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Technology · Liquid cooling · Explainer · updated 1 Nov 2026

Secondary cooling loop regulation: how the CDU controls it, and the rules that apply

In a liquid-cooled data centre the secondary loop, or technology cooling system (TCS), carries coolant from the coolant distribution unit (CDU) to the cold plates on the chips. This page explains how that loop is regulated (temperature, dew point, flow, pressure, coolant chemistry, filtration and leak detection) and which rules and guidelines apply to it. For engineers, operators, buyers and consultants. Facts only, each linked to its source.

Two loopsHow it is regulatedASHRAE classesRulesChecklistQuestions

2 °C

minimum margin above room dew point that the CDU keeps the secondary (TCS) supply at, to stop condensation (ASHRAE TC 9.9 guidance)

Source: ASHRAE TC 9.9 (opens in a new tab)

~25%

propylene glycol in PG25, the common secondary-loop coolant (24.5% to 27.5% by volume, OCP guideline, Sept 2026)

Source: Open Compute Project (opens in a new tab)

500 kW

installed IT power from which EU data centres must report water use, reused heat and waste heat temperature every year

Source: EUR-Lex (opens in a new tab)

Flag of Germany

10%

minimum share of reused energy for German data centres that start operating from 1 July 2026 (EnEfG section 11)

Source: Gesetze im Internet (German Federal Ministry of Justice) (opens in a new tab)

Primary and secondary loops in plain words

Facility water system (FWS)
The primary loop. It carries heat from the CDUs to chillers, cooling towers, dry coolers or a heat network.
Technology cooling system (TCS)
The secondary loop. A closed loop from the CDU to the cold plates or heat exchangers at the IT equipment, with cleaner, controlled coolant.
Coolant distribution unit (CDU)
The box between the two loops. Its liquid-to-liquid heat exchanger keeps the fluids apart, and its pumps, valves, filters and sensors regulate the secondary side.
Dew point
The temperature at which moisture in the room air condenses. Coolant below it would make pipes and cold plates wet.
PG25
A common secondary coolant: about 25% propylene glycol in water with corrosion inhibitors.
Primary and secondary loops: where the CDU regulates
Chillers,dry coolers orheat networkCDUheat exchanger,pumps, valves,filters, sensorsIT racks withcold plates(CPUs, GPUs)Primary: facility water (FWS)Secondary: TCS supplyTCS return (warmer)FWS return12345

Our drawing, simplified, after ASHRAE TC 9.9's description of a CDU separating the facility water system from the technology cooling system. Real systems add redundancy, expansion tanks and bypasses. ASHRAE TC 9.9: Water-Cooled Servers: Common Designs, Components, and Processes (white paper) (opens in a new tab)

How the secondary loop is regulated: five things the CDU and operator control

Flow and pressure

Pumps in the CDU drive the secondary flow, and valves set it for each rack. One rack heat exchanger guide (IBM) sets a 23 to 38 litres a minute flow range, recommends adjustable flow valves on supply lines and requires a relief valve so loop pressure stays below 689.66 kPa (100 psi). Limits differ by product, so use the figures in your own equipment manual.

Source: IBM Documentation: Water specifications for the secondary cooling loop (rear door heat exchanger) (opens in a new tab)

Leak detection and alarms

The secondary loop runs inside the white space, so leaks matter. Lenovo's rack heat exchanger guide asks operators to consider leak detection on the loop that feeds it, and OCP recommends in-line sensors with set operating limits and actions.

Source: Lenovo Docs: Water specifications for the secondary cooling loop (ThinkSystem Heavy Duty Rack Cabinets) (opens in a new tab); Open Compute Project: Guidelines for using propylene glycol-based heat transfer fluids in liquid cooled racks, revision 2.0 (opens in a new tab)

ASHRAE W classes: how warm the facility water can be

ASHRAE liquid cooling classes: highest facility water supply temperature (°C) Industry guidance

W classes set the facility (primary) water temperature the IT equipment must accept at full performance. The minimum for every class is 2 °C. W+ (above 45 °C) has no upper limit, so it has no bar. ASHRAE lists it as typically run without chillers, with district heating as the typical heat user.

Source: ASHRAE: Thermal Guidelines for Data Processing Environments, 5th edition: reference card (Table 3.1, liquid cooling classes) (opens in a new tab) Accessed 1 Nov 2026.

Show the data as a table
ClassHighest supply temperatureTypical heat rejection (ASHRAE)
W1717 °CChiller and cooling tower, optional water-side economiser
W2727 °CChiller and cooling tower, optional water-side economiser
W3232 °CMostly without chillers, some sites still need them
W4040 °CMostly without chillers, some sites still need them
W4545 °CUsually without chillers, dry coolers where the climate allows
W+Above 45 °CTypically without chillers, district heating

Rules and guidelines that apply

Laws are marked as law, industry documents as guidance. This page covers EU and German rules plus global guidance. It is general information, not legal advice. Checked 1 Nov 2026.

WhereRule or guidelineWho it coversWhat it asks forTypeSource
European UnionDelegated Regulation (EU) 2024/1364 (Energy Efficiency Directive reporting) · our policy pageOperators of data centres with installed IT power of 500 kW or moreReport each year by 15 May: total and drinking water input, waste heat reused outside the site, average waste heat temperature (measured where the fluid that cools the IT enters the heat exchanger at the computer room boundary), refrigerants used, and energy figures. Records of measurement points must be kept for 10 years.Law in forceEUR-Lex: Commission Delegated Regulation (EU) 2024/1364 on the first phase of a common Union rating scheme for data centres (opens in a new tab)
Flag of Germany GermanyEnergy Efficiency Act (EnEfG) section 11 · our policy pageData centres with 300 kW or more of non-redundant connected loadNew sites from 1 July 2026: PUE 1.2 or lower and at least 10% reused energy (15% for sites from July 2027, 20% from July 2028). Existing sites: PUE 1.5 from July 2027 and 1.3 from July 2030. Warm secondary loops make heat easier to reuse. An amendment bill is before the Bundestag.Law in force, amendment proposedGesetze im Internet (German Federal Ministry of Justice): Energieeffizienzgesetz (EnEfG) section 11: Klimaneutrale Rechenzentren (opens in a new tab)
GlobalASHRAE TC 9.9 liquid cooling classes (W17 to W+)Designers, operators and IT makersDefines facility water supply temperature classes and the CDU's role in separating the facility water system from the technology cooling system. Industry guidance, not law, but often written into specifications and contracts.Industry guidanceASHRAE: Thermal Guidelines for Data Processing Environments, 5th edition: reference card (Table 3.1, liquid cooling classes) (opens in a new tab)
GlobalOCP guidelines for PG25 heat transfer fluids, revision 2.0 (September 2026)Design engineers, operators, CDU, cold plate and fluid suppliersCoolant properties, wetted materials, flushing and fill, filtration, sampling frequency and in-line monitoring for the secondary loop between CDU and cold plates. Guidance, not law.Industry guidanceOpen Compute Project: Guidelines for using propylene glycol-based heat transfer fluids in liquid cooled racks, revision 2.0 (opens in a new tab)
European UnionPressure Equipment Directive 2014/68/EUMakers and suppliers of stationary pressure equipment above 0.5 bar maximum allowable pressureCovers design, manufacture and conformity assessment. Whether a given CDU, manifold or pipework assembly falls under it depends on its pressure, volume and fluid, so ask the supplier for its conformity assessment.Law in forceEuropean Commission: Pressure Equipment Directive (2014/68/EU) (opens in a new tab)
European UnionF-gas Regulation (EU) 2024/573Operators of listed equipment containing fluorinated gases, relevant to two-phase loops that use a fluorinated refrigerantLeak checks every 3 to 24 months depending on charge and whether leak detection is fitted, records, certified technicians, and a phase-out of placing HFCs on the EU market by 2050. Single-phase water or PG25 loops contain no F-gas. Check how the rules apply to a specific product and refrigerant.Law in forceEuropean Commission: F-gases in equipment and products: stakeholder obligations (Regulation (EU) 2024/573) (opens in a new tab)
GlobalOCP Project Deschutes facilities specification and MQD/MQDB coupling specificationBuyers, designers and suppliers who adopt themVoluntary Open Compute Project specifications for liquid cooled facilities and quick disconnect couplings. They bind only when written into a contract.Industry guidanceOpen Compute Project: Project Deschutes: data center facilities specification (opens in a new tab)
Germany: minimum reused-energy share for new data centres, by first year of operation (%) Law in force

Section 11(2) of the Energy Efficiency Act (EnEfG) as in force on 1 November 2026. Sites have two years after commissioning to reach the share as an annual average. The 15% and 20% steps are planned shares for sites starting later, not targets for existing sites. A government bill (Bundestag printed paper 21/8027) would give four years instead of two and count some internal heat use. It is not law yet.

Flag of GermanyGermany

Source: Gesetze im Internet (German Federal Ministry of Justice): Energieeffizienzgesetz (EnEfG) section 11: Klimaneutrale Rechenzentren (opens in a new tab) Accessed 1 Nov 2026.

Show the data as a table
Data centre starts operatingMinimum reused-energy share
From 1 July 202610%
From 1 July 202715%
From 1 July 202820%

Proposed changes are tracked on the EnEfG amendment bill page and the EU's next step on the EU data centre rating scheme page.

Questions to settle before you buy or commission a secondary loop

Our checklist, drawn from the guidance above. It is not a design standard.

  1. Which W class does the IT equipment support at full performance, and which class is the facility water designed for?
  2. What supply temperature and dew point margin will the CDU control to, and what happens when the room dew point rises?
  3. What are the flow, differential pressure and maximum pressure limits for each rack, and where are the relief valves?
  4. Which coolant is specified (for example PG25 or treated water), who tests it, and how often?
  5. Is filtration sidestream or full flow, what micron rating, and can filters be changed without a shutdown?
  6. Where are the leak sensors, what alarms do they raise, and who responds?
  7. Who measures the waste heat temperature and reused heat for EU reporting, and at which meter?

Start a CDU requirement brief Compare CDU suppliers

Watch: liquid cooling loops

Official videos from the companies' own channels, shown side by side for balance. CoolPower Index does not endorse either. They load from YouTube only when you press play.

AI Data Center Liquid Cooling: End-to-End High-Density Solutions | Schneider Electric Schneider Electric on YouTube. Watch on YouTube
Liquid cooling for NVIDIA GPU workloads Vertiv on YouTube. Watch on YouTube

Common questions

What is secondary cooling in a data centre?

It is the closed pipe loop that carries liquid straight to the hot computer chips and back, like the coolant in a car engine.

Why it matters A heat exchanger in the coolant distribution unit (CDU) passes the heat to the building's own water loop, without the two liquids mixing.

Source: ASHRAE

How is the secondary cooling loop regulated?

A machine called the CDU keeps the liquid at the right temperature and flow, filters it and raises alarms if something goes wrong.

Why it matters It keeps the liquid just warm enough to stop water droplets forming on the electronics, like mist on a cold glass.

  • At least 2 °C above the room's dew point
  • Lab test of the liquid at least once a year

Source: ASHRAE TC 9.9, OCP

Is there a law for secondary cooling loops?

Not for the loop itself. But EU and German rules make larger data centres report water, waste heat and energy use.

  • EU reporting from 500 kW of IT power
  • Report due every 15 May

Source: EU Delegated Regulation 2024/1364, German EnEfG

What coolant is used in the secondary loop?

Usually PG25: water mixed with about a quarter propylene glycol (a kind of antifreeze) and chemicals that stop rust.

  • Around 25% propylene glycol

Source: OCP

What is the difference between W32, W40 and W45?

They are labels for the warmest water the computers can accept: 32, 40 or 45 °C. The warmer the water allowed, the less need for power-hungry chillers.

Why it matters Chillers work like a fridge. Warmer classes can often cool with outside air instead.

  • W32: 32 °C
  • W40: 40 °C
  • W45: 45 °C

Source: ASHRAE

Coverage limits: product limits (flow, pressure, temperature) differ by maker, so the IBM and Lenovo figures are examples only. This page does not cover national rules outside the EU and Germany. Photo: Unsplash. Flags: flag-icons (MIT licence). Charts: Apache ECharts (Apache 2.0). Related: Coolant distribution units (CDUs) · Direct liquid cooling · Warm-water cooling loops · Heat reuse · Policy tracker.

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