Exploring the Future of Circular Economy Eco-design Requirements Through Servers and Data Storage Products

This blog was originally posted on 24th February, 2025. Further regulatory developments may have occurred after publication. To keep up-to-date with the latest compliance news, sign up to our newsletter.

AUTHORED BY MICHELLE WALSH, SENIOR REGULATORY COMPLIANCE SPECIALIST AND TEAM LEADER, COMPLIANCE & RISKS

Ahead of the Ecodesign and Energy Labeling Consultation Forum to be held in Brussels on 10^th March, the EU Commission has circulated a working document on a new draft eco-design regulation for servers and data storage products.

What is special about this proposal, is that it shows some of the future trends the EU Commission will use to encourage circular economy design. Notably, we see improved disassembly, repairability and recycling, stricter requirements around spare parts including a prohibition on parts pairing, as well as new information requirements for components and critical raw materials.

This new draft regulation if enacted, will replace the existing eco-design Regulation 2019/424 for servers and data storage products and is based on several recommendations from the recent review study conducted by ICF for the EU Commission. 

Some of the key highlights include:

Expanded Scope and New Definitions

1. The new draft removes the exemptions for server appliances, large servers and fully fault tolerant servers.
2. New definitions are added for new key terms: serialized part, spare part, professional repairer, fastener, removable fastener, resupplied fastener, commercially available tool, generalist, basic tools, and workshop environment.
3. New further definitions included that are specific to data storage products.

New Requirements for Spare Parts

1. Certain spare parts including their required fasteners must be made available to professional repairers for at least 5 years after the end of placement of the product on the market.
2. Procedure for ordering spare parts must be publicly available on a free access website.
3. Repair and maintenance information must also be accessible to professional repairers on the website (registration may be required).
4. Spare parts must be delivered within 10 working days (during the first 3 years) or 15 days (during remaining years that the parts need to be available) after having received the order. This may be limited to professional repairers registered on the website of the manufacturer.
5. List of pre-tax prices in euros (including pre-tax price of fasteners or tools) must be provided on the free access website.

Disassembly Requirements

1. Process for replacement of covered spare parts must be carried out at least in a workshop environment and by a generalist.
2. Fasteners must be removable, resupplied or reusable. 
3. Necessary tools must be available (spare parts must be either replaced with no tool, basic tools, tools supplied with the product or commercially available tools).

Ban on Parts Pairing

1. For replacement of serialized parts, the manufacturer must provide access to any software tools, firmware or similar auxiliary means necessary to ensure the full functionality of the spare parts of the device in which such spare parts are installed during and after the replacement.
2. The website of the manufacturer must specify the procedure for the notification and authorization for the intended replacement of the serialized part which the manufacture may require (including how to remotely provide the notification and authorization).
3. Access to the necessary tools and software must be provided within 10 working days after the request and may be limited to professional repairers registered on the website.

Recycling – Better Information on Components and Critical Raw Materials

For a period of 8 years after placing servers and online data storage products on the market the following information must be provided:

1. A list of components, their number codes and material content for certain components: (CPU, PSUs, data storage devices, memory, motherboard, graphic card, chassis, batteries, fans, integrated switch, RAID controllers and Network Interface Cards).
2. Information on Critical Raw Materials: Cobalt in the batteries, Neodymium in the HDDs plus also Silicon, Germanium, Tantalum, Gold and Dysprosium in all components.
3. Description of the disassembly steps for covered spare parts.

Energy Efficiency and Design

1. Idle State Power  – A new equation for calculating the Idle State Power is proposed.
2. Stricter active state efficiency requirements for servers (including 4-socket rack servers).
3. New active state efficiency requirements for data storage products.
4. New function for servers to include a product feature to make available real-time data. 
5. Certain servers to include a processor power management functionality, enabled and shipped as the default.
6. Certain data storage products to include a product feature to measure and report input power (Watts) and inlet air temperature (°C).

Energy Efficiency Label

Finally, although not specifically included in this regulation, the EU Commission is also planning to discuss the possibility of an energy label for servers at the Consultation Forum which could be used to facilitate customer procurement processes. 

If an energy label is proposed, we would expect to see this contained in a sister energy labeling regulation to this proposal.

Stay Ahead Of Regulatory Changes like the Eco-design Regulation for Servers and Data Storage Products

Want to stay ahead of these regulatory developments?

Accelerate your ability to achieve, maintain & expand market access for all products in global markets with C2P – your key to unlocking market access, trusted by more than 300 of the world’s leading brands.
C2P is an enterprise SaaS platform providing everything you need in one place to achieve your business objectives by proving compliance in over 195 countries.

C2P is purpose-built to be tailored to your specific needs with comprehensive capabilities that enable enterprise-wide management of regulations, standards, requirements and evidence.
Add-on packages help accelerate market access through use-case-specific solutions, global regulatory content, a global team of subject matter experts and professional services.

• Accelerate time-to-market for products
• Reduce non-compliance risks that impact your ability to meet business goals and cause reputational damage
• Enable business continuity by digitizing your compliance process and building corporate memory
• Improve efficiency and enable your team to focus on business critical initiatives rather than manual tasks
• Save time with access to Compliance & Risks’ extensive Knowledge Partner network

Bird’s Eye View of Global AI Regulations: US, EU, UK, Singapore and China

Gain insights into how different jurisdictions are addressing AI-related challenges and what these developments mean for businesses, policymakers, and compliance professionals.

REGISTER now