Registering a White-Label HPWH for STCs, VEECs, and ESCs

Australian importers may distribute foreign-manufactured HPWHs under a local brand name rather than the OEM brand. When the underlying model already holds AS/NZS 2712 certification, an AS/NZS 5125.1 performance test report, and an AS/NZS 4692.1 tank heat loss result, registering the white-label version for STCs, VEECs, and ESCs does not require new testing or new modelling. The evidence base already exists. What the schemes require is proof that the product being sold matches what was tested and certified, presented under the brand name it will carry in the market.

What makes the white-label scenario different

A standard first-registration requires testing, modelling, certification, and scheme submission, roughly in that order, each with significant lead time. A white-label registration skips the first two steps entirely. The OEM manufacturer’s test reports and modelling outputs remain the technical evidence. What changes is the brand, model name, and certificate holder shown on the documents.

The schemes (SRES through CER, VEU through ESC, and ESS through IPART) accept model equivalence or authorisation declarations in place of repeated testing, provided the declared relationship is clear and the new model name is added to a valid AS/NZS 2712 certificate schedule. CER and ESC both require this certificate as a prerequisite for scheme listing.

No technical changes to the product are permitted under this pathway. If the importer changes refrigerant type, tank volume, compressor model, or control logic, that triggers new testing requirements.

The critical step: AS/NZS 2712 certificate schedule

The single step that cannot be done by declaration is ensuring the importer’s brand and model name appears on a valid AS/NZS 2712 certificate schedule. There are two ways to achieve this, and which route to take is worth deciding early.

The first option is to have the OEM manufacturer add the importer’s model name to their existing schedule. This requires the OEM (as the current certificate holder) to instruct their Accredited Certification Body (ACB), such as SAI Global or IAPMO, to amend the schedule. No new testing is needed; the ACB confirms the model descriptions match and issues an updated certificate. This typically takes two to six weeks. It is the lower-cost path, but the importer’s model will appear on the OEM’s certificate, making the OEM relationship visible.

The second option is for the importer to obtain their own AS/NZS 2712 certificate. This requires engaging an ACB directly, submitting the product for certification under the importer’s entity, and referencing the existing test reports as evidence. It is more involved and more expensive, but the resulting certificate is entirely in the importer’s name with no OEM reference. This is the more common choice for importers who want full control over their certification and supply chain privacy.

Without a current AS/NZS 2712 schedule showing the importer’s model name, scheme submission cannot proceed. CER and ESC both verify this as a prerequisite. Whichever route is chosen, it needs to be started early as it sits outside EnergyAE’s control and determines the timeline for everything that follows.

Similarly, electrical safety certification in Australia is tied to the certificate holder entity. The AS/NZS 2712 schedule update handles the HPWH system certification, but the electrical safety certificate (issued under RCM/EESS by a state electrical safety regulator or a recognised testing body) must also reflect the importer’s brand and entity. If the OEM manufacturer holds the existing electrical certificate under their own name, the importer needs either a transfer of that certificate or a fresh application. This is arranged directly between the importer and the certifying body, not through EnergyAE.

What EnergyAE covers

Once the 2712 certification path is confirmed and underway, EnergyAE can prepare the rest of the submission package. The existing AS/NZS 5125.1 performance test report, AS/NZS 4692.1 tank heat loss result, TRNSYS files, and AS/NZS 4234 modelling from the OEM manufacturer’s original registration are used as the technical basis. EnergyAE writes a model equivalence declaration identifying the OEM model and the white-label model as the same physical product, confirms the declaration is consistent with the test and certification evidence, and prepares scheme-specific application forms.

Everything beyond the 2712 schedule and electrical certificate is covered by declaration. The importer does not need new testing or new modelling.

The importer is responsible for supplying:

Installation and owners manuals in the importer’s brand name and Australian model name.
Data plate images showing the importer’s brand, Australian model name, and relevant certification marks.
The AS/NZS 2712 certificate or updated schedule showing the new model name.
Electrical safety evidence (EESS or RCM registration) under the importer’s entity.

For a full list of what EnergyAE needs before starting, see the Residential HPWH Documentation Checklist.

EnergyAE handles the technical compilation, declaration writing, and submission to CER, ESC, and IPART as required.

Scheme-specific notes

CER runs three application rounds per year for the SRES. Applications must be lodged by the round deadline, and the product will typically appear on the register within three months of the round closing. If a round closes before the 2712 schedule update is available, the submission waits for the next round. See the STC registration guide for a full overview of the CER process.

VEU (ESC) accepts submissions at any time, with a typical review period of six to eight weeks. See the VEEC registration guide for scheme-specific requirements. ESS (IPART) also accepts rolling submissions.

All three schemes accept model equivalence declarations to link the white-label model to the original test evidence. Each scheme has slightly different declaration formats and requirements; EnergyAE prepares scheme-specific versions.

What to do first

Decide which 2712 route suits your situation: amendment to the OEM’s schedule, or your own certificate. Then contact either your OEM manufacturer (for the amendment route) or an ACB directly (for your own certificate) and get an estimated timeline. In parallel, confirm your electrical safety registration status and whether it covers the specific models you intend to sell.

Once those two steps are underway, send EnergyAE the existing test reports, 2712 schedule (current and pending updated version), electrical certificate, manuals, and data plate images. We will review the documents, identify any consistency gaps before they become submission problems, and prepare the application.

Get in touch with EnergyAE to start the process.