DOE RATINGS FOR DOUBLE DUCT HEAT PUMPS
US Department of Energy (DOE) Framework
Under federal law, the US Department of Energy (“DOE”) requires that SEER2 be the only legally permitted cooling-efficiency rating for this double-duct heat pump. These heat pumps do not qualify as Room Air Conditioners “RAC” or Packaged Terminal Heat Pumps “PTHP” because they fail every structural and installation requirement of a RAC and PTHP in 10 C.F.R. §430.2. As a result, CEER, EER, and EER2, COP, and COP2 without the required SEER2 and HSPF2 ratings and “non-standard size” exemptions are all prohibited classifications.
The only lawful testing and rating method is ASHRAE 37 testing combined with AHRI 210/240 rating procedures, producing a single mandatory cooling metric, SEER2, and a compulsory single heating metric, HSPF2. For this size class, federal law requires a minimum of 13.4 SEER2 and 6.7 HSPF2. Any heat pump that cannot meet 13.4 SEER2 for its rated cooling capacity and 6.7 HSPF2 for its rated heating capacity cannot legally be imported, sold, marketed, installed, or certified in the U.S. If there is any uncertainty regarding this classification, it is easily clarified by the decision here from Intertek labs, as does the AHRI classification for units from Ephoca and Olimpia Splendid.
Any brand advertising SEER, HSPF, or EER instead of SEER2, HSPF2, and EER2 for U.S. residential heat pumps after January 1, 2023 is using non-compliant and unlawful efficiency metrics. The U.S. Department of Energy Final Rule published on December 30, 2021 (86 FR 74228) adopted a new mandatory test procedure, Appendix M1 to 10 CFR Part 430, applicable to residential air conditioners and heat pumps evaluated under AHRI 210/240, with a mandatory compliance date of January 1, 2023. From that date forward, manufacturers and marketers are required to use SEER2 instead of SEER, HSPF2 instead of HSPF, and EER2 instead of EER for all representations, certifications, and marketing materials.
Appendix M1 was deliberately designed to reflect more realistic operating conditions and to eliminate inflation present in the prior test method. It introduced higher external static pressure, explicit fan power penalties, tighter airflow tolerance limits, and revised part-load weighting factors. These changes systematically reduce efficiency outcomes when compared to the legacy test procedure. As a result, a unit tested under Appendix M1 will always produce a lower SEER2 value than the SEER value the same unit would have produced under the old method.
Accordingly, even where a legacy SEER value was once technically accurate under the prior test procedure, it becomes legally invalid and misleading after January 1, 2023. The continued use of SEER, HSPF, or EER after that date does not merely reflect outdated data; it reflects non-compliance with current DOE law, because the applicable test method now requires reporting the lower, corrected SEER2, HSPF2, and EER2 values.
Why These Units Are Not Room Air Conditioners
A Room Air Conditioner (“RAC”) must be installed into a window or a through-the-wall sleeve, must conform to the physical design and construction requirements of Appendix F to Subpart B of 10 CFR Part 430 f, and must operate as a contained assembly inside that sleeve. These double duct heat pumps meet none of these criteria: they sit entirely inside the room, use no sleeve, and were never designed for through-the-wall installation. Because they fail every defining element of RAC, the use of CEER is prohibited.
Why These Units Are Not Packaged Terminal Heat Pumps
A PTHP must use a wall sleeve, contain a removable, unencased heating-and-cooling chassis, and be designed for through-the-wall installation. These units have no wall sleeve, no removable chassis, and no wall penetration of the sleeve, making PTHP classification impossible. Since these products legally cannot be PTHPs, the PTHP efficiency tables, the PTHP minimum EER and COP thresholds, and all PTHP-specific testing procedures are legally inapplicable.
Illegal Misclassification by Copycat Brands
Several copycat units produced in China by Nordica, Zymbo, and Wuxi Hammer for US companies, including Applied Comfort, DesignLine, Islandaire, Inspiron Air, Williams, Exinda, Silktech, Kinghome, and others, continue to publish PTHP classifications with EER and EER2, or RAC classifications with CEER values. Each of these classifications requires the product to be a PTHP or a RAC, which these units are not.
Even if their illegal PTHP classification were correct, their published data still fail the PTHP minimum efficiency requirements. A unit in the 10,000 BTU range must reach 11.0 EER, and a unit in the 12,000 BTU range must reach 10.4 EER, yet almost none of the published numbers meet these thresholds. Thus, this classification is illegal, and the units also fail the efficiency criteria within that misclassification.
10 CFR Part 431 Table II.1—Federal Energy Efficiency Standards for PTACs and PTHPs
Why the “Non-Standard Size” Claim Is Also Illegal
The non-standard size exception applies only to PTAC/PTHP units that meet all the following statutory conditions:
They have no wall sleeve, so they cannot qualify as PTAC or PTHP equipment.
”Non-standard size” refers to PTAC or PTHP equipment with wall sleeve dimensions less than 16 inches high and less than 42 inches wide.”
They also lack the required factory label mandated by ASHRAE/IESNA 90.1-1999. Even if such a label were present, the units could only be installed to replace an existing non-standard-sized PTAC/PTHP – not for new installations.
”MANUFACTURED FOR REPLACEMENT APPLICATIONS ONLY; NOT TO BE INSTALLED IN NEW CONSTRUCTION PROJECTS.”
Therefore, any attempt to claim “non-standard size PTHP” status is a clean, intentional, and blatant misrepresentation of federal law.
Technical Evidence of Fabricated Ratings
Copycat units, under various Nordica brands, list multiple BTU capacities and efficiencies for what is, visually and mechanically, the same hardware. The compressor, indoor and outdoor coils, refrigerant charge, and airflow path are identical, yet the published capacities range from 7,800 BTU, 9,000 BTU, 10,000 BTU, 11,200 to 11,970 BTU, and even 12,000 BTU. Such variations with similar efficiency ratings are impossible.
The same for copycat units manufactured by Zymbo: The compressor, indoor and outdoor coils, refrigerant charge, and airflow path are identical, yet the published capacities range from as low as 8.9 EER for 8,000 BTU to 11.77 EER for 8,831 BTU. How exactly is the same unit capable of achieving 32% higher efficiency with a higher capacity??!!
Wuxi Hammer units have the same issue. One brand markets the unit as a 12,000 BTU model with a claimed 11.3 EER and a 16.95 SEER (not the required SEER2), and another brand sells the same unit but with a far more conservative 9,600 BTU with a lower EER of 11.1 and a lower SEER (not the required SEER2) of 14.8. As before, how can a higher-capacity unit be more efficient?
In an inverter heat pump, a higher capacity always reduces efficiency, and a lower capacity always increases efficiency. Yet, these companies publish the opposite trend, contradicting AHRI 210/240 performance curves, basic thermodynamics, and DOE testing logic.
Capacity Manipulation and What It Demonstrates
Brands manipulate printed capacity to distort efficiency calculations. Ice Air labels a single platform from Nordica as 7,800 BTU to artificially present as a super-high 17 SEER2, while other brands label the same unit at 12,000 BTU to claim higher output. A 54% increase in capacity without any hardware changes and with similar efficiency ratings cannot occur in real equipment, proving that the data is fabricated.
The same pattern appears with Zymbo units. Williams artificially lowers efficiency and capacity, claiming the unit uses 900W at 8,000 BTU, while Zymbo, the actual manufacturer, states that 8,831 BTU requires 750W. If one does the math on the numbers presented by Zymbo, the manufacturer, the unit really has 8,831 BTU and uses only 750W, giving an implausibly high 11.77 EER. Presenting false capacity values violates the FTC Act’s prohibition on deceptive practices, DOE certification rules requiring truthful performance reporting, AHRI 210/240 accuracy standards, and EPCA §6291, which governs energy-efficiency representations.
Mathematical Contradictions in SEER2 and EER
Published data from these brands often contradict each other mathematically for the same unit. A specification showing 10,000 BTU of cooling with 535 watts of input power produces a calculated EER of 18.7, yet the brand states a calculated EER of 8.9. These numbers cannot coexist: accurate wattage would yield an EER of 18.7; accurate EER would require roughly 1,123 watts; and if neither matches, the entire specification sheet is inaccurate.
These contradictions appear across multiple brands that use CEER and EER in place of SEER2 and COP/COP2, or even CEER, even though CEER is a cooling metric. Such inconsistencies make it clear that the published efficiency claims are not based on valid laboratory testing.
SEER2 and HSPF2 are the only legal ratings
SEER2 and HSPF2 ratings under AHRI 210/240, with ASHRAE 37 testing, are the only legally valid ratings for this class of heat pump for cooling and heating. The minimum required efficiency for cooling is 13.4 SEER2, and 6.7 HSPF2 for heating. None of the copycat brands publishes a lawful SEER2. Some publish SEER2; however, that SEER2 rating is fake and can not be replicated in a lab test. Others cannot realistically achieve 13.4 SEER2 based on their claimed capacity. When they fail to publish SEER2, and every alternative rating they publish—CEER, EER, EER2 — is a violation of 10 C.F.R. Part 430, FTC truth-in-advertising rules, AHRI 210/240, and federal law under EPCA. The combination of legal requirements, technical analysis, and mathematical inconsistencies shows that the published ratings are fabricated and the products are being misrepresented in the U.S. market.
