What it takes to place an air conditioner on the EU market.

This is the part of the work that is invisible in a price list, and it is the reason a trading company can be worth more to you than the production site it buys from.

1. 01Refrigerant and GWP, fixed in the contractR290 has a GWP of 3, and a movable air conditioner charged with a refrigerant of GWP 150 or more has not been placeable on the EU market since 2020. Where a platform is built in both R290 and R410A for different markets, the technical annex to the contract fixes R290 model by model, so that nothing ambiguous reaches a production line.
2. 02Sound power, not sound pressureChinese catalogues almost always quote sound pressure. EPREL and the energy label require A-weighted sound power to EN 12102-1. The two differ by roughly 10 to 12 dB, and the difference is not a matter of opinion. On our product pages the two are listed separately and labelled.
3. 03Rated input power against the certificate nameplateAn energy class is arithmetic on rated cooling capacity and rated input power. If the input power printed in a catalogue does not match the nameplate rating in the safety test report, the class behind it does not hold. We compare the two before the figure is repeated to you.
4. 04Model code consistencyThe code on the offer and the code on the certificate have to resolve to the same product. Where they differ, we obtain written confirmation from the production site before quoting. It is a routine failure point, and enough on its own to stall a registration.
5. 05Certificate scope, holder and validityA certificate that covers a sister model is not a certificate that covers yours. We read the model table, the issue date and the expiry date, and we check that the holder is the entity that will actually build your order.
6. 06The documents that travel with the goodsA voluntary CE attestation from a test house is not an EU Declaration of Conformity — most attestations say so on their face. The Declaration is signed by the manufacturer, and under EU law it is the importer who must be able to produce it. We establish who signs what before the deposit is paid.

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.

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.

A portable air conditioner falls under the Low Voltage, EMC, RoHS and ecodesign rules. Under Article 4 of the Market Surveillance Regulation (EU) 2019/1020, applying since 16 July 2021, such a product may be placed on the EU market only if an economic operator established in the Union is responsible for it, and that operator's name and contact details appear on the product, its packaging, the parcel or an accompanying document. The General Product Safety Regulation (EU) 2023/988, applying since 13 December 2024, extends the same requirement to consumer products generally.

For most of our buyers that operator is the importer — you. As importer you also put your own name, registered trade name or mark and postal address on the unit or, where that is not possible, on its packaging. In practice that is a fixed field on the rating label and on the carton, sized and positioned before artwork is approved, next to the traceability the rules ask for: model identifier, batch or serial number, and the manufacturer's name and address.

A trading company registered in China cannot carry this role for you, and we will not tell you otherwise. If an authorised representative of the manufacturer is to carry it instead, that is arranged before the order.

R290 (propane) has a GWP of approximately 3. R32 is 675. R410A is above 2,000. For portable units the law has already made the choice: since 1 January 2020 a movable room air conditioner charged with a refrigerant of GWP 150 or more may not be placed on the EU market, which rules out R32 and R410A.

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.

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.

Regulation (EU) 2024/3015 applies from 14 December 2027 and prohibits placing on the EU market, making available on it, or exporting from it any product made with forced labour at any stage of production. The prohibition attaches to the product rather than to the company, and there is no de minimis threshold — a container of portable air conditioners is in scope exactly as anything else is.

What is assessed is wider than overt coercion. Working weeks sustained beyond the statutory limit, overtime that is not genuinely voluntary, hours worked but not paid at the statutory premium, social insurance not enrolled or not paid, and terms that impede a worker from resigning are all treated as indicators. A signed consent to voluntary overtime does not neutralise a sustained pattern of excessive hours; the pattern is what gets read.

The assessment follows the chain rather than stopping at the assembling plant. Compressors, sheet metal, motors, packaging — a supplier two or three tiers back can hold a shipment that is otherwise entirely in order.

The evidential burden sits with the operator placing the goods on the EU market — the importer. Once an authority has a substantiated concern it is for that company to produce attendance records, payroll, overtime authorisations, social insurance receipts and employment contracts. An incomplete file is not neutral — it is read as a failure to rebut. A decision taken in one member state is enforced across all of them, and goods can be withheld, withdrawn from the market or disposed of.

Alongside the prohibition, the Corporate Sustainability Due Diligence Directive obliges large EU companies to run human-rights and labour due diligence across their own chains. Its thresholds and timetable have been amended since adoption and are still moving, so the figure that decides your position is not the directive's scope — it is the clause your customer writes into the purchase contract. That is why importers now ask for an amfori BSCI or SEDEX/SMETA report at the enquiry stage rather than at the audit stage.

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 gives an approximate figure per 40HQ, and your quotation carries the exact loading for 20ft, 40ft and 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.