2026 Energy Label Certification for Water Supply Machines Under CNS 3910

Background

On June 10, 2026, Taiwan’s Energy Administration (under MOEA) issued a revision to the rules governing Energy Label Certification for drinking water equipment. Along with a set of technical updates, the regulation itself was renamed to reflect a wider product category. Manufacturers have some breathing room before they need to comply, since the new rules don’t actually take effect until January 1, 2028.

It’s worth remembering that this certification is voluntary and sits separately from the BSMI and NCC schemes. It simply allows manufacturers to display the energy label logo once a product meets the required energy consumption benchmarks. Because CNS 3910 runs on its own timeline and its own logic, it’s best tracked as a distinct workstream rather than folded into other Taiwan compliance efforts.

A Wider Scope for Covered Products

Previously, the CNS 3910 regulation only applied to “cold-hot drinking water dispensers.” Under the revision, it now covers “drinking water supply machines,” a broader category that pulls more product variations into scope.

To qualify, a product must either comply with CNS 3910 or be approved by the relevant authority. This is the first thing worth checking before anything else, since every other change in this CNS 3910 revision only matters once a product is confirmed to fall within this expanded scope.

Tighter Testing Standards Under CNS 3910

The revision also spells out, in much more detail than before, exactly how test results should be measured and rounded:

• 24-hour standby energy loss (E24): measured in kWh, rounded to 3 decimal places
• Hot and cold water temperatures (Th, Tc): measured in °C
• Tank capacity (hot and cold water systems): measured in liters, rounded to 1 decimal place

On top of these measurement rules, the energy consumption benchmark (E) is now calculated through a formula based on declared tank capacities (V1 for hot water, V2 for cold water), with the result rounded to 3 decimal places. Together, these details give manufacturers and labs a clear, consistent way to evaluate products across different tank sizes.

A New Two-Part Rule for E24

To close a gap in the old CNS 3910 rules, the revision now sets out a clear two-part test that products have to pass:

1. The measured E24 value cannot be higher than the declared value.
2. Neither the measured value nor the declared value can be higher than the benchmark.

Both conditions have to hold at the same time. In practice, this means a product can’t pass certification just because its test result looks good on paper — the declared value printed on the label has to independently meet the benchmark as well.

Stricter Labeling Requirements

CNS 3910 Labeling requirements have also been tightened, with a few new disclosures now mandatory:

• The certificate holder’s name and address must appear on the product or packaging.
• If the certificate holder is an agent or distributor (not the manufacturer), the manufacturer’s name and address must also be shown.
• The product catalog must display the E24 value.

Key Takeaways

• The category rename, from “dispensers” to “supply machines,” is the biggest change. It widens which products fall under this certification.
• Test reports should follow the new rounding rules (3 decimals for E24 and the benchmark, 1 decimal for tank capacity).
• Recalculate the benchmark for any product using the new V1/V2 formula.
• Check that both measured and declared E24 values meet the benchmark, not just one.
• Update packaging and catalogs to show manufacturer details (for agents/distributors) and the E24 value.
• Track this separately from BSMI and NCC compliance, since it’s a different, voluntary scheme.

Source

https://gazette.nat.gov.tw/EG_FileManager/eguploadpub/eg032105/ch04/type2/gov31/num9/Eg.pdf