EU – Draft Ecodesign Regulation for Servers and Data Storage Products

The European Commission has notified the WTO of a draft ecodesign regulation for servers and data storage products.  The draft regulation is the outcome of the original Lot 9 study under the Ecodesign Directive which started in 2013. It follows several years of work by the Commission, EU member state representatives, consultants, and industry consultations to develop a workable regulation.  The scope of the draft regulation is limited to specific types of servers and storage products and specifically excludes server appliances. However, the draft regulation does continue the Commission`s direction of including ecodesign requirements that go beyond just energy efficiency.

Description of content: This draft Commission Regulation sets compulsory requirements on the energy efficiency (such as minimum efficiency of the internal power supply unit) as well as on the material efficiency (such as the ability of certain components to be disassembled) of servers and data storage products. In accordance with Framework Directive 2009/125/EC, products not meeting these requirements will not be allowed to be placed on the EU market.

The draft Regulation is based on the findings of technical, environmental and economic studies which have been carried out with stakeholders from around the world.

The original intention was to implement a regulation that would cover all computer servers and storage products, but a methodology and metric that is applicable to all such products has eluded the regulator and their consultants.  As a result, the draft regulation, Article 1 (Subject matter and scope) establishes the scope as:

  1. This Regulation establishes ecodesign requirements for placing on the market and putting into service of servers and online data storage products.
  2. This Regulation shall not apply to the following products:

(a) servers intended for embedded applications;
(b) servers classified as small scale servers in terms of Regulation (EU) No 617/2013;
(c) servers with more than four processor sockets;
(d) server appliances;
(e) large servers;
(f) fully fault tolerant servers;
(g) network servers;
(h) small data storage products;
(i) large data storage products.

Definition of Server

The definition of server is provided in Article 2, Definitions as:

(1) ‘server’ means a computing product that provides services and manages networked resources for client devices, such as desktop computers, notebook computers, desktop thin clients, internet protocol telephones, smartphones, tablets, tele-communication, automated systems or other servers, primarily accessed via network connections, and not through direct user input devices, such as a keyboard or a mouse and with the following characteristics:

(a) it is designed to support server operating systems (OS) and/or hypervisors, and targeted to run user-installed enterprise applications;

(b) it supports error-correcting code and/or buffered memory (including both buffered dual in-line memory modules and buffered on board configurations);

(c) all processors have access to shared system memory and are independently visible to a single OS or hypervisor;

For clarity, Article 2 defines several other related terms such as server appliance, resilient server, large server, network server, etc.

(3) ‘server appliance’ means a server that is not intended to execute user-supplied software, delivers services through one or more networks, is typically managed through a web or command line interface and is bundled with a pre-installed OS and application software that is used to perform a dedicated function or set of tightly coupled functions.;

 Ecodesign Requirements

The technical requirements that need to be met by servers and online storage products are specified in Annex II to the regulation.

Three conformance dates are specified; the initial set of requirements need to be met by March 1, 2020, followed by stricter and/or additional requirements in 2021, 2023, and 2026.

Table 3: Compliance Dates for Ecodesign Requirements of Servers and Storage Products

Compliance DateRequirements
March 1, 2020Annex II points 1.1.1, 1.2.1, 1.2.2, 2.1, 3.1, 3.3 and 3.4
March 1, 2021Annex II point 1.2.3
January 1, 2023Annex II point 1.1.2
January 1, 2026Annex II point 1.1.3

The draft regulation specifies requirements on:

  • Power Supply Efficiency (some of the requirements align with EnergyStar and others do not)
  • Idle State Power requirements
  • Material efficiency requirements (addressing disassembly secure data deletion and firmware upgrades)
  • Information to be provided by manufacturers

Furthermore, subsection 3.3 identifies information that manufacturers, authorized representatives, and importers need to make available information on the quantity of Cobalt in batteries and neodymium in HDDs and to provide disassembly instructions for the major components.

Overall, it seems that the Commission intends to persuade manufacturers to provide a high degree of transparency with information on product efficiency to potential customers, end-users, and recyclers.

Server Efficiency

The draft regulation refers to “server efficiency” and requires a server efficiency metric to be reported. It’s defined as the ratio of performance divided by power, Article 7 on “review” suggests that a minimum requirement may be set in the future.

ECD Compliance has produced a more detailed summary of the requirements and timeline.  Please contact ECD Compliance for additional information.