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

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.

Following the amendment in June of the EU Waste Framework Directive, the European Chemical Agency (ECHA) posted a press release on July 11^th acknowledging that it will develop a new database on “the presence of hazardous chemicals in articles by the end of 2019 for waste treatment operators and consumers”. Companies producing, importing or selling articles that contain REACH Candidate List SVHCs will need to submit information about the products and the SVHCs by the end of 2020.

With the metal lead (Pb) now included on the Candidate List, nearly all EEE products will need to be registered in the database. ECD Compliance will follow ECHA progress in developing the database and reporting regularly.

Manufacturers are reminded that the phthalates restrictions (DEHP, DBP, BBP, DIBP) in EEE products start to take effect in less than one year.  The date that a specific EEE product needs to comply depends on the product category as shown in Table 1. Phthalates have been commonly used in plastic materials, especially wire and cable sheathing, requiring many products to be redesigned to substitute the parts that are non-conformant.  Technical documentation files also need to be updated.

Placed on the Market

EEE products need to comply if they are “placed on the EU market” on or after the date that the restriction take effect. For imported products, “placed on the EU market”, typically refers to the import date.  If a manufacturer has a tight transition timeline for its products, it’ll be important to closely manage the inventory that is not phthalate-free to ensure that it’s placed on the market before the deadline.

Table 1: Date of phthalate restrictions based on product category

Phthalate substances and thresholds

The RoHS Directive (2011/65/EU), Annex II was amended by Delegated Directive (EU) 2015/863 to add the four phthalate substances. The substances and maximum concentration in homogeneous material are:

• Bis(2-ethylhexyl) phthalate (DEHP) (0,1 %)
• Butyl benzyl phthalate (BBP) (0,1 %)
• Dibutyl phthalate (DBP) (0,1 %)
• Diisobutyl phthalate (DIBP) (0,1 %)

Technical Documentation

The technical documentation files (as per EN 50581 or IEC 63000) will need to be updated to reflect the additional substances – even if no redesign was required, the technical documentation still needs to be updated with supplier documentation and other documentation to demonstrate that the four phthalates aren’t present.

ECD Compliance can provide support to manufacturers and suppliers in implementing IEC 63000 to develop technical document for a EEE product being imported into the EU or other jurisdictions with RoHS regulations.

The European Chemical Agency (ECHA), on June 27, 2018 added ten additional substances to the EU REACH Candidate List. The new SVHC entries are listed in Table 1. The IEC 62474 Validation Team has reviewed the substances for potential uses in EEE. The typical EEE applications (where applicable) are included in the table as are general uses (provided by ECHA).  There are now a total of 191 SVHCs on the REACH Candidate List.

Table 1: Ten SVHCs Added to REACH Candidate List

Impact on EEE manufacturers

The REACH communication obligations take effect immediately for the newly added SVHCs. Unfortunately, Given that the substance “Lead” was added, the update creates a particularly difficult challenge for EEE manufacturers who now need to disclose Lead as an SVHC.  Lead (as an element) is used in many EEE products (allowed under RoHS exemptions). Note: this specific SVHC entry is applicable to lead as a stand-alone element and not as compound and is relevant to lead in several RoHS exemptions.

The EEE Industry declarable substances list was updated on July 7, 2018 to reflect the new SVHCs that are relevant to the EEE products. Please see the article on the IEC 62474 update in IEC62474 blog http://rohs.ca/iec62474 .

The European Commission has received a proposal from Sweden to restrict medium-chained chlorinated paraffins (MCCP) under the EU RoHS Directive.  MCCPs are one of the seven priority substances that were recently out for public consultation as part of a RoHS review.  Rather than waiting for the due course of considering MCCP under the current RoHS review, Sweden is proactively pushing for the restriction.

MCCPs are used in EEE as a flame retardant and plasticizer in certain plastic materials such as PVC used in cable sheathing.

The proposal is now with the European Commission for next steps.

The European Commission is moving forward with a new database for data on SVHCs in articles. ECHA is contracted to develop the database; which is considered by the Commission to be a part of interface between chemical, product, and waste legislation.  Product manufacturers will in turn be required to submit data on the SVHCs that are present in the products as per the reporting requirements of REACH Article 33 (SVHCs in articles).

Discussion is underway between some industry organizations and the European Commission on the proposed database and the challenges of implementing such a system.

The revised waste legislation[1] that mandates the creation of such a database was published on June 14, 2018. The legislation comes into force after 20 days and the database needs to be operational 18 months thereafter (January 5, 2020) (Article 9, paragraph 2). Once the database is in place, article suppliers (e.g. importers) are required to provide information on SVHCs to the database within 30 months of the amending Directive coming into force (January 5, 2021) – this is specified in Article 9(1)(i) and is excerpted below:

(i) promote the reduction of the content of hazardous substances in materials and products, without prejudice to harmonised legal requirements concerning those materials and products laid down at Union level, and ensure that any supplier of an article as defined in point 33 of Article 3 of Regulation (EC) No 1907/2006 of the European Parliament and of the Council (*) provides the information pursuant to Article 33(1) of that Regulation to the European Chemicals Agency as from 5 January 2021;

Impact on EEE Manufacturers

A requirement for manufacturers and importers to submit all SVHCs in their products into a central database will create significant challenges and extra work for many manufacturers, especially SMEs. ECD Compliance will be monitoring the requirements and industry efforts as the details of the requirements become more visible.

[1] Amendment to EU Waste legislation, https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32018L0851&from=EN

The seven EU RoHS exemption renewals that the European Commission posted in March for Parliamentary scrutiny were formally published in the European journal on May 18^th. The exemptions include: 6a, 6b, 6c, 7a, 7c-I, 24, and 34. The Commission has provided a transition period of just over a year, with the new exemptions coming into effect on July 1, 2019.

The new exemptions are excerpted in Table 1.

Table 1: RoHS Exemption Renewals Adopted

Impact on EEE Manufacturers

Most of the exemptions are renewed for the full five years for product categories 1-7 and 10 (starting with the original expiry date of July 21, 2016 until July 21, 2021) with a few exceptions:

• Exemption 6a) lead in steel alloy has a reduced scope — the lead in batch hot dip galvanised steel components has been reduced to 0.2% by weight.
• In exemption 6(b)-II, the use of lead in aluminium for machining purposes expires on 18 May 2021 (three years from the date of publication). The European Commission is signalling that it intends to sunset the use of lead in aluminum, except where the lead content comes from recycled aluminum scrap.

Note that for product categories 8 and 9, the original exemption wording remains in effect for the full seven years from when that product category came into scope of the RoHS substance restrictions. This is July 21, 2024 for industrial monitoring and control instruments.

As part of the European initiatives on circular economy, the EU member states have approved a set of “ambitious measures” related to EU waste legislation.  The challenging (and disconcerting) part of this for manufacturers is that the new measures include a proposal for producers to notify ECHA about the presence of SVHCs in articles for the purpose of providing recyclers with information that they may use during recycling operations.  This (if implemented) will be a significant challenge to EEE manufacturers and especially SMEs.

Impact on Manufacturers

Although the overall measures have been approved by EU members states, the regulation is still several steps from being officially adopted and there are still many details to be worked out.  Industry groups have already provided strong feedback on the proposal.  ECD Compliance will continue to monitor for any concrete developments.

The China Ministry of Industry and Information Technology (MIIT) has published MIIT Notice No. 15 2018 dated 15 March with ”1st Compliance Management Catalogue of Electric Appliances and Electronic Products for Restriction Use Hazardous Substances” and ”Applications Exempted from the Restriction in Product Compliance Management Catalogue” for China RoHS 2. The substance restrictions come into effect on March 15, 2019.

The revised standard for the environment assessment of computer, tablets and monitors (IEEE 1680.1-2018) was officially published on March 19, 2018.  The standard is used by the EPEAT(tm) ecolabel program[1] to recognize products that meet specific environmental and social responsibility requirements. Product manufacturers are now assessing their products and corporate programs and adjusting where necessary to meet the requirements specified in the revised standard. The Green Electronics Council (who operates the EPEAT program) has said that the new requirements will need to be met by November 2018 for products to remain registered in the EPEAT system.

The EPEAT ecolabel is used by many governments (including US and Canadian federal governments) and other organizations for IT purchasing. It influences significant annual computer, monitor, and tablet purchasing.

The requirements in the standard are organized into “criteria” which may impose requirements on the product (product criteria) or on the manufacturer (corporate criteria) and the criteria may be either “required” or “optional”.  All required criteria must be met; optional criteria count towards qualifying for a silver or gold rating.  The criteria are grouped into the following categories:

• Substance management
• Materials selection
• Design for end of life
• Product longevity/life-cycle extension
• Energy conservation
• End-of-life management
• Packaging
• Life cycle assessment and carbon footprint
• Corporate environmental performance
• Corporate social responsibility

Some of the major changes in the revised standard include the addition of corporate social responsibility requirements and requirements associated with the suppliers to the finished product manufacturers.

A complete list of all criteria in the revised IEEE 1680.1-2018 standard is provided in Annex 2.

The standard may be purchased on the IEEE standards store[2].

ECD Compliance can assist manufacturers with implementation of the requirements in the standard or with a audit.

[1] EPEAT, https://www.epeat.net/

[2] IEEE webstore, https://www.techstreet.com/ieee/standards/ieee-1680-1-2018?product_id=1999671