A data-centre cooling system depends on more than the equipment inside the server room. Heat must move from IT equipment through cooling loops and facility systems before it can be rejected outside. Each part has its own equipment, operating requirements and documentation.

That makes supply planning a system-level task. A CDU, facility water loop, chiller or dry cooler may each play a different role in a design. Refrigerant supply and F-gas compliance add further requirements where the system uses covered gases or includes imported pre-charged equipment.

This does not mean that every data-centre project will face a shortage or delivery delay. Those outcomes cannot be inferred from system complexity alone. It does mean operators benefit from understanding the dependencies in their own design and confirming the relevant supply and compliance arrangements before equipment is needed.

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Cooling depends on connected systems

In liquid-cooled data centres, heat moves from IT equipment into a technology cooling loop. A coolant distribution unit transfers heat between that loop and the facility water system. The facility then needs a way to reject the heat, which may involve dry coolers, chillers or other equipment.

NVIDIA’s DSX facilities reference design illustrates one possible arrangement: a central utility building supplies facility water to CDUs and computer-room air handlers, while paired dry coolers reject heat to the atmosphere. NVIDIA also describes redundant CDU groups in mechanical galleries as part of that design. This is a particular reference architecture, not a prescribed configuration for every facility. NVIDIA DSX Documentation

The example shows why procurement teams need to understand the whole cooling chain. Ordering a CDU alone does not establish how heat will be rejected, which facility equipment will be needed, or how the systems will be controlled together. The cooling plant must align with the data-centre design.

NVIDIA’s facilities documentation describes cooling alongside power, controls, connectivity and compute as systems that require coordinated planning. For operators, that means cooling specifications should be connected to facility plans and procurement schedules, rather than treated as an isolated equipment purchase. docs.nvidia.com

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Start with a system and supplier map

A supply-chain review should begin with an equipment map. Record the components in the cooling architecture, where they sit, what each one does and which supplier or contractor is responsible for them. Include the CDU, chillers, dry coolers, pumps, heat exchangers, controls and relevant facility-water systems where these are part of the project.

The purpose is to identify dependencies that require coordination. For example, the CDU transfers heat from the IT-side cooling loop to a facility loop; the heat-rejection plant must then handle the heat received by the facility system. The required interfaces and operating conditions should be documented in the project’s engineering specifications.

This map should also show how individual responsibilities fit together. The equipment vendor, systems integrator, facilities contractor, refrigerant supplier and customs importer may be different parties. The project team should know which party provides each item, who is responsible for installation and commissioning, and who supplies compliance records.

This is a planning method, not a prediction of a specific delay. Its value is that a project can identify missing information and clarify responsibilities before installation or service work begins.

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Add refrigerant and compliance dependencies

Where a chiller or other equipment contains fluorinated gases, refrigerant becomes part of the supply plan. Operators should record the refrigerant type, charge and equipment location, then identify what is required for installation, maintenance or replacement.

For HFCs placed on the EU market, the F-gas Regulation sets a quota system for eligible producers and importers. From 2027, the maximum quantity for the EU market is 21,665,691 tonnes of CO₂ equivalent for the 2027–2029 period. The Commission allocates quota through its F-gas system; the cap does not itself tell an individual operator how much refrigerant will be available or what price a supplier will charge. eur-lex.europa.eu

The refrigerant record should therefore connect the equipment inventory to procurement. It should identify the gas required, the supplier, the quantity, the market where it will be placed, and which party is responsible for the applicable quota or authorisation. This helps the operator distinguish a technical requirement from a regulatory responsibility.

Where non-HFC gases are used, other F-gas requirements may still apply depending on the substance and equipment. The exact scope should be checked against the Regulation rather than inferred from a general label such as “refrigerant.”

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Import planning starts before customs

Equipment supply also includes regulatory steps at the border. Under the EU F-gas framework, importers of covered products or equipment containing fluorinated gases may need to register in the F-gas Portal before import. The Commission’s guidance identifies registration and other requirements for importers of refrigeration, air-conditioning and heat-pump equipment. Fluorinated Greenhouse Gases – Climate Action

The Regulation also specifies information for customs declarations. This includes the F-gas Portal registration identification number and the quantity expressed in tonnes of CO₂ equivalent for bulk gases and gases contained in products or equipment. Customs authorities use the system to check registration and compliance information. eur-lex.europa.eu

For project teams, this means the customs and compliance process should be included in import planning. Confirm who is named as importer, who holds the required portal registration, which documents must accompany the declaration, and whether the equipment’s F-gas content triggers quota coverage or authorisation requirements.

These checks are specific to the product and transaction. They should be completed using current requirements for the shipment route and the party’s role. A supplier’s statement that equipment is compliant does not by itself identify which undertaking is responsible for each import obligation.

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Keep documentation linked to the equipment

Compliance records are most useful when they can be matched to the actual equipment and refrigerant. A project file should include model and serial details where available, the refrigerant type and charge, supplier documents, import information, quota or authorisation evidence where required, and commissioning and service records.

The European Commission’s F-gas Portal is used for quota management, import and export requirements and reporting. It records organisation details, quota and authorisations, and is connected to the EU customs Single Window environment for customs checks. Fluorinated Greenhouse Gases – Climate Action

For operations teams, the goal is a clear link between the system installed on site and the records that support its purchase and servicing. This makes it easier to verify the refrigerant requirement during maintenance, identify the relevant supplier and confirm which party handled the compliance steps.

Documentation should also distinguish between equipment using HFCs and systems using other refrigerants. The quota rules apply to specified HFCs; other F-gas obligations may depend on the gas, equipment and activity involved. Keeping those categories clear helps avoid applying the wrong rule to a system.

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Build continuity into seasonal planning

Before a peak cooling period or planned expansion, operators can review their inventory and procurement file:

• Confirm the installed base. Check that the equipment list reflects the current systems and refrigerants at each site.

• Review planned work. Identify scheduled maintenance, known repairs and equipment replacements that have already been specified.

• Check supply responsibilities. Confirm the supplier, importer and party responsible for quota coverage or authorisations where applicable.

• Verify the import route. Ensure the importer, F-gas Portal registration and customs information are identified before shipment.

• Align equipment interfaces. Check that the CDU, facility cooling system and heat-rejection plant match the project specifications.

• Keep records accessible. Link refrigerant, equipment, import and service documentation so teams can retrieve the information when needed.

This review cannot guarantee equipment availability or eliminate every disruption. It does make requirements and responsibilities visible and gives procurement and facilities teams a shared basis for planning.

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Treat cooling as an end-to-end supply chain

Data-centre cooling depends on connected equipment, controls, refrigerant supply where applicable, and import and compliance processes. Planning one component without documenting its interfaces and dependencies leaves the wider system unclear.

Operators can reduce uncertainty by mapping the complete cooling architecture, confirming suppliers and responsibilities, and maintaining equipment-level records. The EU’s HFC quota and F-gas import rules add specific requirements that should be checked alongside the technical design.

AFS Cooling supports businesses with refrigerant procurement, quota management, compliance and documentation. To discuss refrigerant and supply planning for your cooling infrastructure, contact AFS Cooling.