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, and a few specifically Kiwi requirements that will catch you out if you don’t plan for them. This post walks through what’s required to legally place a HPWH on the New Zealand market, in the order you should tackle it.

The four regimes you need to satisfy

A HPWH supplied in New Zealand sits at the intersection of four separate compliance regimes, each administered by a different body:

Electrical safety: Electricity (Safety) Regulations 2010, administered by Energy Safety (WorkSafe).
Plumbing & building: New Zealand Building Code, in particular Acceptable Solution G12/AS1 Water Supplies, administered by MBIE.
Energy efficiency: Energy Efficiency (Energy Using Products) Regulations 2002 (the E3 programme), administered by EECA.
Refrigerant / environmental: Ozone Layer Protection Act 1996 and the synthetic greenhouse gas levy, administered by EPA and Customs.

You can’t skip any of these. The good news is that your existing Australian evidence package addresses most (but not all) of what’s needed.

1. Electrical safety: the SDoC pathway

Many domestic integrated HPWHs fall within WorkSafe’s declared medium-risk “water heater” category (Electricity (Safety) Regulations 2010), 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, supported by a test report demonstrating compliance with the relevant standard listed in Schedule 4 of the Regulations. For HPWHs, this 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, must reference the New Zealand importer (with NZBN, address, contact details), and must be available within 10 working days of any request from Energy Safety, a purchaser, or a consumer. Selling without a valid SDoC is a Grade A offence with fines up to $10,000 for an individual or $50,000 for a company.

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 one).
Hold the SAA test report on file as the supporting document.
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. Note that, 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) (AS 3498) certification can be strong supporting evidence in New Zealand. However, it must still 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 standard. 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.
Lead-free and DZR copper alloy requirements. 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. Evidence should include NSF/ANSI/CAN 372:2020 for lead-free compliance and AS 2345:2006 for DZR, supported by IANZ-accredited or equivalent test certificates. NZ-bound HPWHs should be transitioned to lead-free and DZR-compliant components before supply into projects relying on G12/AS1 Amendment 14.
AS/NZS 4020 drinking water contact testing for any wetted non-metallic components (gaskets, liners, tempering valve seats). Usually already addressed within a WaterMark certification, but worth confirming for each component.
G12/AS1 system requirements. These are installation-side, but the product needs to enable compliance: sanitation cycle to ≥60 °C daily for Legionella control, a tempering valve compatible with 50 °C delivery to personal-hygiene fixtures, and adequate seismic restraint provisions in the installation manual.

You don’t 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.

However, 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 be carrying well over 50% of the annual load. But the exclusion is not automatic — you have to demonstrate it with 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 TRNSYS .dck files that show the element boost input is minimal or zero.
Provide reasoning that products with energy savings ≥60% must have element contribution <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:

Most common: HPWH passes the AS/NZS 4234 exclusion — no NZ MEPS registration required. Document the simulation result and keep it on file.
Rare: HPWH fails the exclusion (e.g. small tank with aggressive resistive boosting) — product must be registered on the E3 database against AS/NZS 4692.2 MEPS, and meet the standing heat-loss limits.
TTMRA: A TTMRA argument may be available where the product is lawfully supplied in Australia under the relevant E3 framework, but 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 5125.1 test data is essential evidence, but on its own it doesn’t constitute regulatory approval anywhere. It’s 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 (kg) at the point of import.
Pay the synthetic greenhouse gas levy, calculated from charge mass × refrigerant GWP × prevailing carbon price. For a 1.5 kg R-410A charge this is typically a few hundred dollars per unit — a real line item in the landed cost.
Comply with HFC phase-down quota arrangements if importing in commercial volumes.

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 its NZ importer) needs to assemble before first shipment:

NZ importer entity with an NZBN and a registered office address.
EESS Responsible Supplier registration (preferred) or a New Zealand SDoC referencing your existing SAA AS/NZS 60335.2.40 test report.
Lead-free confirmation: all wetted copper alloy components lead-free to NSF/ANSI/CAN 372 for any product manufactured or imported from 2 May 2026 onwards.
AS/NZS 4234 simulation report demonstrating either (a) eligibility for the AS 4692.2 exclusion, or (b) 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 (B1, B2, E2, G9, G12, H1).
Customs and refrigerant documentation: refrigerant type, GWP, charge mass per unit, and process for paying the synthetic GHG levy.
AS/NZS 5125.1 performance data in the product literature, expressed in a way that aligns with how Kiwi specifiers and merchants compare products (typically COP at the AS 4234 reference point).

Common failure points

The most common issues for an Australian-certified HPWH entering the New Zealand market:

Leaded brass. A factory sending the same SKU to AU and NZ that hasn’t yet switched to lead-free brass will be shut out of the NZ market from 2 May 2026.
No NZ SDoC and no EESS registration of the NZ entity. The Australian SAA certificate is recognised, but only when wrapped in a New Zealand SDoC issued by the NZ supplier. Many importers assume the SAA cert “is enough”. It isn’t.
Assuming TTMRA covers everything. TTMRA covers E3 energy registration but does not cover the SDoC requirement under the Electricity (Safety) Regulations, the lead-free plumbing rule, or the synthetic GHG levy.
No AS/NZS 4234 simulation evidence on file. Even where the product is genuinely exempt from MEPS, the importer still needs to be able to show why it’s exempt if EECA asks.
R-410A landed cost shock. The synthetic GHG levy is significant. If you haven’t priced it in, your retail margin is wrong.

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; review of your AS/NZS 5125.1 test data for consistency and for use in NZ-facing technical literature; and gap analysis against the four regimes above so you have a single, prioritised list of what’s needed before first shipment.

If you’re already certified for Australia, you’ve 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/certification package is complete and no product redesign is needed.

If you’d like a free 30-minute call to talk through your entry to the NZ market, get in touch.