Bringing your Australian-certified HPWH to New Zealand: a compliance roadmap

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 must be mapped carefully to NZ electrical safety, Building Code, E3, and refrigerant obligations. Australian certification is a strong starting point, not a complete NZ approval.

There are four separate regulatory regimes you need to walk through, plus a few specifically New Zealand requirements that can catch suppliers out if they are not planned for.

The four regimes you need to satisfy

A HPWH supplied in New Zealand sits at the intersection of four separate compliance regimes.

Electrical safety sits under the Electricity (Safety) Regulations 2010 and is administered by Energy Safety (WorkSafe). Plumbing and building compliance sits under the New Zealand Building Code, especially Acceptable Solution G12/AS1 Water Supplies, administered by MBIE.

Energy efficiency obligations sit under the Energy Efficiency (Energy Using Products) Regulations 2002 and the E3 programme, administered by EECA. Refrigerant and environmental obligations sit under the Ozone Layer Protection Act 1996 and the synthetic greenhouse gas levy, administered by EPA and Customs.

You cannot skip any of these. The good news is that your existing Australian evidence package addresses most, but not all, of what is needed.

1. Electrical safety: the SDoC pathway

Many domestic integrated HPWHs fall within WorkSafe’s declared medium-risk “water heater” category, particularly unvented storage units incorporating an electric element and with storage volume between 4.5 L and 680 L. Larger commercial or split configurations should be classified against the declared-article definitions rather than assumed to fit automatically.

Before the product is sold in New Zealand, the New Zealand importer or manufacturer must have a valid Supplier Declaration of Conformity (SDoC) in place. The SDoC must be supported by a test report demonstrating compliance with the relevant standard listed in Schedule 4 of the Regulations, which for HPWHs is AS/NZS 60335.2.40 in conjunction with AS/NZS 60335.1.

The SDoC must be issued in the ISO/IEC 17050-1 format and must reference the New Zealand importer, including NZBN, address, and contact details. A copy of the SDoC and its supporting test report must be produced within 10 days of a request from Energy Safety, and the SDoC must also be available to a purchaser or consumer.

Your existing electrical certification will usually be the core test evidence for the NZ SDoC, provided it covers the exact product configuration being supplied into New Zealand and the applicable NZ variations. In many cases no retesting is needed, but the NZ importer must still hold a compliant SDoC file.

You will need to issue a New Zealand-specific SDoC under your importer entity, not the Australian entity. The importer also needs to hold the SAA test report as supporting evidence and keep the documentation accessible for the 10-day disclosure rule.

The second route is a Level 3 EESS registration that names the NZ supplier and explicitly confirms the product is compliant for use in New Zealand. WorkSafe treats it as deemed approval for a medium-risk article (regulation 83A of the Electricity (Safety) Regulations 2010). That route has conditions: the test report must be no more than 5 years old at certification, the product must be marked 230 V or a range that includes 230 V, and it must carry the certifier’s unique certification marking, because the RCM is not recognised for that purpose in New Zealand.

The NZ supplier on that route must be a New Zealand registered company with at least one director permanently and physically resident in New Zealand. On either route, do not assume an Australian certificate alone is sufficient; the NZ supplier still needs a compliant NZ supply file and must ensure the product details match the certificate and test report.

2. Plumbing and building: G12 compliance

New Zealand’s plumbing rules sit under the Building Code, with Acceptable Solution G12/AS1 as the primary deemed-to-comply pathway. Unlike Australia, WaterMark is not legally mandatory in New Zealand, but MBIE now recognises listed WaterMark certificates.

MBIE’s Building (Product Recognition WaterMark Water Heaters and Hot-Water Storage Tanks) Notice 2026 (RN-10034) has been in force since 9 February 2026. It recognises the AS 3498:2020 certificates listed in its Schedule 1, and states that the listed products comply with the relevant Building Code clauses when used within the conditions of the certificate.

Recognition is by certificate number, so check that your WaterMark (WMK) certificate is on the list, is still in date, and covers the model you are shipping. The notice recognises plumbing components only. It does not cover the refrigeration side, and it lists no separate heat pump category. Copper alloy parts still need a lead-free test certificate lodged with the building consent application. If your certificate is not listed, the product can still be supported through an alternative solution, which each building consent authority then assesses case by case.

Your WaterMark and AS/NZS 2712 certification are the product-level plumbing evidence. G12/AS1 lists no heat pump water heater standard in its water heater table, and it reaches AS/NZS 2712 through G12/AS2 for solar water heaters. To finalise the New Zealand picture you also need to address installation requirements, drinking-water material requirements, and installation-side Building Code outcomes.

The HPWH must be installable to AS/NZS 3500.4 (Heated water services), which is cited by G12/AS1. This is an installation requirement rather than a product test, but your installation manual should reference it explicitly for the New Zealand market.

From 2 May 2026, G12/AS1 Amendment 14 is the only MBIE Acceptable Solution for Clause G12. Any product containing copper alloy in contact with drinking water must be lead free (no more than 0.25% lead), and the Amendment names water heaters among its examples. The evidence is a test report to NSF/ANSI/CAN 372:2020 from a laboratory with IANZ or equivalent accreditation. Copper alloy components that are in contact with water and under hydrostatic pressure must also be dezincification resistant, to AS 2345:2006.

G12/AS1 also requires every wetted material to comply with AS/NZS 4020, and accepts BS 6920 for non-metallic materials. This evidence is often already within a WaterMark certification, but confirm that the certificate scope covers gaskets, liners, tempering valve seats, and any other wetted material.

G12/AS1 also creates installation-side requirements that the product needs to support. The installation package should allow for Legionella control, tempering to 50 C delivery at personal-hygiene fixtures, and adequate seismic restraint.

You do not need a separate “NZ approval” stamp on the cylinder. What you need is a documented compliance package that a Licensed Building Practitioner, plumber, or building consent authority can rely on to sign off the installation under G12.

3. Energy efficiency: the E3 / EECA question

Under the New Zealand E3 programme, MEPS applies to electric storage water heaters (hot water cylinders with capacity up to 710 L). The E3 category explicitly includes the storage component of heat pump systems. The standard is AS/NZS 4692.2:2005, and the MEPS level is a maximum standing heat loss (Table A5). Importers and manufacturers of products that MEPS covers must register them with E3 before sale.

There is a critical exclusion. A water heater is excluded from MEPS under AS/NZS 4692.2 when it uses electric-resistive heating to provide less than 50% of the energy supplied in a typical year, when simulated to AS/NZS 4234 under Climate Zone 3 with a daily energy delivery of 22.5 MJ/day, using the boost element and energization profile that the manufacturer specifies.

For a properly designed HPWH this exclusion almost always applies; the heat pump should carry well over 50% of the annual load. The exclusion is not automatic, so you need an AS/NZS 4234 simulation report showing the element contribution is less than 50%.

If this information is not shown directly in the report, provide the TRNSYS .dck files showing that element boost input is minimal or zero. You can also provide supporting reasoning where the product’s energy savings are high enough to demonstrate that electric-resistive contribution must be below 50%.

If the product has been accepted for Australian STCs, there is likely to be AS/NZS 4234 simulation evidence available for the relevant model family. This is EnergyAE core expertise, so let us know if you need help on this point.

In practice there are three possible outcomes.

The most common outcome is that the HPWH passes the AS/NZS 4234 exclusion and no NZ MEPS registration is required. The importer should document the simulation result and keep it on file.

A less common outcome is that the HPWH fails the exclusion, for example because a small tank uses aggressive resistive boosting. In that case, the product must be registered on the E3 database against AS/NZS 4692.2 MEPS and must meet the standing heat-loss limits.

A TTMRA argument may also be available where the product is lawfully supplied in Australia under the relevant E3 framework. This should not be treated as a substitute for NZ electrical safety, Building Code, customs, or refrigerant obligations. The TTMRA does not apply to the Building Code. Under Acceptable Solution H1/AS1, an electric storage water heater that does not meet NZ MEPS needs an alternative pathway agreed with the building consent authority.

A note on AS/NZS 5125.1: this is a performance assessment standard, not a MEPS standard. It tells you how to characterise COP and capacity at defined operating points so the data can feed into AS/NZS 4234 annual-performance simulations.

Holding AS/NZS 5125.1 test data is essential evidence, but on its own it does not constitute regulatory approval anywhere. It is the input, not the output.

4. Refrigerant and environmental obligations

This is the regime most often forgotten. New Zealand controls HFC refrigerants under the Ozone Layer Protection Act 1996 and applies a synthetic greenhouse gas levy on imported goods containing HFCs or PFCs. The levy rates are set in the Climate Change (Synthetic Greenhouse Gas Levies) Regulations and the levy is collected at the border by Customs.

If your product is pre-charged with R-32, R-410A, R-134a, or similar, the New Zealand importer must declare the refrigerant type and charge mass at the point of import. The importer must also pay the synthetic greenhouse gas levy, calculated from charge mass, refrigerant GWP, and the prevailing carbon price.

For a 1.5 kg R-410A charge, the levy can be a few hundred dollars per unit and should be treated as a real landed-cost item. Commercial-volume importers also need to understand whether HFC phase-down quota arrangements apply.

Products using natural refrigerants such as CO2 / R744 or R290 (propane) are not HFC/PFC-containing goods and are not subject to the synthetic greenhouse gas levy or HFC phase-down controls. R290 is flammable, so check that the electrical certificate explicitly covers the R290 variant.

5. Putting the package together

Here is what an NZ-bound manufacturer or importer needs to assemble before first shipment:

NZ importer entity with an NZBN and a registered office address.
A New Zealand SDoC referencing the existing SAA AS/NZS 60335.2.40 test report, or an EESS registration that names the NZ supplier and confirms the product is compliant for use in New Zealand.
A WaterMark certificate (AS 3498) whose number appears in MBIE recognition notice RN-10034, or an alternative-solution case for each building consent.
Lead-free test report (NSF/ANSI/CAN 372) from an IANZ or equivalent laboratory, and dezincification resistance evidence (AS 2345), for wetted copper alloy components in products manufactured or imported from 2 May 2026 onwards.
AS/NZS 4234 simulation report demonstrating either eligibility for the AS/NZS 4692.2 exclusion, or compliance with the MEPS heat-loss limits and an E3 registration record.
New Zealand-specific installation manual referencing AS/NZS 3500.4, G12/AS1, seismic restraint, and the relevant Building Code clauses.
Customs and refrigerant documentation showing refrigerant type, GWP, charge mass per unit, and the process for paying the synthetic GHG levy.
AS/NZS 5125.1 performance data in product literature, expressed in a way that aligns with how New Zealand specifiers and merchants compare products.

Common failure points

The most common issues for an Australian-certified HPWH entering the New Zealand market are usually avoidable if they are checked before the first shipment.

Leaded brass is a major risk. A factory sending the same SKU to Australia and New Zealand without switching to lead-free brass will be shut out of the NZ market from 2 May 2026. Brass under water pressure that is not dezincification resistant will be shut out too.

Another common issue is having neither an NZ SDoC nor an EESS registration that names the NZ entity. The Australian SAA certificate is recognised only when it sits behind a New Zealand SDoC issued by the NZ supplier, or behind an EESS registration that confirms NZ compliance. A product marked 240 V only, or relying on the RCM as its certification marking, can fail the EESS route.

TTMRA is also often misunderstood. It may help with E3 energy registration, but it does not remove the SDoC requirement, the lead-free plumbing rule, or the synthetic GHG levy.

Even where the product is genuinely exempt from MEPS, the importer still needs AS/NZS 4234 simulation evidence on file to show why it is exempt if EECA asks. For R-410A products, the synthetic GHG levy can also create a landed-cost shock if it has not been priced into the product.

How EnergyAE can help

EnergyAE can provide the technical evidence package: AS/NZS 4234 / TRNSYS simulations to support both the E3 exclusion case and, if needed, MEPS registration. We can also review your AS/NZS 5125.1 test data for consistency and for use in NZ-facing technical literature.

We can also prepare a gap analysis against the four regimes above, so you have a single, prioritised list of what is needed before first shipment.

If you are already certified for Australia, you have done the hard work. The New Zealand step is mostly paperwork and a small number of targeted technical confirmations.

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.