The Findings — Part 05

Illegally Imported and Sold in North America

None of these brands are listed in the database of NRCan as required by law! Not as Room Air Conditioners, not as Heat Pumps, and not even (incorrectly) as PTHP! Zero.

Almost none of these brands are listed in DOE’s database, as required by law! Not as Heat Pumps, and not even (incorrectly) as PTHP or Room Air Conditioners!

Canada - Energy Efficiency Act, Section 5(1)

"Every dealer who, for the purpose of sale or lease, ships an energy-using product from one province to another or imports an energy-using product into Canada shall provide the Minister [...] with prescribed information..." "A report must be filed only when a product model is not already listed in the NRCan database."

"Each manufacturer, before distributing in commerce any basic model of a covered product... shall submit a certification report."

USA - 10 CFR § 429.12(a)

"Each manufacturer, before distributing in commerce any basic model of a covered product... shall submit a certification report."

Under 10 CFR § 429.102, "prohibited acts" include:

Failure to certify a model before selling it.
Distributing a model that does not meet the minimum energy standards.

If a company or contractor tells you a model "doesn't need to be on the list," they are incorrect. Every regulated heat pump (under 65,000 Btu/h) must be reported to the Minister (Canada) or to the DOE to be legally present in the North American market.

Canada

Penalties Bill S-4 / 2026 Context

As of recent updates to the Act (Bill S-4), this law has been sharpened significantly to catch online "grey market" sellers:

Summary Conviction (Minor): Up to $50,000 for an offense
Indictable Offense (Major): Up to $200,000 for an offense

USA

10 CFR § 429.120: "Any person who knowingly violates any provision of § 429.102(a) may be subject to assessment of a civil penalty of no more than $575 for each violation."

"As to § 429.102(a)(1) with respect to failure to certify... each unit of a covered product or covered equipment distributed in violation of such paragraph shall constitute a separate violation."

"For violations of § 429.102(a)(1), (3), and (4), each day of noncompliance shall constitute a separate violation for each basic model at issue."

US Department of Energy's Compliance Certification Database (DOE CCMS)

Every unit imported and/or sold in the USA must be registered in this database by law, and it is illegal to import, sell, or use a unit that is not listed.

https://www.regulations.doe.gov/certification-data/CCMS-4-Air_Conditioners_and_Heat_Pumps_-_Central.html#q=Product_Group_s%3A%22Air%20Conditioners%20and%20Heat%20Pumps%20-%20Central%22

California Energy Commission, Modernized Appliance Efficiency Database System (MAEDBS)

Every unit imported and/or sold in the State of California, in addition to being registered in the DOE CCMS, must be registered in this database by law, and it is illegal to import, sell, or use a unit that is not listed.

https://cacertappliances.energy.ca.gov/Pages/ApplianceSearch.

Natural Resources Canada Searchable Product List (NRCan SPL)

By law, every unit imported and/or sold in Canada must be registered in this database, and it is illegal to import, sell, or use a unit that is not listed. In Canada, units can be listed under Room Air Conditioner or Heat Pump. You can check and see that not a single one of these brands is listed.

Room Air Conditioner: https://spl-lpi.nrcan-rncan.gc.ca/en-US/product/?product=AC.Room&page=1

Heat Pumphttps://spl-lpi.nrcan-rncan.gc.ca/en-US/product/?product=HP.SinglePackageSingle&page=1

		USA			Canada
		DOE CCMS	California MAEDBS	AHRI	NRCan as a Heat Pump	AHRI
Applied Comfort	TPHE10L00E6	X	X		X	X
Applied Comfort	TPHE10K10E6	X	X		X	X
DesignLine	Roommate MHP11	X	X		X	X
DesignLine	Roommate MHP10	X	X		X	X
Dubbll	DDHPA-10X-00E	X	X		X	X
Dubbll	DDHPA-12Y-10E	X	X		X	X
Forest Air	FPH-12-2PA	X	X		X	X
Forest Air	FPH-12-2PD	X	X		X	X
Genuine Comfort	GCMB-H12KA0-1	X	X		X	X
Genuine Comfort	GCMB-H12KC2-1	X	X		X	X
Genuine Comfort	GCMB-H12KD3-1	X	X		X	X
Ice Air*	8RSXC09-DH	✔️	✔️		N/A	N/A
Inspiron Air	iAIRHP-35-CC/CC-ERV	X	x		X	X
Inspiron Air	iAIRHP-35-CS/CS-ERV	X	x		X	X
Inspiron Air	iAIRHP-35-VK/VK-ERV	X	x		X	X
Inspiron Air	iAIRHP-35-WM-A	X	x		X	X
Islandaire	EZMB9L5A1S95AA	X	X		X*	X*
Islandaire	EZMB10L5A1S95AA	X	X		X*	X*
Kinghome	Dolphin 40 Inverter	X	x		X*	X*
Mits Air	MITSWZ28EC	X	x		X	X
Mits Air	MITZWZ-40EC	X	X		X	X
Multi MFG	MAIRHP-35-CS/CS-ERV	x	x		x	x
Multi MFG	MAIRHP-35-WM	x	x		x	x
Multi MFG	MAIRHP-35-CC/CC-ERV	X	x		X	X
Nordica	YWD-10HD/FC6-W	x	x		x	x
Nordica	YWD-10HD2/FC6-W	x	x		x	x
Ortech	Solo1	X	x		X	X
PMC Green*	PMCG-10HD	x	x		N/A	N/A
Silktech	EcoAuro 1.0	x	✔️		X	X
Silktech	EcoAuro 2.0	✔️	✔️		X	X
Technoact	TECH-115V-10C	X	x		X	X
Waysos	Compact-Aire 3K	X	X		X	X
Williams	Montara HP003	X	x		X	X
Zymbo	MITSWZ-40EC	X	✔️		x	x
Zymbo	Clima Puro	X	X		X	X
Zymbo	Dolphin 25 Inverter	✔️	✔️		x	x
Zymbo	Compact-Aire 3K	X	✔️		X	X
Zymbo	Dolphin 40 Inverter	X	✔️		X	x

* PMC Green and Ice Air are not sold in Canada