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Please note: This article concerns French legislation. The requirements described may not apply in other countries.
As a reminder, thermodynamic systems existing as of 1st January 2020 must undergo:
- Maintenance every 2 years where their capacity is between 4 and 70kW (1st maintenance to be carried out before 1st July 2022), and at the latest within two years following its replacement or installation
- Or an inspection every 5 years where their capacity exceeds 70kW (1st inspection to be carried out before 1st July 2025), and at the latest within 5 years following the replacement or installation of the system. If the system is subject to inspection, it is not subject to maintenance.
- And a heating, ventilation and air conditioning logbook (HVAC logbook) for systems over 70kW. This gathers together data relating to the system, regardless of the capacity of the individual units connected, and must be presented during the inspection.
What is a thermodynamic system?
It is a system that uses a thermodynamic cycle to transfer heat between the surrounding environment and a building, or an industrial application, in order to heat or cool the indoor air.
The most common thermodynamic equipment/systems are:
- Heat pump (HP),
- Air conditioner
- Server room air-conditioning cabinet
- Data centre cooling
- Cold room
- Refrigerated warehouse
These examples are not exhaustive. They can be found in offices, clean rooms, laboratories, server rooms and warehouses. Boilers are not included, as they are subject to other inspection requirements.
What is it used for?
Cooling or heating indoor air (thermal treatment of a space in which a person is present). As a result, industrial processes that do not treat ambient air are not covered (e.g. a cooled electrical cabinet connected to a production machine, a drying tunnel, or a process water cooling system).
How do I calculate my system's capacity?
By adding together the capacities (heating and cooling) of all the equipment in a building, with no minimum threshold. Several thermodynamic units delivering cooling or heating within the same building are therefore considered to be a single system.
Note that the capacities of systems belonging to different owners are not to be added together.
Which capacity should be taken into account if my equipment both heats and cools?
It is the higher of the heating capacity and the cooling capacity of the thermodynamic system, as declared by the manufacturer and measured under the nominal performance conditions defined in standard EN 14511. This data is generally provided in the equipment's technical documentation.
Who can carry out the maintenance?
A qualified person (II of Article 16 of Law No. 96-603 of 5 July 1996)
Who can carry out the inspections?
Since 1st January 2025, only an accredited body may carry out these periodic inspections.
Can this 5-year frequency be adjusted? Are there any exemptions?
Yes, it can be extended to 10 years if the site's activity is covered by an energy management system certified in accordance with ISO 50001 and this system covers the thermodynamic system.
There are two exemptions to the periodic inspection requirement:
- if the system is covered by an energy performance contract (EPC) meeting the criteria set out in the order of 24 July 2020. In this specific case, the owner is also not required to have an HVAC logbook (although it is still recommended to centralise data relating to the system).
- If the site is ISO 50001 certified and its activity is mainly dedicated to cold storage.
What content is required?
Is there a link between the periodic inspection and the BACS decree obligations?
The BACS decree applies to systems that distribute cooling and heating in certain buildings, and aims to optimise their energy performance through the installation of a supervision system known as an “automation and control system”. The threshold for being subject to this installation requirement, set at 70kW, is also based on the combined capacity of the equipment present dedicated to the building; however, only tertiary buildings are taken into account, and boilers must be included in the calculation.
For more information on the BACS decree, feel free to consult our newsletter on the subject
What about mixed systems (comfort + industrial application)?
If the general rule does not allow you to easily determine these obligations, the Ministry's FAQ may answer some of your questions: