Forest Air FPH-12-2PA and FPH-12-2PD are illegal and Non-Compliant

Failure to be Listed in the NRCan Searchable Product List

In Canada, all air-conditioning and heat-pump systems must be listed in the NRCan database. It is illegal to import or sell a unit that is not listed. At the time of this publication, March 16, 2026, the Forest Air FPH-12-2PA and FPH-12-2PD cannot be located in the NRCan Searchable Product List under any product category — not as a Room Air Conditioner, not as a Heat Pump, and not even as a PTHP.

Failure to Meet NRCan Minimum Efficiency Requirements

Forest Air FPH-12-2PA and FPH-12-2PD have a claimed nominal cooling capacity of 8,000 BTU and a claimed heating capacity of 8,000 BTU. Under federal law, any unit in this class must meet one of the following minimum efficiency thresholds to be legally sold, installed, or used in Canada:

• As a Heat Pump: 13.4 SEER2 for cooling and 5.4 HSPF2 for heating
• As a Room Air Conditioner: 9.3 CEER (rising to 13.7 CEER effective May 26, 2026)

Forest Air publishes neither a SEER2, nor a CEER, nor an HSPF2. This alone renders the unit illegal, regardless of any other violation.

Illegal and Nonsensical Rating: "REER"

Forest Air FPH-12-2PA publishes a rating of 2.6 "REER." There is no such rating as REER under any Canadian, American, or international standard. It does not exist in NRCan regulations, AHRI 210/240, ASHRAE 37, CSA C744, or any applicable certification framework. If the "R" is a typographical error and the intended rating is CEER, the published value of 2.6 is still deeply problematic. CEER values are expressed in BTU/Wh, not in kW of cooling /K watts of power, and a CEER of 2.6 would be catastrophically below the 9.3 minimum — roughly 72% below the legal threshold. If, alternatively, the 2.6 represents a COP-style metric in watts, then multiplying by 3.412 to convert to BTU/Wh yields an approximate CEER of 8.87, which is still below the legally required minimum of 9.3. Interesting to note that in the document, Forest Air shows the “REER” rating is “BTU/W*hr”. Either interpretation renders the unit non-compliant. There is no reading of "2.6 REER" that results in a lawful, compliant efficiency rating.

Fraudulent and Fake Numbers

The performance data published for the Forest Air FPH-12-2PA fails basic mathematical scrutiny.

In Cooling

• Cooling Capacity: 8,000 BTU
• Power Input: 1,380 W
• Using Forest Air's own published figures.

8,000 ÷ 1,380 = EER 5.80. An EER of 5.80 is not only far below the legal CEER minimum of 9.3 — it is so low that it suggests the unit is operating at roughly half the efficiency of a compliant product. For context, window air conditioners from the 1970s achieved EERs in this range. A modern heat pump claiming efficiency while delivering an EER of 5.80 based on its own published wattage is either consuming far more power than it claims, delivering far less cooling than it claims, or both.

Given that the CEER must always be lower than the EER — because CEER accounts for standby power consumption in addition to active consumption — the unit's CEER would be even lower than 5.80. No reasonable interpretation of Forest Air's own published numbers supports a CEER anywhere near the required 9.3, let alone the 13.7 required after May 26, 2026.

In Heating

Forest Air claims an 8,000 BTU heating capacity and a published COP. COP is not a legal rating for this product category under NRCan regulations. The legally required metric is HSPF2, derived from AHRI 210/240 testing. The fact that Forest Air publishes a COP instead of an HSPF2 confirms that no proper laboratory testing was ever conducted, since a genuine AHRI 210/240 test produces an HSPF2 result, not a COP. Furthermore, Forest Air claims equal cooling and heating capacity — both 8,000 BTU — at meaningfully different power inputs. In a real heat pump, the relationship between heating and cooling outputs is governed by the refrigeration cycle and the laws of thermodynamics. While heating and cooling outputs are not always identical, the published figures must be internally consistent with the compressor, coil size, refrigerant charge, and operating conditions. Forest Air provides no data to support the plausibility of its heating claims, and its cooling data alone disqualifies the unit from compliance.

Illegal Rating Metric

Forest Air publishes a COP for heating instead of the required HSPF2, and a fictional "REER" for cooling instead of the required SEER2 or CEER. Neither of the published metrics is legally valid for this product category. Using non-standard or invented rating metrics is a direct violation of the Energy Efficiency Regulations, 2016, and constitutes a deceptive representation under the Competition Act (R.S.C., 1985, c. C-34). No accredited laboratory would issue a test report using the term "REER." The use of a fabricated metric confirms that the data originates from a spreadsheet rather than a certified testing facility.

Illegal Misclassification

Forest Air does not explicitly classify the BTU/W*hr as a PTHP, but its use of a non-standard EER-style metric and COP implies a PTHP-adjacent classification framework. Regardless of how Forest Air internally classifies the unit, it does not meet the structural definition of a PTHP under the Energy Efficiency Regulations, 2016. A lawful PTHP must have a wall sleeve, a separate unencased chassis, and through-the-wall mounting. The FPH-12-2PA lacks all of these features. The unit also does not qualify as a portable air conditioner or a single-package vertical unit. It must therefore be classified as either a Room Air Conditioner or a Heat Pump — and under either classification, it fails to meet the required minimum efficiency thresholds.

Regulatory Violation Summary: Forest Air — FPH-12-2PA & FPH-12-2PD

These products are illegal to distribute, specify, install, or use in the United States and Canada. Forest Air publishes a fictional "REER" cooling metric and a COP heating metric — neither of which exists in any applicable standard or would ever appear on a report from an accredited laboratory. The FPH-12-2PA and FPH-12-2PD fail to meet DOE and NRCan minimum efficiency requirements under every applicable classification. Based on Forest Air's own published data, the calculated EER of 5.80 is less than two-thirds of the legally required minimum CEER of 9.3 — a gap so large that no plausible adjustment to the data could bring it into compliance.

No accredited laboratory would issue a test report using the term "REER." Its use confirms that the data originates from a spreadsheet rather than a certified testing facility.

Illegal Product Misclassification

Forest Air's use of non-standard metrics implies a PTHP-adjacent classification framework. However, the FPH-12-2PA does not meet the structural definition of a PTHP under any applicable regulation — a lawful PTHP requires a wall sleeve, a separate unencased chassis, and through-the-wall mounting, none of which the FPH-12-2PA possesses. The unit also does not qualify as a portable air conditioner or a single-package vertical unit. It must therefore be classified as either a Room Air Conditioner or a Heat Pump — and under either classification, it catastrophically fails to meet the required minimum efficiency thresholds.

These ratings cannot be invented. They must be established through certified testing in an SCC-accredited laboratory in accordance with the correct NRCan test procedures. Forest Air has not done this, and the data it publishes makes clear why.