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As of October 1, 2020, the inspection requirement for air conditioning and heat pump systems over 12 kW is replaced by maintenance and inspection requirements for thermodynamic systems based on their power output and per building.
The scope is now broader; equipment that was not previously subject to inspection is now covered by the maintenance or inspection requirement (e.g., office air conditioning or industrial applications).
We invite you to review these new requirements to determine if your equipment (air conditioning systems, heat pumps, etc.) is affected and within what timeframe.
What are thermodynamic systems?
It is a system that uses a thermodynamic cycle to transfer heat between the surrounding environment and a building, or an industrial application, to heat or cool the indoor air.
Examples of thermodynamic systems : heat pumps (HP), air conditioners, collective thermodynamic water heaters, etc.
They can be found in offices, clean rooms, laboratories, computer servers, and cold storage warehouses.
Several thermodynamic machines that provide cooling or heating within the same building are considered a single system.
What is nominal power?
It is the higher value between the heating capacity and the cooling capacity of the thermodynamic system, declared by the manufacturer and measured under the nominal performance conditions defined in standard EN 14511. These data are generally indicated in the equipment's technical documentation.
When several thermodynamic machines provide cooling or heating within the same building, the entire setup is considered a single system whose nominal power is equal to the sum of the individual nominal powers.
What are the inspection requirements for thermodynamic systems with a nominal power between 4 kW and 70 kW?
A maintenance visit by a qualified person is mandatory every 2 years for thermodynamic systems with a power output between 4 kW and 70 kW. For new or replaced installations, the first maintenance must be carried out no later than 2 years after commissioning.
Note: Thermodynamic systems intended solely for hot water production for a single dwelling are excluded.
This maintenance is initiated by the occupant (e.g., tenant, unless the lease specifies otherwise) for individual thermodynamic systems, and by the owner or co-ownership association for collective thermodynamic systems.
Scope of Inspection
This maintenance visit includes:
- a system inspection and, if necessary, its cleaning and adjustment;
- advice regarding proper use and possible improvements to the heating or air conditioning system, as well as the potential benefit of replacing it;
- A leak check of the refrigerant circuit (*) and, where applicable, a check of the refrigerant sight glass and recording of compressor inlet and outlet pressures on the gauges.
(*) not mandatory for equipment containing at least 5 tonnes CO2 equivalent of fluorinated greenhouse gases already subject to leak checks.
Documentation
A certificate must be provided to the operator by the person who performed the maintenance within 15 days. It can be provided in electronic format.
Note: a maintenance certificate is provided for each system that has undergone maintenance in the case of a building, part of a building, or premises comprising several thermodynamic systems.
What are the inspection requirements for thermodynamic systems with a nominal power greater than 70 kW?
An inspection is mandatory every 5 years, initiated by the owner or the building's co-ownership association. It must be carried out by a person certified by an accredited body until December 31, 2024. As of January 1, 2025, the inspection will be carried out by an accredited body.
Note that ventilation systems combined with Joule effect heating with a nominal power greater than 70 kW are also subject to this inspection.
The frequency can be extended to 10 years if the site's activity is covered by an energy management system certified compliant with ISO 50001 and this system covers the thermodynamic system or the ventilation system combined with Joule effect heating.
For new or replaced installations, the first inspection must be carried out no later than 5 years after commissioning.
What are the deadlines for existing equipment?
For installations existing as of July 1, 2020:
- the first maintenance must be carried out before July 1, 2022, if applicable;
- the first inspection must be carried out before July 1, 2025, if applicable.
Are exemptions possible?
Yes, if the equipment is covered by an Energy Performance Contract (EPC) that meets the criteria set by the decree of July 24, 2020.
For sites primarily dedicated to refrigerated storage, maintaining ISO 50001 certification serves as periodic inspection.
Conclusion
Equipment not previously subject to inspection may now be covered by maintenance or inspection obligations, even if their power is less than 4 kW.
We advise you to:
- inventory all your thermodynamic equipment (air conditioners, heat pumps, etc.) noting their nominal power;
- sum these nominal powers per building to determine the nominal power of each system;
- where appropriate, schedule a maintenance visit before July 1, 2022, or an inspection before July 1, 2025, depending on the power for systems installed as of July 1, 2020;
- incorporate these checks into your mandatory inspection schedule.
Reminder: boilers are subject to other inspection obligations.