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From October 1, 2020, the obligation to inspect air-conditioning systems and heat pumps over 12 kW will be replaced by obligations to maintain and inspect thermodynamic systems, according to their output and by building.
As the scope is broader, equipment that was not previously subject to inspection is now covered by the maintenance or inspection obligation (e.g. office air-conditioning or industrial applications).
We suggest you take stock of these new obligations to determine whether your equipment (air-conditioning systems, heat pumps, etc.) is affected, and within what timeframe.
What are thermodynamic systems?
It's a system that uses a thermodynamic cycle to transfer heat between the surrounding environment and a building or industrial application, in order to heat or cool the indoor air.
Examples of thermodynamic systems: heat pumps (PAC), air conditioners, collective thermodynamic water heaters, etc.
They can be found in offices, cleanrooms, laboratories, computer servers and cold stores.
Several thermodynamic machines delivering cooling or heating to the same building are considered as a single system.
What is rated power?
This is the higher of the heating and cooling capacities of the thermodynamic system, as declared by the manufacturer and measured under the nominal performance conditions defined in EN 14511. These data are generally indicated in the equipment's technical documentation.
When several thermodynamic machines deliver cooling or heating to the same building, the whole is considered as a single system, with a power rating equal to the sum of the individual power ratings.
What are the inspection requirements for thermodynamic systems with a rated output of between 4 kW and 70 kW?
A service visit by a qualified person is mandatory every 2 years for thermodynamic systems with an output of between 4 kW and 70 kW. For new or replacement systems, the first service must be carried out no later than 2 years after commissioning.
Note: thermodynamic systems designed solely to produce hot water for a single dwelling are excluded.
For individual thermodynamic systems, maintenance is the responsibility of the occupant (e.g. tenant, unless otherwise stipulated in the lease). For collective thermodynamic systems, maintenance is the responsibility of the owner or co-ownership association.
Audit content
This maintenance visit includes :
- Checking the system and, if necessary, cleaning and adjusting it;
- advice on the proper use and possible improvements of the heating or air-conditioning system, as well as on whether it should be replaced;
- A tightness check of the refrigerant circuit (*) and, if necessary, a check of the refrigerant sight glass and compressor inlet and outlet pressure readings on the pressure gauges.
(*) not mandatory for equipment containing at least 5 tonnes C02 equivalent of fluorinated greenhouse gases already subject to leak testing.
Documentation
A certificate must be issued to the operator by the person who carried out the maintenance within 15 days. It can be provided in electronic form.
Note: a maintenance certificate is provided for each system serviced in the case of a building, part of a building or premises with several thermodynamic systems.
What are the inspection requirements for thermodynamic systems with a rated output of over 70 kW?
An inspection is mandatory every 5 years, at the initiative of the building's owner or co-ownership association. It must be carried out by a person certified by an accredited body, until December 31, 2024. From January 1, 2025, the inspection must be carried out by an accredited body.
Note that ventilation systems combined with Joule-effect heating with a rated output of over 70 kW are also subject to this inspection.
The periodicity can be increased to 10 years if the site's activity is covered by an ISO 50001-certified energy management system, and if 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 on July 1, 2020 :
- the first maintenance is due before July 1, 2022 if concerned ;
- 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 (CPE) that meets the criteria set by the decree of July 24, 2020.
For sites whose main activity is cold storage, ISO 50001 certification is maintained in lieu of periodic inspection.
Conclusion
Equipment not previously subject to inspection may now be subject to maintenance or inspection obligations, even if its output is less than 4 kW.
We recommend :
- make an inventory of all your thermodynamic equipment (air conditioners, heat pumps, etc.), noting their power ratings;
- sum these power ratings by building to obtain the power rating of each system;
- where applicable, schedule a maintenance visit before July 1, 2022 or an inspection before July 1, 2025, depending on capacity, for systems in place on July 1, 2020;
- include these checks in your schedule of mandatory inspections.
Reminder: boilers are subject to other inspection requirements.