From the Report

Not a single one of these units is listed in the NRCan Searchable Product List.

Brand Findings

Mits Air MITSWZ28EC is Illegal and Non-Compliant


Overview

The Mits Air MITSWZ28EC is a residential mini-split unit marketed in Canada with a claimed nominal cooling capacity of 8,881 BTU and a claimed heating capacity of 7,895 BTU. A review of its published specifications and regulatory standing reveals multiple serious compliance failures under Canadian federal law, as well as technical inconsistencies that undermine the credibility of the manufacturer's published data.

Failure to be Listed in the NRCan Searchable Product List

Under Canadian federal regulations, all air-conditioning and heat-pump systems must be listed in Natural Resources Canada's (NRCan) Searchable Product List before they can be legally imported, distributed, or sold. As of the date of this publication, the MITSWZ28EC does not appear in that database under any applicable product category — including Room Air Conditioner, Heat Pump, or Packaged Terminal Heat Pump (PTHP).

This absence alone constitutes a violation of federal law, independent of any other deficiency identified in this analysis.

Failure to Meet NRCan Minimum Efficiency Requirements

Canadian federal regulations establish minimum efficiency thresholds for units in this capacity class. Depending on classification, the MITSWZ28EC would be required to meet one of the following:

  • 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

Mits Air publishes neither a SEER2 nor a CEER for cooling, and no HSPF2 for heating. Instead, the company publishes EER and COP values — metrics that do not satisfy Canadian regulatory requirements and cannot be used as substitutes for the mandated ratings. The absence of any compliant efficiency rating renders the unit illegal to sell, install, or use in Canada, regardless of its actual performance.

The Zymbo Connection

The MITSWZ28EC is manufactured by Zymbo, which markets the identical unit as the WZ-28EC. The two products share the same compressor, coil geometry, refrigerant charge, airflow path, and chassis. The only distinguishing feature is the nameplate.

A direct comparison of the published specifications from both companies reveals physically inconsistent figures:

Let’s compare the data from the manufacturer, Zymbo, to Mits Air:

WZ-28EC Inverter 1 1

Mits Air WZ-28EC

Change between Zymbo and Mits Air

Cooling Capacity (BTU)

9000

8881

Slightly Less Capacity

-1.32%

Input Power Watts (cooling)

745

675

Much less power

-9.40%

EER (Btu/W)

12.08

13.16

Higher Efficiency

8.94%

Heating Capacity (BTU)

8500

6824

Way less capacity

-19.72%

Input Power Watts (heating)

697

689

Slightly Less power

-1.15%

COP (W/W)

3.5

3.36

Less efficiency

-4.00%

Refrigerant

R32/470g

470

No change

This doesn’t add up.

Cooling: An Implausible Efficiency Gain

Mits Air's figures show a 9.4% reduction in input power while cooling capacity falls by only 1.3% —yielding an apparent 8.9% improvement in EER. On identical hardware with identical refrigerant, this is not physically achievable. A reduction in input power of that magnitude would require a corresponding, nontrivial reduction in capacity.

Heating: An Implausible Efficiency Loss

The heating figures are even more inconsistent. Mits Air reports a 19.7% reduction in heating capacity compared to Zymbo, while input power is reduced by only 1.1%, and COP actually declines by 4.0%. Thermodynamically, a substantial reduction in output capacity on the same hardware, with nearly unchanged power consumption, is not possible. Furthermore, lower capacity at similar power input should generally produce higher efficiency, not lower. The direction and magnitude of these changes are irreconcilable with the laws of thermodynamics.

The only coherent explanation is that Mits Air's published figures were not derived from laboratory testing. They appear to have been manually entered without a credible empirical basis.

Regulatory Classification and Labeling Violations

Because the MITSWZ28EC carries no recognized efficiency rating — no CEER, no SEER2, no HSPF2 — it cannot satisfy the classification or labeling requirements under any applicable NRCan product category. To achieve legal status, the unit would require:

  • As a Heat Pump: A certified SEER2 of at least 13.4 and a certified HSPF2 of at least 5.4, established through testing at a Standards Council of Canada (SCC)-accredited laboratory.
  • As a Room Air Conditioner: A certified CEER of at least 9.3, rising to 13.7 after May 26, 2026, established through the same accredited process.

These ratings cannot be self-declared or calculated from published wattage figures. They must be derived from standardized test procedures conducted at an accredited facility.

Regulatory Violation Summary: Mits Air — MITSWZ28EC

This product is illegal to distribute, specify, install, or use in Canada. The MITSWZ28EC carries no compliant efficiency ratings, is absent from the NRCan product registry, and its published technical data contains internal contradictions that are physically impossible and inconsistent with any laboratory-derived measurements. The published EER and COP figures cannot be reconciled with the specifications of the identical Zymbo WZ-28EC — the unit's own manufacturer — nor with basic thermodynamic principles.

No Compliant Efficiency Data Published

Required Metric

Purpose

MITSWZ28EC Status

SEER2

Mandatory cooling efficiency rating for heat pumps

❌ Not published

HSPF2

Mandatory heating efficiency rating for heat pumps

❌ Not published

CEER

Mandatory cooling efficiency rating for room air conditioners

❌ Not published

EER

Published, but contradicts the specifications of the identical Zymbo WZ-28EC and violates thermodynamic principles

⚠️ Published but invalid

COP

Published, but contradicts specifications of the identical Zymbo WZ-28EC and violates thermodynamic principles

⚠️ Published but invalid

The absence of compliant efficiency ratings is not an oversight. Published EER and COP figures that contradict those of the unit's own manufacturer and that are inconsistent with physical reality are not measurements — they are fabrications. Under the Competition Act, both false statements and material omissions of required performance data are equally actionable.

Faking Test Results

Violation

US Law Violated

Canadian Law Violated

Mits Air has provided no evidence of testing at an SCC-accredited laboratory — no legitimate efficiency rating for the MITSWZ28EC has ever been produced

10 CFR Part 429/430

Energy Efficiency Regulations, 2016

Published EER and COP figures are internally contradictory and cannot be reconciled with the specifications of the identical Zymbo WZ-28EC or with basic thermodynamic principles

10 CFR Part 429/430; 18 U.S.C. § 1001

Energy Efficiency Act; Energy Efficiency Regulations, 2016

The MITSWZ28EC uses identical hardware to the Zymbo WZ-28EC, yet publishes efficiency and capacity figures that contradict those of its own manufacturer, making clear that no legitimate independent testing has been conducted

10 CFR Part 429/430; 18 U.S.C. § 1001

Energy Efficiency Act; Energy Efficiency Regulations, 2016

Selling a Product That Should Not Be on the Market

Violation

US Law Violated

Canadian Law Violated

MITSWZ28EC does not meet minimum efficiency standards — no certified data exists to demonstrate compliance with any applicable efficiency threshold

10 CFR Part 430

MEPS under Energy Efficiency Regulations, 2016

Mits Air never listed the MITSWZ28EC on NRCan's searchable product database, meaning the product was never legally cleared for import or interprovincial sale in Canada

NRCan Searchable Product Database; Energy Efficiency Act

MITSWZ28EC was never certified by an accredited certification body and does not carry the mandatory compliance mark

DOE Certification under 10 CFR Part 429

Standards Council of Canada Energy Efficiency Verification Mark

Mits Air never filed the required compliance reports with regulators before importing or selling the MITSWZ28EC

DOE via CCMS

NRCan Energy Efficiency Report

Contractors, specifiers, and consumers who source, install, or use this unit may expose themselves to regulatory and legal liability

10 CFR Part 430

Energy Efficiency Act; Energy Efficiency Regulations, 2016

Lying to Customers and Regulators

Violation

US Law Violated

Canadian Law Violated

Mits Air markets and sells the MITSWZ28EC with published efficiency figures that contradict its own manufacturer's specifications and violate thermodynamic principles

10 CFR Part 429.12; 18 U.S.C. § 1001 — federal criminal offence

Energy Efficiency Act — fines up to $10,000 per violation

Product literature and marketing materials violate classification and labeling requirements by omitting all mandatory compliance efficiency metrics

FTC Energy Labeling Rule, 16 CFR Part 305; DOE Labeling Requirements under 10 CFR Part 430

NRCan Product Classification and EnerGuide Labeling Requirements under Energy Efficiency Regulations, 2016

By publishing figures that contradict those of the unit's own manufacturer, Mits Air misrepresents the performance capability of the MITSWZ28EC to customers, dealers, regulators, and certification bodies

18 U.S.C. § 1001 — federal criminal offense

Energy Efficiency Act offense

Breaking Consumer Protection and Competition Laws

Violation

US Law Violated

Canadian Law Violated

Publishing efficiency and capacity figures that contradict the unit's own manufacturer and that are inconsistent with physical reality constitutes false or misleading representations in a material respect

FTC Act Section 5, 15 U.S.C. § 45; Lanham Act, 15 U.S.C. § 1125(a)

Competition Act, R.S.C. 1985, c. C-34

The deliberate omission of all compliant efficiency ratings is a material omission under the Competition Act, treated the same as a false statement and equally actionable

Competition Act, R.S.C. 1985, c. C-34

Maximum penalties for serious violations or refusal to take corrective action

FTC civil penalties up to $53,088 per violation

Energy Efficiency Act fines $10,000–$200,000

Mits Air MITSWZ28EC cannot legally be sold, installed, or used in Canada.