Major Retrofitting Works

Frequently Asked Questions

1.What are “major retrofitting works”?
There are two major types of “major retrofitting works” defined in Schedule 3 of the Ordinance, including:
1. addition or replacement of a building services installation in the retrofitting works covering an internal floor areaⁱ of not less than 500m² ⁱⁱ in a unit or a common areaⁱⁱⁱ, where a building services installation means either (as elaborated in Section 10 of the latest edition of the Building Energy Code). (Notes:
  1. Please refer to Section 2 of the Building Energy Code for the interpretation of “internal floor area”. The internal floor area should be measured per unit or common area but not lumped together across more than one unit or common area.
  2. In other words, retrofitting works inside a unit or a common area of an internal floor area less than 500 m² will not fall within the scope of “major retrofitting works”.
  3. Please refer to Note (1) in Schedule 3 of the Ordinance for the identification of “a common area”.)
2. addition or replacement of a main component of the central building services installation^iv, where a main component means either –
  1. a complete electrical circuit at rating 400A or above, (note: “complete electrical circuit” meaning switch plus cable but not only cable or a single switch),
  2. a unitary air-conditioner or a chiller of a cooling rating or a heat pump of heating rating at or exceeding 350kW (note: only counting a single air-conditioner or chiller, but not a plant), or
  3. a motor drive plus mechanical drive of a lift, escalator or passenger conveyor (note: not including only a motor drive or only a mechanical drive).
Type A only applies to individual units or common areas while type B only applies to central building services installations. Meeting either type A or type B, plus either one of the corresponding conditions elaborated in the 2^nd and/or 3^rd columns from the left of Table 10.1 in Section 10 of the latest edition of the Building Energy Code, will be regarded as major retrofitting works. Moreover, for each type of the major retrofitting works listed in the 2^nd and/or 3^rd columns from the left of the Table, the corresponding BEC requirement(s)/clause(s) required to be complied with is/are listed in the 1^st and/or 2^nd columns from the right of the Table. For further detailed requirements and conditions, please refer to Schedule 3 of the Ordinance and the technical elaboration in Section 10 of the Building Energy Code. Please also consult engineering professionals (e.g. Registered Energy Assessors under the Ordinance) if necessary.
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2.If a piece of retrofitting works is carried out in phases in a unit or common area and each phase covers an internal floor area less than 500m², will the retrofitting works be regarded as “major retrofitting works”?
Pursuant to Schedule 3 of the Ordinance, if the internal floor areas covered by various phases of the retrofitting works add up to not less than 500m² within 12 months, the retrofitting works will still be regarded as “major retrofitting works”. For further detailed conditions, please refer to Schedule 3 of the Ordinance and the technical elaboration in Section 10 of the latest edition of the Building Energy Code.
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3.If a piece of retrofitting works covers an internal floor area not less than 500m² in a unit or common area but no building services installation is involved except painting, replacement of wall paper, replacement of carpet or replacement of fixed furniture etc., will the retrofitting works be regarded as “major retrofitting works”?
No. Only if the addition or replacement of a building services installation is involved, the retrofitting works will likely, but not necessarily, be regarded as “major retrofitting works”. For the detailed scopes and conditions, please click here and refer to Section 10 of the latest edition of the Building Energy Code.
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4.If a piece of retrofitting works covers an internal floor area not less than 500m² in a unit or common area but no building services installation is involved except replacement of a few fluorescent tubes, will the retrofitting works be regarded as “major retrofitting works”?
No. Only the addition or replacement of building services installations to a certain scale will be regarded as “major retrofitting works”. Indeed, it is specified in the Section 10 of the latest edition of the Building Energy Code that only the addition or replacement of either one of the following building services installations in a piece of retrofitting works covering an internal floor area not less than 500m² in a unit or common area will be regarded as “major retrofitting works”:
1. luminaires with the sum of rated wattage not less than 3kW (for example, equivalent to about 200 nos. 15W compact fluorescent lamps or over 90 nos. standard T5 fluorescent tubes of 1.2m);
2. air handling unit(s), unitary air-conditioner(s), VRF system(s), heat pump(s) and/or chiller(s) with the sum of cooling/heating capacity not less than 60kW (for example, equivalent to about 17 nos. 1.5hp air-conditioners); or
3. a motor drive and mechanical drive of a lift, escalator or passenger conveyor.
For further detailed conditions, please refer to Section 10 of the latest edition of the Building Energy Code.
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5.If the “major retrofitting works” are commenced before 21 September 2012 and will be completed on or after that day, is it compulsory to comply with the Building Energy Code (BEC)?
Yes. Please refer to the relevant soft reminder for major retrofitting works at the webpage of the Ordinance where you may also find other useful information about the Ordinance including the statutory requirements for major retrofitting works. On the contrary, if the retrofitting works are completed on or before 20 September 2012, the compliance with the BEC is not mandatory.
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6.When “major retrofitting works” are regarded as completed?
Pursuant to Section 17(3) of the Ordinance, “major retrofitting works” are regarded as completed when all the building services installations involved in the works are ready to be used for its principal function as designed. For example, if lighting installation, electrical installation and air-conditioning installation are involved in the works and the air-conditioning installation is the last completed, the works are regarded as completed when the air-conditioning installation has also been ready to be put into normal operation. In practice, a certificate of completion issued by the works consultant or contractor, if available, may be regarded as a documentary evidence for the completion date of the works.
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7.Who is the responsible person of major retrofitting works?
Normally, in respect of a unit, owner, tenant or occupier is regarded as the “responsible person”, depending on who occupies or is in possession or control of the unit as at the completion of the major retrofitting works. In respect of a common area or central building services installation, the “responsible person” should be the owner, i.e. the Owners' Corporation, or all individual owners if no such organization.
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8.In a common area with the gross floor area of not less than 500m², it is intended to replace the existing fluorescent tubes by LED tubes or T8/T5 conversion kits while the existing fittings will remain unchanged. Does this retrofitting work fall into the scope of “major retrofitting works”?
Pursuant to Schedule 3 of the Buildings Energy Efficiency Ordinance and Table 10.1 in Section 10 of the latest edition of the Building Energy Code (BEC), works will be regarded as "major retrofitting works" under the Ordinance provided that they involve addition or replacement of luminaires and cover a total internal floor area of not less than 500 m², plus the total circuit wattage of the luminaires involved exceeding 3kW and the works meeting either one of the corresponding conditions elaborated in the 2^nd and/or 3^rd columns from the left of the Table 10.1 as well. Moreover, pursuant to the interpretation of "luminaire" in Section 2 of the BEC, a luminaire should include lamp(s), controlgears, if applicable, and all necessary components for fixing and mechanical protection of lamps.

In this case, the works involve replacement of lamps or addition of conversion kits only and therefore are not regarded as major retrofitting works.
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9.After a Registered Energy Assessor’s signature of a Form of Compliance (Form EE4), what documents should be delivered by the Registered Energy Assessor to different parties?

Parties	Documents to be submitted
Responsible person of the relevant unit / common area / central building services installation	Original of the full set of Form EE4, Form EE-SU, all relevant Technical Forms and all associated supporting documents
Electrical and Mechanical Services Department	Copy of the full set of Form EE4, Form EE-SU, all relevant Technical Forms and all associated supporting documents
Property management company (or if none, building owner)	Copy of Form EE4 only

10.Shall the submission of FOC be required for the following case?
For a case of an A&A works in a hotel, the project is separated into different phases in separate package. The construction area of 1st phase is larger than 500 m². The works are located at typical floor and the FOC submission for 1st phase was submitted. The construction area of 2nd phase is less than 500 m². The works are located at a non-typical floor. Should the works be treated as the same series of works within 12 months? Shall the submission of FOC is required for 2nd phase?
Pursuant to Item 1 of Schedule 3 of the BEEO, retrofitting works involving BSIs that covers more places with total floor area of 500m² or above under the same series of works within 12 months in a prescribed building is regarded as major retrofitting works and should be covered by a FOC. The “relevant factors” as prescribed under Note (3) of Schedule 3 of the BEEO should be the reference to determine whether the works under the "1st phase" and the "2nd phase" should be regarded as being under the same series of works.

TG-BEC provides further guidance that, for the purpose of counting the 500 m² works areas, all the works conducted at the various places within a unit or a common area are considered under the same series of works if the works are treated as a single project in the plans and works programme even though those works are carried out by different contractors being assigned under different agreements and paid under different works order.

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11.In according with the Building Energy Code 2015, shall the submission of FOC is required for the following case?
Regarding to the new retrofitting work, building owner / developer has all New Luminaires hanged up and fixed on the false ceiling at a vacant office unit. The total rated power of all new luminaires are over 3kW. The office unit area is over 500sqm. No conduit and wiring work have been installed and connected to any of luminaires at the area. The luminaires is individually hang on the true ceiling and without any electric wiring connection with other luminaires. The building owner / developer has not any obligation for any installation of electrical wiring and connecting of electric circuit for the vacant office. All luminaires are the provision item for a vacant office unit. All wiring and electrical installation work shall be done by the future tenant.

Pursuant to Section 2 of the BEEO, luminaires installed at false ceiling without any connection of power supply, wiring and control is not regarded lighting installation. Therefore, submission of Form of Compliance for such luminaires is not required at this stage. The building owner / developer should remind the future tenant on the requirements of MRW and submit relevant statutory document (i.e. FOC) timely after the installation work is completed. For further detailed information, please refer to Clause 10.1.8 of the TG-BEC2015.

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12.Is the works involving replacement of lift mechanical drive and lift motor only (existing control panel is kept) regarded as "major retrofitting works"?

Pursuant to BEC Table 10.1 (b) (iii), addition or replacement of both the motor drive and mechanical drive of a lift, an escalator or a passenger conveyor is regarded as major retrofitting works (MRW). For the definition of mechanical drive, please refer to Section 2 (Interpretations and Abbreviations) of the Building Energy Code. Replacement of lift motor without involving the driving controller is not regarded as replacement of motor drive, by definition, and the works is therefore NOT regarded as MRW. The Form of compliance submission is thus not required.

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13.Is replacement of the outdoor units only of an existing VRF system with the system total cooling capacities of or above 60kW regarded as "major retrofitting works"?

Given the involved works area and equipment capacity exceeding 500m2 and 60kW respectively, the BEC refers the MRW as the addition or replacement of air handling unit, unitary air-conditioner and/or chiller. Therefore, for any works involving replacement of the outdoor condenser only, by definition, is not regarded as the MRW under the BEC.
Care should be taken that, according to the requirements set out in section 12(3) and section 18(2) of the BEEO, if a COCR/FOC had been issued in respect of the air-conditioning installation of that building/building unit, the owner of the building (or the owner of the installation) /responsible person of the building unit must maintain the installation to a standard not lower than that applied in that COCR/FOC. In the other words, the replaced outdoor condenser(s), when working with the existing indoor units, shall comply with the relevant energy efficiency requirements prescribed under the BEC edition stated in the COCR/FOC.

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