Bringing your Australian-certified HPWH to New Zealand: a compliance overview
Alastair McDowell
On this page
If you already manufacture or import a heat pump water heater for the Australian market, and the product is tested to AS/NZS 5125.1, holds SAA electrical certification, and carries WaterMark (WMK) and StandardsMark (SMK), you are in a strong starting position to enter the New Zealand market.
Much of the Australian evidence package can be reused in New Zealand, but it has to be mapped to New Zealand requirements. Australian certification is a strong starting point, and some New Zealand requirements sit outside it.
The four regimes
A HPWH supplied in New Zealand sits at the intersection of four separate compliance regimes.
Electrical safety is administered by Energy Safety (WorkSafe). Plumbing and building compliance sits under the New Zealand Building Code and is administered by MBIE. Energy efficiency obligations sit under the E3 programme, administered by EECA. Refrigerant and environmental obligations are administered by the EPA and Customs.
Each regime has its own evidence requirements, and your existing Australian package addresses some of them directly.
1. Electrical safety
Electrical products sold in New Zealand must be shown to meet New Zealand electrical safety requirements before they are supplied. The pathway depends on how WorkSafe classifies the product and on how the New Zealand supplier is set up.
Existing Australian electrical test evidence is usually the core of the New Zealand file. The New Zealand supplier is responsible for holding that evidence in the form WorkSafe requires.
2. Plumbing and building
Water heater installations in New Zealand are assessed against the Building Code clause for water supplies. Unlike Australia, WaterMark is not legally mandatory, although MBIE recognises WaterMark certificates that it has listed.
Product-level evidence normally draws on your existing WaterMark and plumbing certification. Material requirements for components in contact with drinking water, and installation requirements, also apply and are checked against the current Acceptable Solution.
The aim is a documented compliance package that a plumber, Licensed Building Practitioner, or building consent authority can rely on to sign off the installation.
3. Energy efficiency
Under E3, minimum energy performance requirements apply to electric storage water heaters. Whether a particular heat pump water heater falls within them depends on how much of its annual energy comes from the heat pump and how much from electric resistance heating.
That question is answered with an AS/NZS 4234 simulation, and the result determines whether E3 registration is needed. AS/NZS 5125.1 test data is the input to that simulation. The importer keeps the simulation result on file either way.
4. Refrigerant and environmental obligations
New Zealand controls HFC refrigerants and applies a synthetic greenhouse gas levy at the border on imported goods that contain them. The importer declares the refrigerant type and charge at import, and the levy should be allowed for in landed cost.
Products using natural refrigerants are treated differently from those using HFCs.
5. Assembling the package
Before first shipment, the New Zealand importer or supplier assembles a file covering each of the four areas: electrical supplier documentation, plumbing and building evidence, energy efficiency evidence, and customs and refrigerant records. A New Zealand installation manual and performance data in product literature complete the package.
The documents required depend on the product configuration, the refrigerant, and how the New Zealand supplier is set up.
How EnergyAE can help
EnergyAE offers an NZ market compliance review. We assess your product and existing certification against the four regimes and give you a single prioritised list of what is needed before first shipment.
We also provide the technical evidence for the energy efficiency regime: AS/NZS 4234 / TRNSYS simulations, and a review of your AS/NZS 5125.1 test data for consistency and for use in New Zealand product literature.
Done in the right order, the process can be completed within several weeks where the existing test and certification package is complete and no product redesign is needed.
If you would like a free 30-minute call to talk through your entry to the NZ market, get in touch.