This section details how every copycat brand violates binding U.S. federal law. These are not minor irregularities or classification mistakes; they are complete failures in mandatory federal product categorization, required laboratory test procedures, rating methods, truth-in-labeling rules, minimum efficiency requirements, and DOE certification obligations. Under federal law, these units are illegal to classify, rate, certify, sell, or install anywhere in the United States.
The violations begin with the most basic requirement in 10 C.F.R. § 430.2: a product must exactly fit the definition of its claimed category. These units do not. They are falsely labeled as Room Air Conditioners, Packaged Terminal Heat Pumps, and even “Non-Standard Size” PTAC/PTHP versions.
None of these classifications is lawful because the units lack the structural and installation features required for those categories. A legitimate PTHP must have a wall sleeve, an unencased removable chassis, a through-the-wall design, outdoor louvers, and optional resistance heat. These units have none of those. A legitimate Room Air Conditioner must mount in a window or through-the-wall opening with outside-air exchange. These units do not satisfy any of those requirements. Their classifications are false, rendering every associated metric and performance claim unlawful the moment they are published.
Mandatory federal test procedures are ignored entirely. All residential heat pumps of this size must be tested in accordance with ASHRAE 37 and rated in accordance with AHRI 210/240 in a controlled psychrometric laboratory using certified instrumentation across the required operating conditions. The copycat brands do not use ASHRAE 37, do not use AHRI 210/240, do not possess any NRTL laboratory performance report, and publish performance values that are physically impossible under these procedures. Because the tests were never performed, every EER, SEER2, COP, HSPF2, BTU output, and watt input they publish is illegal under federal regulation.
Violations escalate under minimum efficiency standards. DOE requires a minimum of 13.4 SEER2 for ductless heat pumps in the 10,000–12,000 BTU range. None of these units meets the 13.4 SEER2 requirement. Those who publish an SEER2 publish fake data, and those who do not publish an SEER2 rating because none can survive compliance testing. Their performance collapses in a real laboratory, which is why they hide behind fake CEER, EER, and “PTHP EER” values instead of publishing the required SEER2. Failing to meet the minimum standard makes a product illegal to market, certify, sell, or install, and subjects violators to civil penalties under 42 U.S.C. §6303.
The misuse of federal metrics is an additional violation. CEER is only for Room Air Conditioners under Appendix F; these products are not RACs. Using CEER is illegal. PTHP EER tables only apply to Packaged Terminal Heat Pumps under Part 431; these products are not PTHPs. Using PTHP EER tables is unlawful. Heating performance metrics such as COP and HSPF2 must come from AHRI 210/240 tests; none of these brands have even attempted such tests. Every metric they publish belongs to a product category the unit does not qualify for, making the metric itself unlawful.
DOE certification, labeling, and reporting requirements are also violated across the board. Every HVAC product sold in the United States must be classified appropriately, tested under mandatory procedures, registered in DOE’s CCMS certification database, and labeled with truthful information supported by certified data. None of the copycat units appear in DOE’s CCMS database. Accredited test data support none. None complies with classification rules. All are misrepresented in marketing. Every unit fails every DOE certification and labeling requirement.
These acts also constitute deception under the FTC Act §5. Publishing fake performance data, fake capacities, fake EER values, false CEER values, fictitious SEER2 claims such as 15.5, 16, or 17.0, and fabricated COP and HSPF2 values is not a technical mistake; it is deceptive conduct prohibited by federal law. Each false representation is a material misrepresentation affecting consumers, engineers, contractors, and developers. FTC has the authority to fine, require recall, demand relabeling, prohibit further sales, and impose compliance monitoring. The behavior of these brands fits squarely within the enforcement scope.
The violations extend further into EPCA (42 U.S.C. 6291 et seq.). Under EPCA, all published performance must be truthful. All tests must use mandatory federal procedures. Certified data must support all claims. Non-compliant products cannot legally be sold. The copycat brands violate every one of these statutory requirements.
Lab certification requirements are also violated. None of the copycat products has been tested in a real lab. Any SEER2 claim must have a genuine lab report to be lawful. The absence of a real lab test means that every published SEER2, EER, EER2, CEER, COP, COP2, HSPF2, and BTU value is illegal.
Under 42 U.S.C. §6303, DOE may impose financial penalties, seize noncompliant products, mandate a recall, require relabeling, and permanently prohibit the sale of the offending equipment. These units qualify for enforcement action because they falsify classification, watt inputs, BTU outputs, SEER2, EER, CEER, COP, and HSPF2, fail federal test procedures, and evade certification.
Every rating published by these brands is illegal. Every classification is illegal. Every watt input, BTU output, SEER2, EER, EER2, CEER, COP, COP2,HSPF2 value, and every representation made in marketing or documentation is fabricated. These units violate federal regulations at every level — classification, testing, certification, labeling, marketing, and performance reporting. None complies with U.S. law in any meaningful dimension.
The performance data published by every copycat brand using this platform is internally contradictory, mathematically impossible, thermodynamically unrealistic, and legally non-compliant. None of the numbers originates from required AHRI 210/240 or ASHRAE 37 testing; none of the units are classified correctly in 10 C.F.R. §430.2; none meet the mandatory 13.4 SEER2 minimum standard; and none appear in AHRI listings, DOE certification records, or any NRTL performance report. This is not a borderline interpretation of the law, not an administrative delay, and not a technical misunderstanding. It is a direct fabrication of BTU, SEER2, EER, CEER, COP, and HSPF2 values to make a low-cost, low-performance platform appear competitive on paper.
Legally, these brands and Nordica, the Chinese manufacturer, violate the Energy Policy and Conservation Act, DOE test procedure mandates, and FTC Act §5’s prohibition on deceptive claims. They face potential DOE enforcement actions, FTC penalties, competitor and consumer litigation, forced relabeling, product seizure, and market removal. Their published performance data cannot survive a federal audit or courtroom challenge.
Technically, any engineer relying on these ratings is relying on false information, and any owner purchasing these units based on the published specifications is paying for performance that does not exist. The fraud is fundamental; it affects every rating, every claim, and every representation made about these products.
