What it takes to place an air conditioner on the EU market.
Most of the friction in this trade is not price. It is whether a model can legally be placed on the EU market, whether the paperwork survives contact with a customs officer or a market surveillance authority, and whether the refrigerant can be shipped on the sailing you planned. This is what applies to this category, and what we do about it.
Energy labelling: the right scale for the right product
Portable air conditioners — single-duct and dual-duct units — are covered by Commission Delegated Regulation (EU) No 626/2011, and they still carry the older A+++ – D label scale. They are rated on steady-state values: EER for cooling and COP for heating.
Fixed split systems fall under the same regulation but are rated on seasonal values instead — SEER and SCOP. That is why a split unit's class and a portable unit's class are not comparable even when both read “A+”: the underlying measurement is different, and a buyer who lines them up in the same spreadsheet column will draw the wrong conclusion.
The A–G rescaling introduced across other product groups in 2021 has not been applied to air conditioners. If a supplier sends you A–G label artwork for a portable unit, the label is wrong — and at the border a wrong label is the importer's problem, not the factory's.
What we do. We coordinate with our manufacturing partners to confirm that the class quoted for a model is derived from the correct metric for its product type, and that the declared EER, COP, SEER or SCOP figure traces back to a test report rather than a marketing sheet.
EPREL registration before the goods are placed on the market
Every model that carries an energy label must be registered in the European Product Registry for Energy Labelling (EPREL) before it is placed on the EU market. The registration carries the label and the product information sheet, and it is the first thing a market surveillance authority checks.
Two changes have made this materially harder for non-EU suppliers. Since 22 October 2024, supplier verification is a mandatory precondition: an unverified account can no longer register a new model or modify an existing registration. Since 22 April 2025, verification by legal-entity electronic seal requires the NTR (national trade register) identity type, which an entity registered outside the EU cannot satisfy on its own.
In practice a non-EU manufacturer registers through an authorised representative established in the Union, or the responsibility sits with you as the importer. Either way it has to be settled before shipment. A container arriving at Rotterdam without a valid EPREL entry is an expensive way to discover who was supposed to do it.
What we do. We coordinate with our manufacturing partners on the EPREL route for each model, and where you act as importer of record we supply the label data and product information sheet in the format the registry expects, so the entry is complete before the shipment is booked.
Refrigerants: R290 changes the shipment, not just the datasheet
R290 (propane) has a GWP of approximately 3. R32 is 675. R410A is above 2,000. The direction of European procurement is not ambiguous, and most EU buyers now specify R290 for portable units by default.
R290 is a flammable refrigerant, and that changes the shipping process rather than just the specification. Sea freight has to be booked as dangerous goods, the safety data sheet has to reach the carrier with the booking, and the carrier's acceptance conditions — including charge limits per unit and per container — have to be confirmed before space is fixed.
This is a scheduling question as much as a compliance one. Dangerous-goods bookings close earlier than general cargo and space is tighter in peak season, so the refrigerant you choose affects the date you can promise your own customers.
R290
≈ 3
GWP
R32
675
GWP
R410A
> 2,000
GWP
What we do. We coordinate with our manufacturing partners to obtain the safety data sheet and the declared refrigerant charge for each model, and we confirm dangerous-goods acceptance and charge limits with the carrier before we give you a shipment date.
The document pack that travels with the goods
Each shipment goes out with a document set that should let you clear customs and answer a market surveillance request without coming back to us:
- 01EU Declaration of Conformity
Names the model and the directives it is issued against
- 02RoHS documentation
Substance restriction evidence for the model
- 03EU energy label
Artwork on the correct scale for the product type
- 04Product information sheet
The data set that must match the EPREL entry
- 05User manual
In the languages of the destination markets
- 06Technical specification sheet
The signed sheet the goods are inspected against
For this category the applicable directives are typically the Low Voltage Directive, EMC and RoHS, with the exact conformity route depending on how the unit is built. We ask the factory to state which directives and harmonised standards its declaration is based on, rather than accepting a generic certificate with a logo on it.
- Commercial invoice
- Packing list
- Bill of lading
- Certificate of origin
- Safety data sheet (R290)
- Dangerous goods declaration (R290)
What we do. We coordinate with our manufacturing partners to assemble the pack per model and per order, and we send you the draft documents for review before mass production rather than after loading.
Logistics: loading quantity is a commercial specification
We ship full container loads by sea. Portable air conditioners cube out long before they weigh out, so loading quantity is a commercial specification in its own right — every product page lists units per 20ft, 40ft, 40HQ — because that number moves your landed cost per unit more than the unit price does.
Indicative timing is 30 to 45 days from confirmed order and deposit to loading, plus roughly 30 to 40 days port to port to the main North European base ports. Both figures move with season and routing, and we confirm them per order instead of quoting them as a promise.
LCL is possible for a trial order but is rarely economic for this product, and it complicates handling where the units are charged with R290.
What we do. We quote loading quantities per model with the price, and we confirm the sailing schedule and dangerous-goods acceptance before you place the order rather than after.
Have a specification you want checked?
Send it over. If a model cannot be placed on the EU market as specified, we would rather tell you at enquiry stage than after you have committed to a price with your own customer. We reply within three business days.