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. It must be available within 10 working days of any request from Energy Safety, a purchaser, or a 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.

If the product is registered on EESS and the NZ supplier is correctly registered as the Responsible or Affiliated Supplier, that EESS registration may be used to support the NZ SDoC pathway. 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 EESS registration.

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 it is increasingly recognised.

MBIE has formally recognised some WaterMark-certified products through product recognition notices, so your existing WaterMark (WMK) certification to AS 3498 can be strong supporting evidence. It still needs to be checked against the relevant recognition notice scope and any NZ-specific conditions, including lead-free and DZR requirements.

Your WaterMark and AS/NZS 2712 certification cover the core product-level plumbing certification. 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 becomes the only MBIE Acceptable Solution for Clause G12. Copper alloy products in contact with drinking water must contain no more than 0.25% lead and must be dezincification resistant, with evidence such as NSF/ANSI/CAN 372:2020 for lead-free compliance and AS 2345:2006 for DZR.

Any wetted non-metallic components also need AS/NZS 4020 drinking water contact evidence. This is often already addressed within a WaterMark certification, but it is worth confirming for gaskets, liners, tempering valve seats, and similar components.

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, electric storage water heaters (hot water cylinders with capacity up to 710 L) must comply with NZ MEPS to AS/NZS 4692.2:2005 and must be registered in the trans-Tasman E3 registration database before sale. The E3 category explicitly includes the storage component of heat pump systems.

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.

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.

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, 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 CO2 / R744 are not HFC/PFC-containing goods and are not subject to the synthetic greenhouse gas levy or HFC phase-down controls.

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.
EESS Responsible Supplier registration, or a New Zealand SDoC referencing the existing SAA AS/NZS 60335.2.40 test report.
Lead-free confirmation for wetted copper alloy components for 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.

Another common issue is having no NZ SDoC and no EESS registration for the NZ entity. The Australian SAA certificate is recognised only when wrapped in a New Zealand SDoC issued by the NZ supplier.

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.