CROSS-STANDARD public interest · Refrigerator / cold appliance
China-to-Vietnam Household 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 Chinese household refrigerator compliance (CCC, GB 4706.13, GB 12021.2) against Vietnam requirements: MOIT mandatory energy labelling and MEPS (TCVN 7828 / TCVN 7829), TCVN IEC 60335-2-24 safety, QCVN/CR-mark conformity, R-600a refrigerant, and in-country importer obligations.
Dataset 2026-06-11
Last verified 2026-06-15
7 rows
GAP MATRIX
Compliance Gap Matrix
| Compliance item | Common China baseline | Vietnam (TCVN / QCVN) | Gap / action | Source + verification date |
|---|---|---|---|---|
| Electromagnetic Compatibility — Household Appliances (TCVN CISPR 14 series) | In China, EMC for household refrigerators is governed by GB 4343.1 (emission requirements for household appliances, electric tools and similar apparatus, equivalent to CISPR 14-1) and GB 4343.2 (immunity, equivalent to CISPR 14-2). EMC testing to GB 4343.1/4343.2 is part of the China Compulsory Certification (CCC) assessment for household refrigerators. The GB 4343 series is technically aligned with the CISPR 14 series that Vietnam adopts as TCVN, but the Chinese CCC EMC test reports are issued under the Chinese scheme and are not automatically accepted as the Vietnamese conformity evidence.GB 4343.1 — Electromagnetic compatibility — Requirements for household appliances, electric tools and similar apparatus — Part 1: Emission (equivalent to CISPR 14-1) GB 4343.2 — Part 2: Immunity (equivalent to CISPR 14-2) China Compulsory Certification (CCC) — EMC testing forms part of CCC for household refrigerators |
Electromagnetic compatibility of household refrigerating appliances in Vietnam is assessed against the Vietnamese adoption of the CISPR 14 series: TCVN 7492-1 / TCVN CISPR 14-1 (emission requirements for household appliances, electric tools and similar apparatus, adopting CISPR 14-1) and TCVN 7492-2 / TCVN CISPR 14-2 (immunity requirements, adopting CISPR 14-2). A refrigerator with an electric motor-compressor is an apparatus within scope. EMC requirements are applied through the relevant national technical regulation framework and conformity assessment administered under STAMEQ (Ministry of Science and Technology); where the product is in scope of a QCVN that covers EMC, demonstrating compliance with the TCVN CISPR 14 emission and immunity limits forms part of the conformity file supporting the CR mark. Testing covers conducted and radiated disturbance (emission) and immunity to common electromagnetic phenomena.TCVN 7492-1 / TCVN CISPR 14-1 — Electromagnetic compatibility — Requirements for household appliances, electric tools and similar apparatus — Part 1: Emission (adoption of CISPR 14-1) TCVN 7492-2 / TCVN CISPR 14-2 — Part 2: Immunity (adoption of CISPR 14-2) Law No. 68/2006/QH11 on Standards and Technical Regulations (conformity-assessment framework administered by STAMEQ/MOST) |
The GB 4343 series and the TCVN CISPR 14 series share the same CISPR 14 base, so the underlying limits and methods are largely equivalent. The gap is procedural rather than technical: (1) Chinese CCC EMC test reports are not automatically accepted in Vietnam — EMC evidence must be presented to the STAMEQ-designated body within the Vietnamese conformity file. (2) The certification body decides whether existing GB 4343.1/4343.2 reports (or IEC/CISPR reports under a recognised scheme such as IECEE CB) can be leveraged or whether re-testing at a recognised laboratory is needed. (3) Documentation, model coverage, and the rated-voltage test condition (220 V, 50 Hz) must match the Vietnamese registration. Exporters should confirm with the chosen Vietnamese conformity body whether their CISPR 14-based reports are accepted before assuming no re-testing.[INFORMATIONAL] EMC compliance to the TCVN CISPR 14 series is technically close to China's GB 4343 series (shared CISPR 14 base), but Chinese CCC EMC reports are not automatically accepted in Vietnam. Exporters should confirm with the STAMEQ-designated body whether existing CISPR 14-based reports can be leveraged or whether re-testing at a recognised laboratory is required for the CR conformity file. | STAMEQ — Directorate for Standards, Metrology and Quality (Ministry of Science and Technology, Vietnam)2026-06-15 · reference |
| Minimum Energy Performance Standards (MEPS) — Household Refrigerators (TCVN 7828) | China's mandatory energy efficiency standard for household refrigerators is GB 12021.2-2015 (Minimum allowable values of energy efficiency and energy efficiency grades for household refrigerators). It establishes energy efficiency grades (Grade 1 most efficient, Grade 5 minimum threshold) and minimum annual energy consumption limits, enforced by SAMR under the China Energy Label system administered by the NDRC. Products must display the China Energy Label before sale. GB 12021.2 uses a different test methodology and grade basis than TCVN 7828/7829 — a Chinese energy grade does not map directly to the Vietnamese MEPS threshold or star rating without recalculation against the Vietnamese reference basis.GB 12021.2-2015 — Minimum allowable values of energy efficiency and energy efficiency grades for household refrigerators (mandatory; enforced by SAMR/NDRC under China Energy Label system) GB/T 8059-2016 — Household and similar refrigerating appliances (test method standard, aligned with IEC 62552 series) |
Vietnam operates a mandatory Minimum Energy Performance Standard (MEPS) regime for household refrigerating appliances under the Ministry of Industry and Trade (MOIT), implementing the Law on Economical and Efficient Use of Energy (Law No. 50/2010/QH12) and Decision No. 04/2017/QD-TTg (and successor roadmap decisions) which lists refrigerators among products subject to mandatory minimum energy efficiency. The technical basis is TCVN 7828 (energy efficiency requirements for household refrigerating appliances), with energy consumption measured per TCVN 7829. A refrigerator that does not meet the minimum energy efficiency level set in TCVN 7828 may not be imported or sold in Vietnam. The MEPS level and the star-rating energy efficiency classification are determined from tested annual energy consumption against the standard volume and climate-class basis defined in TCVN 7828. Energy testing must be performed by a MOIT-recognised testing laboratory and the results form the basis for the energy label.TCVN 7828 — Household refrigerating appliances — Energy efficiency requirements (technical basis for MEPS and energy classification) Law No. 50/2010/QH12 — Law on Economical and Efficient Use of Energy Decision No. 04/2017/QD-TTg — List of products and equipment subject to minimum energy efficiency and roadmap for application (MOIT/Prime Minister) |
Three gaps: (1) Different test and threshold basis — TCVN 7828/7829 set the Vietnamese MEPS and star rating; a Chinese Grade 1 or Grade 2 rating under GB 12021.2 does NOT guarantee the unit clears the Vietnamese MEPS floor, and annual energy consumption must be re-evaluated against the Vietnamese reference. (2) Local testing — energy data must come from a MOIT-recognised laboratory in Vietnam or one whose results MOIT accepts; Chinese GB test reports are generally not accepted as-is. (3) MEPS is a hard import gate — a model below the TCVN 7828 minimum cannot be imported or sold, regardless of its China Energy Label grade. Exporters should plan energy re-testing and confirm the current MEPS floor before shipment.[INFORMATIONAL] Meeting Vietnam's MEPS under TCVN 7828/7829 is a legal precondition for importing or selling household refrigerators. Chinese GB 12021.2 grades do not substitute for the Vietnamese MEPS threshold — annual energy consumption should be re-tested at a MOIT-recognised laboratory and assessed against the current TCVN 7828 floor before shipment. | Ministry of Industry and Trade of Vietnam (MOIT)2026-06-15 · reference |
| Mandatory Energy Labelling — Vietnam Energy Efficiency Label (MOIT) | China's energy labelling for household refrigerators is the China Energy Label (CEL) system under the Measures for the Administration of Energy Efficiency Labels (NDRC/SAMR, 2016 revision). The label shows a 1-to-5 grade scale (1 highest) and annual energy consumption and is administered by CNIS under NDRC/SAMR. Manufacturers self-declare the grade based on testing against GB 12021.2. The Chinese self-declared grade label is structurally different from the Vietnamese MOIT star-rating label and the MOIT registration-and-acknowledgement workflow, and is not interchangeable with it.Measures for the Administration of Energy Efficiency Labels (NDRC/SAMR 2016 revision) — China Energy Label framework GB 12021.2-2015 — Minimum allowable values of energy efficiency and energy efficiency grades for household refrigerators (underlying grade standard) |
Under the Law on Economical and Efficient Use of Energy (Law No. 50/2010/QH12) and MOIT implementing circulars (notably Circular No. 36/2016/TT-BCT on energy labelling and its successors), household refrigerators must carry the Vietnam Energy Efficiency Label before being sold. There are two label types: the comparative label (star rating, typically 1 to 5 stars, derived from energy efficiency measured per TCVN 7828/7829) and the confirmation label where applicable. The supplier or importer must register the energy label with MOIT, submit a test report from a recognised laboratory, and obtain MOIT acknowledgement before affixing the label and placing the product on the market. The label shows the star rating, annual electricity consumption (kWh/year), model identification, and a registration reference. Online and in-store listings must reflect the registered efficiency information.Circular No. 36/2016/TT-BCT (MOIT) — Regulations on energy labelling for energy-using means and equipment (and successor circulars) Law No. 50/2010/QH12 — Law on Economical and Efficient Use of Energy TCVN 7828 / TCVN 7829 — energy efficiency requirements and test method underpinning the refrigerator energy label |
Two mandatory actions with no direct Chinese equivalent: (1) MOIT energy-label registration — the importer or supplier must file a test report from a recognised laboratory and register the energy label with MOIT, then obtain acknowledgement before the label is used and the product sold; this is a workflow the Chinese self-declared CEL does not satisfy. (2) Vietnamese star-rating label — the physical comparative label (1 to 5 stars, kWh/year, model, registration reference) must appear on the product and in listings; the Chinese 1-to-5 grade CEL cannot serve as the Vietnamese label and must be replaced. MOIT and market surveillance check that products on sale carry a valid registered label, so a missing or unregistered label blocks lawful sale.[INFORMATIONAL] MOIT energy-label registration and display of the Vietnam Energy Efficiency Label are mandatory hard gates for selling household refrigerators in Vietnam. Chinese exporters must obtain a recognised-laboratory test report, register the label with MOIT, and affix the Vietnamese star-rating label; the China Energy Label does not satisfy Vietnamese labelling obligations. | Ministry of Industry and Trade of Vietnam (MOIT)2026-06-15 · reference |
| Conformity Declaration and CR Mark — In-Country Importer and Registration (chung nhan hop quy) | In China, market access for household refrigerators is via China Compulsory Certification (CCC / 3C): a CCC certificate issued by a designated certification body (such as CQC) based on GB 4706.1, GB 4706.13, GB 4343.1/4343.2 and GB 12021.2 testing plus factory inspection, after which the 3C mark is applied. The Chinese manufacturer or its domestic agent holds the certificate. CCC is a self-contained Chinese national scheme; it does not provide for a Vietnamese importer-of-record, nor is the 3C mark or CCC certificate recognised as the Vietnamese CR conformity. The two systems are parallel national conformity regimes with different bodies, marks and document sets.China Compulsory Certification (CCC / 3C) — mandatory scheme for household refrigerators, certificate issued by a designated body (e.g. CQC) CNCA/CCC implementation rules for household and similar electrical appliances |
Vietnam's market-access model for regulated electrical products rests on national technical regulations (QCVN, mandatory) supported by TCVN standards (voluntary), with conformity proven through the CR mark (chung nhan hop quy). For products within an applicable QCVN, a Vietnam-based legal entity (the importer or an authorised in-country representative) must hold the conformity-assessment certificate issued by a STAMEQ-designated certification body, lodge the declaration of conformity with the competent provincial authority, and ensure the CR mark and Vietnamese-language labelling are applied before customs clearance and sale. There is no foreign-manufacturer self-declaration route that bypasses the in-country entity. The importer is responsible for keeping the technical file (test reports, certificate, label artwork) and for goods-labelling under Decree No. 43/2017/ND-CP (origin, importer name and address, technical specifications in Vietnamese). Customs clearance through ports such as Cat Lai / Ho Chi Minh and Hai Phong requires the conformity and labelling documentation to be in order.Law No. 68/2006/QH11 on Standards and Technical Regulations + Law No. 05/2007/QH12 on Product and Goods Quality (QCVN/TCVN and CR-mark conformity framework) Circular No. 28/2012/TT-BKHCN (and amendments) — declaration of standard conformity and declaration of technical-regulation conformity (CR mark procedures) Decree No. 43/2017/ND-CP — Labelling of goods (Vietnamese-language label, importer details, origin) |
Three market-access gaps: (1) In-country entity — Vietnam requires a Vietnam-based importer or authorised representative to hold the conformity certificate and lodge the declaration of conformity; there is no foreign self-declaration route, unlike a manufacturer simply holding a CCC certificate. (2) Separate CR conformity — a CCC certificate / 3C mark is not accepted; the product needs CR-mark conformity from a STAMEQ-designated body, with the Vietnamese declaration of conformity filed with the provincial authority. (3) Vietnamese labelling — Decree 43/2017/ND-CP requires a Vietnamese-language label with importer name and address, origin and technical specifications; the Chinese label/3C mark does not satisfy this. Exporters must appoint or work through a Vietnamese importer, complete CR conformity, and prepare compliant Vietnamese labelling before goods clear customs at Cat Lai / Ho Chi Minh or Hai Phong.[INFORMATIONAL] Vietnam market access for refrigerators requires a Vietnam-based importer/representative, CR-mark conformity from a STAMEQ-designated body with a filed declaration of conformity, and Vietnamese-language labelling under Decree 43/2017/ND-CP. A Chinese CCC/3C certificate is not recognised. Exporters should line up a Vietnamese importer and the CR conformity workflow before shipment. | STAMEQ — Directorate for Standards, Metrology and Quality (Ministry of Science and Technology, Vietnam)2026-06-15 · reference |
| Pre-Import Energy-Label Registration and Customs Clearance Gate (MOIT registration before sale) | In China, before sale a household refrigerator needs its CCC certificate (safety/EMC) and the China Energy Label (energy) based on GB 12021.2, with the manufacturer self-declaring the energy grade and registering/filing under the NDRC/SAMR energy-label system. There is no foreign-importer-of-record concept and no Vietnam-style pre-import registration gate tied to a local importer; the Chinese energy-label filing and CCC are domestic processes completed by the manufacturer or its agent. Neither the China Energy Label filing nor CCC substitutes for the Vietnamese MOIT energy-label registration or the importer-held conformity records.China Energy Label system (NDRC/SAMR) — energy-grade filing based on GB 12021.2-2015 China Compulsory Certification (CCC / 3C) — safety/EMC certificate held by the manufacturer or its domestic agent |
Before household refrigerators can be lawfully sold in Vietnam, the importer must complete MOIT energy-label registration: obtain an energy-efficiency test report from a recognised/designated testing laboratory, register the energy label with MOIT, and receive MOIT acknowledgement, after which the Vietnam Energy Efficiency Label (star rating) is affixed. This energy-labelling step operates alongside the CR-mark electrical-safety conformity and the Vietnamese goods-labelling requirement. In practice this creates a documentary gate at and after customs: the importer should have the energy test report and label registration plus the safety conformity certificate ready, so that products cleared through Cat Lai / Ho Chi Minh or Hai Phong can be placed on the market with valid label and conformity records. Market surveillance under MOIT and STAMEQ checks that on-sale refrigerators carry both a registered energy label and the required conformity mark and Vietnamese labelling.MOIT Circular No. 36/2016/TT-BCT (and successors) — energy-label registration procedure (test report, registration, acknowledgement) Law No. 50/2010/QH12 — Law on Economical and Efficient Use of Energy (mandatory energy labelling/MEPS for refrigerators) Decree No. 43/2017/ND-CP — Labelling of goods (Vietnamese-language label at import) |
The gap is a Vietnam-specific pre-sale registration sequence that the Chinese domestic processes do not cover: (1) Energy test at a Vietnam-recognised laboratory plus MOIT label registration and acknowledgement must be completed before the refrigerator is placed on the market — the China Energy Label self-declaration is not accepted. (2) The importer of record must hold the energy-label registration, the CR-mark safety conformity, and the Vietnamese-language labelling artwork as a single coherent file presented at/after customs. (3) Timing risk — because energy registration and CR conformity each require Vietnamese testing/assessment, exporters should start the process well before shipment to avoid goods sitting at Cat Lai / Ho Chi Minh or Hai Phong without a registered label or valid conformity, which would block lawful market placement.[INFORMATIONAL] Vietnam imposes a pre-sale energy-label registration sequence (recognised-lab test, MOIT registration and acknowledgement) that the Chinese self-declared energy label does not satisfy. The importer of record should assemble the energy-label registration, the CR-mark conformity, and the Vietnamese labelling as one file and start early so goods are not held at Cat Lai / Ho Chi Minh or Hai Phong without valid registration. | Ministry of Industry and Trade of Vietnam (MOIT)2026-06-15 · reference |
| Refrigerant — R-600a Flammable Refrigerant Charge and Phase-Down of HCFC/HFC (Montreal Protocol / Kigali Amendment) | China is also a party to the Montreal Protocol and Kigali Amendment and phases down HCFCs/HFCs under the Regulation on the Administration of Ozone-Depleting Substances and related MEE programmes. For household refrigerators, R-600a (isobutane) is the dominant low-GWP refrigerant and is already standard in most Chinese export models. The flammable-refrigerant safety requirements in China derive from GB 4706.13 (equivalent to IEC 60335-2-24) including the Annex provisions for flammable refrigerants, so Chinese factory practice for R-600a charge, marking and construction is generally based on the same IEC 60335-2-24 technical basis Vietnam adopts.Regulation on the Administration of Ozone-Depleting Substances (China; Montreal Protocol / Kigali Amendment implementation, administered by MEE) GB 4706.13 — Particular requirements for refrigerating appliances (flammable-refrigerant safety provisions, equivalent to IEC 60335-2-24) |
Vietnam is a party to the Montreal Protocol and has ratified the Kigali Amendment, committing to phase down hydrofluorocarbons (HFCs); ozone-depleting substances and controlled refrigerants are regulated under the Law on Environmental Protection (Law No. 72/2020/QH14) and Decree No. 06/2022/ND-CP on greenhouse-gas emission reduction and ozone-layer protection, administered by the Ministry of Natural Resources and Environment (MONRE / now under MARD-MONRE reorganisation). R-600a (isobutane), a hydrocarbon with very low GWP, is widely accepted in Vietnam for domestic refrigerators and aligns with the phase-down direction. Because R-600a is flammable, the refrigerant charge limit, marking, and construction requirements of TCVN IEC 60335-2-24 (Annex on flammable refrigerants) must be met, and the safety and refrigerant information must appear on the rating plate and in the documentation. Servicing and import of bulk controlled refrigerants are subject to MONRE quota/licensing, but factory-charged R-600a in a finished sealed appliance is generally treated as part of the product.Decree No. 06/2022/ND-CP — Greenhouse-gas emission reduction and protection of the ozone layer (HFC/HCFC controlled-substance management; Montreal Protocol / Kigali Amendment implementation) Law No. 72/2020/QH14 — Law on Environmental Protection TCVN IEC 60335-2-24 — flammable-refrigerant charge limit, marking and construction provisions (Annex for R-600a class) |
R-600a is a strength rather than a barrier for China-to-Vietnam refrigerator export, because both markets accept it and both base flammable-refrigerant safety on IEC 60335-2-24. Remaining points to verify: (1) the R-600a charge, marking and construction must be demonstrated in the Vietnamese CR conformity file against TCVN IEC 60335-2-24, not merely assumed from the GB 4706.13 file; (2) Vietnamese-language safety markings and refrigerant/charge information on the rating plate and manual; (3) confirm that any bulk-refrigerant import for servicing (if relevant to the business model) is handled within MONRE controlled-substance licensing under Decree 06/2022/ND-CP — factory-sealed appliance charge is normally fine. There is no need to convert away from R-600a for the Vietnamese market.[INFORMATIONAL] R-600a is accepted in Vietnam and aligns with the Montreal Protocol/Kigali phase-down, so it is an advantage for Chinese exporters rather than a barrier. The action is to document the R-600a charge, marking and construction in the Vietnamese CR file per TCVN IEC 60335-2-24 (with Vietnamese-language safety markings) and to handle any bulk refrigerant import within MONRE licensing under Decree 06/2022/ND-CP. | Ministry of Natural Resources and Environment of Vietnam (MONRE)2026-06-15 · reference |
| Electrical Safety — Household Refrigerating Appliances (TCVN IEC 60335-2-24) + CR Conformity Mark | In China, electrical safety of household refrigerators is governed by GB 4706.1 (general requirements, equivalent to IEC 60335-1) and GB 4706.13 (particular requirements for refrigerating appliances, equivalent to IEC 60335-2-24). Household refrigerators are within the scope of China Compulsory Certification (CCC / 3C), so a CCC certificate based on GB 4706.1 and GB 4706.13 testing and factory inspection is required before sale in China. While the GB 4706 series is technically aligned with the IEC 60335 series that Vietnam adopts as TCVN, the CCC certificate and the Vietnamese CR mark are separate national conformity schemes issued by different designated bodies and are not mutually recognised.GB 4706.1 — Household and similar electrical appliances — Safety — General requirements (equivalent to IEC 60335-1) GB 4706.13 — Particular requirements for refrigerating appliances (equivalent to IEC 60335-2-24) China Compulsory Certification (CCC / 3C) — mandatory for household refrigerators sold in China |
Electrical safety of household refrigerating appliances in Vietnam is assessed against the Vietnamese adoption of the IEC 60335 series: TCVN 5699-1 (general requirements for household and similar electrical appliances, adopting IEC 60335-1) together with TCVN IEC 60335-2-24 (particular requirements for refrigerating appliances, ice-cream appliances and ice-makers, adopting IEC 60335-2-24). Low-voltage electrical and electronic products in scope of the relevant national technical regulation (QCVN) must undergo conformity assessment and bear the CR mark (chung nhan hop quy / certificate of conformity) before being placed on the Vietnamese market. Conformity assessment is carried out by a certification or testing body designated by STAMEQ (Directorate for Standards, Metrology and Quality) under the Ministry of Science and Technology. Testing covers protection against electric shock, mechanical and thermal hazards, abnormal operation, and the flammable-refrigerant provisions where R-600a is used.TCVN IEC 60335-2-24 — Household and similar electrical appliances — Safety — Particular requirements for refrigerating appliances (adoption of IEC 60335-2-24) TCVN 5699-1 — Household and similar electrical appliances — Safety — General requirements (adoption of IEC 60335-1) Law No. 68/2006/QH11 on Standards and Technical Regulations + Law No. 05/2007/QH12 on Product and Goods Quality (CR-mark conformity-assessment framework, administered by STAMEQ/MOST) |
Although GB 4706.13 and TCVN IEC 60335-2-24 share the same IEC 60335-2-24 base, three gaps remain: (1) Separate conformity scheme — a Chinese CCC certificate is not accepted in Vietnam; the product must be assessed by a STAMEQ-designated body and carry the CR mark. (2) National differences (national deviations and the Vietnamese-language documentation, voltage 220 V single-phase 50 Hz, plug/cord and rating-plate requirements) must be verified against the TCVN adoption rather than assumed identical to the GB version. (3) Flammable-refrigerant clauses — because most Chinese export refrigerators use R-600a, the Annex/flammability provisions of TCVN IEC 60335-2-24 (charge limit, marking, construction) must be demonstrated in the Vietnamese conformity file. Existing GB 4706.13 test reports can shorten testing if the certification body accepts them as supporting evidence, but a fresh CR conformity assessment is generally required.[INFORMATIONAL] Electrical-safety conformity to TCVN IEC 60335-2-24 with the CR mark is a Vietnamese national requirement separate from China CCC. The shared IEC 60335-2-24 base helps, but a Chinese CCC/GB 4706.13 certificate is not recognised — a STAMEQ-designated body must perform the CR conformity assessment, verifying national deviations and the R-600a flammability provisions before market placement. | STAMEQ — Directorate for Standards, Metrology and Quality (Ministry of Science and Technology, Vietnam)2026-06-15 · reference |
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SOURCES
Official-source register.
- STAMEQ — Directorate for Standards, Metrology and Quality (Ministry of Science and Technology, Vietnam) · accessed 2026-06-15 · reference · used in 3 rows
- Ministry of Industry and Trade of Vietnam (MOIT) · accessed 2026-06-15 · reference · used in 3 rows
- Ministry of Natural Resources and Environment of Vietnam (MONRE) · accessed 2026-06-15 · reference · used in 1 rows