343.2-2020 (Immunity), administered by SAMR/SAC. CCC certification includes EMC testing for relevant product categories. The Chinese GB 4343 series is technically aligned with CISPR 14 (the international standard on which BS EN 55014 is also based) but contains national annexes and deviations. CCC-granted EMC compliance is not accepted under the UK SI 2016/1091 conformity assessment pathway.GB 4343.1-2018 — Electromagnetic disturbances — Requirements for household appliances, electric tools and similar apparatus — Part 1: Emission (SAMR/SAC)
GB/T 4343.2-2020 — Electromagnetic disturbances — Requirements for household appliances, electric tools and similar apparatus — Part 2: Immunity (SAC)		 Household refrigerating appliances placed on the GB market must comply with the Electromagnetic Compatibility Regulations 2016 (SI 2016/1091), the UK retained law equivalent of EU Directive 2014/30/EU. The regulations require that the appliance does not generate electromagnetic disturbances exceeding the limits that would prevent other equipment from operating normally (emission requirements), and that it has an adequate level of immunity to the electromagnetic disturbance expected in its normal use environment (immunity requirements). The primary harmonised standard applicable to household refrigerating appliances for EMC purposes is BS EN 55014-1 (Electromagnetic disturbances — Requirements for household appliances, electric tools and similar apparatus — Part 1: Emission) and BS EN 55014-2 (Immunity). For appliances with electronic controls and inverter compressors, additional standards such as BS EN IEC 61000-3-2 (harmonic current emissions) and BS EN IEC 61000-3-3 (voltage fluctuations and flicker) also apply.Electromagnetic Compatibility Regulations 2016 (SI 2016/1091)
BS EN 55014-1:2021 — Electromagnetic disturbances — Requirements for household appliances, electric tools and similar apparatus — Part 1: Emission
BS EN 55014-2:2015+A1:2019 — Electromagnetic disturbances — Requirements for household appliances, electric tools and similar apparatus — Part 2: Immunity
BS EN IEC 61000-3-2:2019+A1:2021 — Electromagnetic compatibility (EMC) — Part 3-2: Limits — Limits for harmonic current emissions
BS EN IEC 61000-3-3:2013+A2:2021 — Electromagnetic compatibility (EMC) — Part 3-3: Limits — Limitation of voltage changes, voltage fluctuations and flicker		 The core gap is the conformity assessment pathway: the UK route under SI 2016/1091 requires testing against BS EN 55014-1 and BS EN 55014-2 (and related 61000-3-x standards for electronic/inverter models) at a UKAS-accredited laboratory or equivalent, with a UK Declaration of Conformity and UKCA marking. Chinese CCC EMC test reports (even if tested to GB 4343 which is CISPR 14-based) do not satisfy this requirement. For inverter compressor models increasingly common in modern refrigerators, the harmonic current (EN IEC 61000-3-2) and flicker (EN IEC 61000-3-3) testing requirements must be verified — these may differ from Chinese test conditions. A UK Technical File must document the EMC assessment separately from the safety TCF.[INFORMATIONAL] SI 2016/1091 requires EMC conformity assessment (emission and immunity) to UK designated standards (BS EN 55014-1/2 and related 61000-3 series for inverter models) as part of UKCA marking. Chinese GB 4343 / CCC EMC test reports are not accepted. A separate UK Technical File section for EMC and a UK DoC are required. Inverter compressor models require additional harmonic and flicker testing. UK Government / legislation.gov.uk2026-06-12 · unverified
Energy Efficiency — Ecodesign Requirements for Household Refrigerating Appliances China mandates energy efficiency compliance under GB 12021.2-2015 (Minimum allowable values of energy efficiency and energy efficiency grades for household refrigerators), enforced under the China Energy Label scheme administered by NDRC and SAMR. The Chinese system uses a 1-to-5 grade scale (Grade 1 being most efficient). Energy consumption testing follows GB/T 8059 series standards. China's energy label and test methodology differ substantially from the UK EEI-based system — Chinese Grade 1/2 ratings are not directly comparable to UK A-G labels. Registration in China's energy label filing system (energylabel.cn) does not satisfy the UK GPDB/EPREL-equivalent registration requirement.GB 12021.2-2015 — Minimum allowable values of energy efficiency and energy efficiency grades for household refrigerators (NDRC/SAMR)
GB/T 8059-2016 — Methods for measuring the performance of household and similar refrigerating appliances (SAC)		 Household refrigerating appliances placed on the Great Britain (GB) market must comply with the Energy-related Products and Energy Information (Household Refrigerating Appliances) Regulations 2021 (SI 2021/1295), which is the UK retained implementation of EU Regulation 2019/2019 (Ecodesign for household refrigerating appliances) and EU Regulation 2019/2016 (energy labelling). The regulations set minimum energy performance requirements expressed as an Energy Efficiency Index (EEI) — from 1 March 2021, no refrigerating appliance with EEI ≥ 80 may be placed on the GB market. A new A-to-G energy label (replacing the old A+/A++/A+++ scale) with a QR code linking to the GB Product Database (GPDB) / GB EPREL equivalent is mandatory. Climate classes (SN, N, ST, T) and specific temperature range requirements for food compartments must be met and declared.Energy-related Products and Energy Information (Household Refrigerating Appliances) Regulations 2021 (SI 2021/1295)
Commission Regulation (EU) 2019/2019 (retained in UK law as basis for SI 2021/1295) — Ecodesign requirements for household refrigerating appliances
Commission Delegated Regulation (EU) 2019/2016 (retained in UK law) — Energy labelling of household refrigerating appliances		 Three distinct gaps exist: (1) Performance gap — the product EEI must be below 80 (calculated per Annex IV of EU 2019/2019 / SI 2021/1295 methodology), which may not align with Chinese GB 12021.2 Grade 1 products depending on the model; (2) Label gap — a UK-compliant A-G energy label with QR code must be physically affixed; the Chinese energy label format is not accepted; (3) Registration gap — the product must be registered in the UK GPDB or equivalent GB register before supply; no Chinese registry entry substitutes. Additionally, the noise declaration and net/gross volume measurement methodology must follow EN 15502-1 or equivalent UK-designated standards, which differ from Chinese test methods.[INFORMATIONAL] SI 2021/1295 imposes mandatory EEI limits, a new A-G energy label with QR code, and GPDB product registration before GB market supply. Chinese GB 12021.2 energy labels and energylabel.cn registration do not satisfy any of these three requirements. Re-testing to UK/EU methodology, re-labelling, and fresh GPDB registration are all required. UK Government / legislation.gov.uk2026-06-12 · unverified
Refrigerant Controls — F-gas Regulation (GB) and Alternatives China regulates ozone-depleting substances and some HFCs under the Regulations on the Administration of Ozone-Depleting Substances (State Council Order No. 573, 2010) and through compliance with the Montreal Protocol phase-out schedule administered by the Ministry of Ecology and Environment (MEE). Chinese domestic household refrigerators commonly use R-600a (isobutane) as the refrigerant in compliance with the phase-down schedule. There is no Chinese domestic regulation that directly mirrors the UK F-gas GWP-based prohibition threshold of GWP ≥ 150 for household appliances — Chinese regulations focus primarily on HCFC phase-out rather than HFC GWP limits for this product category.Regulations on the Administration of Ozone-Depleting Substances (State Council Order No. 573, 2010) — China
Montreal Protocol phase-out schedule as implemented by Ministry of Ecology and Environment (MEE), China		 The UK Fluorinated Greenhouse Gases Regulations 2022 (SI 2022/1013), which came into force on 1 January 2023, governs the use of hydrofluorocarbons (HFCs) and other fluorinated gases in refrigerating appliances placed on the GB market. Under these regulations, household refrigerating appliances that contain HFCs with a Global Warming Potential (GWP) of 150 or above were prohibited from being placed on the GB market from 1 January 2022 (under the prior retained EU F-gas Regulation (EU) 517/2014). The current SI 2022/1013 continues and develops this phase-down regime. Products using R-600a (isobutane, GWP 3) or R-134a (GWP 1430 — prohibited for new household refrigerators from 1 Jan 2022) must be assessed against the current GWP thresholds. Products using refrigerants such as R-600a (isobutane) comply; products still using R-134a do not. Labelling requirements: the type and quantity of refrigerant, its GWP, and a statement that the product contains fluorinated greenhouse gases (if applicable) must be displayed on the product.The Fluorinated Greenhouse Gases Regulations 2022 (SI 2022/1013)
Regulation (EU) No 517/2014 on fluorinated greenhouse gases (retained in UK law as basis for GB F-gas regime prior to SI 2022/1013)		 The primary gap is refrigerant identity and GWP verification: (1) If the Chinese-manufactured refrigerator uses R-134a (GWP 1430), it is prohibited from GB market placement — a refrigerant change to R-600a or another low-GWP alternative is required before export; (2) If R-600a is already used, this requirement is likely met, but the refrigerant type, quantity (grams), and GWP must still be clearly labelled on the appliance in English per SI 2022/1013 requirements; (3) The manufacturer must verify the precise refrigerant charge and GWP — reliance on Chinese factory documentation without independent verification is a documentation risk. NOTE: R-600a (isobutane) is flammable (A3 safety classification under ISO 817) — UK-market products using R-600a must comply with the flammability handling and labelling requirements within BS EN 60335-2-24 (safety standard, separate from F-gas). Most modern Chinese household refrigerators have transitioned to R-600a; verify by reviewing the refrigerant nameplate.[INFORMATIONAL] SI 2022/1013 prohibits new household refrigerating appliances using HFC refrigerants with GWP ≥ 150 (including R-134a) on the GB market. Products using R-600a are not subject to this prohibition. Verify the refrigerant nameplate on every model before export. English-language refrigerant labelling (type, quantity in grams, GWP) must be affixed to the appliance. No equivalent Chinese regulatory prohibition exists — Chinese exporters must independently assess each model. UK Government / legislation.gov.uk2026-06-12 · unverified
Market Access — UKCA Marking, UK Responsible Person, and CE Transition Status China does not have a direct equivalent to the UKCA marking or the UK Responsible Person requirement. For domestic China market access, the equivalent market access controls are: (1) CCC (China Compulsory Certification) marking — mandatory for household refrigerating appliances under the CNCA-C09 scheme; (2) a designated Chinese manufacturer or authorised importer bears regulatory responsibility; (3) the China Energy Label (GB 12021.2) must be affixed. There is no Chinese requirement for a UK-resident representative.China Compulsory Certification (CCC) — CNCA-C09-01 scheme for household refrigerating appliances (SAMR/CNCA)
GB 12021.2-2015 — China energy efficiency label requirement (NDRC/SAMR)		 Since 1 January 2021 (end of the Brexit transition period), products placed on the Great Britain (England, Scotland, Wales) market must carry the UKCA (UK Conformity Assessed) marking rather than CE marking. For household refrigerating appliances, the UKCA mark replaces CE under SI 2016/1101 (electrical safety), SI 2016/1091 (EMC), and SI 2021/1295 (energy/ecodesign). IMPORTANT TRANSITION NOTE: The UK Government extended the period during which CE marking is accepted on the GB market multiple times. As of the date of this dataset, the UK Government had announced that CE marking continues to be accepted for most consumer products (including household appliances) in the GB market until 31 December 2027 (check gov.uk for the current confirmed date as this has been extended repeatedly). After that date, UKCA will be the only accepted mark for GB market placement. Northern Ireland (NI) continues to follow the CE marking regime under the Windsor Framework. A UK Responsible Person (UKRP) — an entity established in the UK — must be appointed by the manufacturer and their name, registered trade name, or registered trademark, and postal address must appear on the product or its packaging. This replaces the EU Authorised Representative requirement. The UKCA mark itself must be affixed to the product (or, where not possible, the packaging or an accompanying document), be at least 5 mm in height, and be indelible.Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019 (SI 2019/696) — established the UKCA marking framework
Electrical Equipment (Safety) Regulations 2016 (SI 2016/1101) — amended to require UKCA for electrical safety
Electromagnetic Compatibility Regulations 2016 (SI 2016/1091) — amended to require UKCA for EMC
Energy-related Products and Energy Information (Household Refrigerating Appliances) Regulations 2021 (SI 2021/1295) — UKCA applies
UK Government UKCA guidance — https://www.gov.uk/guidance/using-the-ukca-marking (check for latest CE transition deadline)		 Three market access gaps exist for Chinese exporters: (1) UKCA mark — the product must bear the UKCA mark (or CE mark while the transition period remains open, currently extended to 31 December 2027 — verify current status at gov.uk); Chinese exporters should plan for UKCA-only compliance beyond 2027 rather than relying on the CE transition; (2) UK Responsible Person (UKRP) — a UK-established entity (company or individual) must be appointed and their details affixed to the product or packaging; Chinese manufacturers without a UK subsidiary or distributor must contract a third-party UKRP service; (3) UK Declaration of Conformity (DoC) — separate from any EU DoC, a UK DoC must be signed and held on file in the UK for 10 years. TRANSITION UNCERTAINTY: The CE acceptance deadline has been extended multiple times (originally 31 Dec 2021, then 31 Dec 2022, 31 Dec 2024, 31 Dec 2027). Future extensions are possible but not guaranteed — exporters should not design UK supply chains around CE mark acceptance beyond 2027. Northern Ireland: products sold in NI continue to require CE marking under the Windsor Framework — dual UKCA+CE marking may be required for a GB+NI unified supply.[INFORMATIONAL] UKCA marking is the mandatory GB market conformity mark, replacing CE. CE marking is currently accepted in GB until 31 December 2027 (verify current deadline at gov.uk — this deadline has been extended multiple times). A UK Responsible Person must be appointed and identified on the product or packaging. A UK Declaration of Conformity must be held on file. Northern Ireland requires CE marking. Chinese exporters should begin UKCA compliance now rather than relying on CE transition extension beyond 2027. UK Government (gov.uk)2026-06-12 · unverified

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