Contents 1.Introduction 1.1.The Ecodesign work on enterprise servers and data storage products 1.2.Structure of this impact assessment 2.Problem definition 2.1.What is the issue or problem that may require action? 2.2.What is the scale of the problem? 2.2.1.Data centre consumption share by servers and data storage products 2.2.2.Data centre locations 2.3.What are the underlying drivers of the problem? 2.3.1.Lack of functional information – energy related aspects 2.3.2.“Non-optimal economic behaviour” of the users 2.3.3.Lack of functional information - resource related aspects 2.4.Who is affected, in what ways and to what extent? 2.5.How are existing policies and legislation affecting the issue? 2.6.Baseline scenario: How will the issue evolve in absence of intervention? 2.6.1.Base Cases 2.6.2.Sales

2.6.3.Product lifetime and stock 2.6.4.Expenditure 2.6.1.Industry revenue 2.6.2.Employment 2.6.3.Energy consumption and GHG emissions 2.6.4.Improvement potential 2.7.Should the EU act? 3.Policy objectives 3.1.General objectives 3.2.Specific objectives 3.3.Consistency with other EU policies 4.Policy options 4.1.Introduction 4.2.General scope and definitions 4.3.Option 1: No action (Business-as-usual, BAU) 4.4.Option 3: Ecodesign requirements for servers and data storage products 4.4.1.Minimum efficiency requirements for power supply units 4.4.2.Operating temperature information requirements 4.4.3.Requirement on the idle mode energy consumption 4.4.4.Information or MEPS requirement on servers’ performance (e.g. SERT-based)

4.4.5.Information requirements 4.4.6.Material efficiency requirements 4.5.Option 5: Complementary regulatory approaches – compulsory Energy Star 4.6.Summary of policy scenarios 5.Analysis of impacts 5.1.Environmental impacts 5.1.1.Energy impacts of servers 5.1.1.Energy impacts of data storage products 5.1.2.Energy impact of servers and storage products 5.1.3.Greenhouse gas emission reduction of servers 5.1.4.Reduction of other environmental impacts due to material efficiency requirements 5.2.Economic impacts 5.2.1.Business revenue of servers 5.2.2.Business revenue of data storage products 5.2.3.Employment of servers industry 5.2.4.Employment of data storage products industry 5.2.5.User expenditure for servers 5.2.6.User expenditure for data storage products 5.2.7.Single user expenditure for 2 sockets rack server 5.2.8.Single user expenditure for Online 2 storage product

5.3.Other impacts 5.3.1.Administrative burden 5.3.2.Testing cost for the server industry 5.3.3.Cost associated with material efficiency requirements 5.3.4.Impact on innovation 5.3.5.Impact on SMEs 6.Comparison of options 6.1.Summary of impacts and options comparison 6.1.1.Sensitivity analysis on different adoption rates of operating conditions 6.1.2.Sensitivity analysis on the cloud utilisation 7.Evaluation and monitoring 7.1.Evaluation and revision Annex 1: Procedural information Annex 2: Synopsis Report Annex 3: Who is affected by the initiative and how Summary of costs and benefits Annex 4: Inputs, assumptions, calculations Annex 5: Definitions and glossary Annex 6: Proposed metrics requirements Annex 7: Additional graphs and tables

7.1.Greenhouse gas emission reduction 7.2.Sensitivity analysis – detailed tables 7.2.1.Detailed tables for sensitivity analysis of 15% data centre adoption of Operating condition for scenario 3.2 7.2.2.Detailed tables for sensitivity analysis of 45% data centre adoption for scenario 3.2 and 75% for scenario 3.3 7.2.3.Detailed tables for sensitivity analysis on the cloud utilisation 7.3.Cumulative savings by 2030 for the policy scenarios 7.4.Single user expenditure for a server and data storage product Annex 8: Indicative benchmarks Annex 9: Evaluation of an existing ecodesign/energy labelling measure Annex 10: Procedural steps for Ecodesign measures Annex 11: Existing Policies, Legislation and Standards on servers and Data storage products EU legislation Standards for servers and data storage products Voluntary legislative tools in the EU National programs inside the EU National and global programs outside the EU This report commits only the Commission’s services involved in its preparation and does not prejudge the final form of any decision to be taken by the Commission. 1.Introduction In the European Union (EU), the Ecodesign Directive requires product manufacturers to improve the environmental performance of their products by meeting minimum energy efficiency requirements, as well as other environmental requirements such as water consumption, emission levels or minimum durability of certain components. The Energy Labelling Regulation complements Ecodesign by enabling end-consumers to identify the better-performing products, via the well-known A-G/green-to-red labelling grading. The legislative framework, which builds upon the synergic effect of the two aforementioned pieces of legislation, is central to making energy use in Europe more efficient, contributing especially to the 'Energy Union and Climate' priority, and also to the priority of a 'Deeper and fairer internal market with a strengthened industrial base'. This legislative framework is also of paramount importance for several aspects. First of all, it pushes industry to improve the energy efficiency of products and removes the worst-performing ones from the market. Secondly, it helps individuals, families and companies to reduce their utility bills. In the industrial and services sectors, this results in support to competitiveness and innovation. Thirdly, it ensures that the legal entities (typically manufacturers and importers) responsible for placing products on the EU markets only have to comply with a single EU-wide set of rules and standards.

It has been estimated that by 2020 the Ecodesign and the Energy Labelling directives will deliver around 175 Mtoe (i.e about 2035 TWh) of energy savings per year in primary energy, roughly equivalent to Italy's energy consumption in 2010, close to half the EU 20% energy efficiency target by 2020 and about 11% of the expected EU primary energy consumption in 2020. Moreover, the average household saves annually on energy bills an amount growing to about €500 by 2020 whilst for industry, service and sale and retail sectors it will result in €55 billion per year of extra revenue. This legislative framework benefits from a broad support from competitive European industries, consumer organizations and environmental NGOs (non-governmental organization) , as the transparent and regular consultation process in establishing implementing measures is largely appreciated. The Ecodesign Directive and Energy Labelling Regulation include a built-in proportionality and significance test. For the Ecodesign Framework Directive, Articles 15(1) and 15(2) state that a product should be covered by an ecodesign or a self-regulating measure if the following conditions are met: ·The product should represents a significant volume of sales; ·The product should have a significant environmental impact within the EU; ·The product should present a significant potential for improvement without entailing excessive costs, while taking into account: o an absence of other relevant Community legislation or failure of market forces to address the issue properly, oa wide disparity in environmental performance of products with equivalent functionality; The procedure for preparing such measures are described in Article 15(3). In addition, the criteria of Article 15(5) should be met: ·No significant negative impacts on user functionality of the product; ·No significant negative impacts on Health, safety and environment ·No significant negative impacts on affordability and life cycle costs ·No significant negative impacts on industry’s competitiveness (including SMEs). The procedural steps prior to the finalisation of Ecodesign measures are described in detail in ' Annex 10: Procedural steps for Ecodesign measures '. 1.1.The Ecodesign work on enterprise servers and data storage products In the domain of information and communication technology (ICT), Ecodesign implementing measures already cover electronic displays and computers . A further group of ICT products is currently being investigated as part of the Ecodesign Working Plan 2012-14 : enterprise servers (referred to as ‘servers’ in this impact assessment) and data storage products. As described more in detail in the present report, the market figures related to these products are expected to continuously increase: trends such as the Internet of Things (objects and people interconnected through telecommunication), the Industry 4.0 (the trend of automation and data exchange in manufacturing technologies) and Cloud Computing (distribution of computational work and data storage on a number of sites connected in the Internet) are growing at a very fast pace and require more and more computing power and storage capacity. Following the inclusion of servers and data storage products in the Ecodesign Working Plan 2012-14, an Ecodesign design preparatory study on these products (referred to as 'the preparatory study' in the remainder of the text) was concluded on September 2015 . The overall conclusion was that the primary environmental impact of servers and data storage products is related to the energy consumption in the use phase, and that the yearly electricity consumption related to the use of servers and data storage products in the EU is highly significant. For these reasons, an Ecodesign regulation on these products was recommended. More in detail, several policy recommendations for servers and data storage products were formulated, including information requirements, quantitative requirements at hardware level (in particular on the efficiency of internal power supply units), on the product operating conditions (mainly: higher temperature to save on cooling costs), and on product software components and configuration, such as virtualization. The preparatory study also proposed requirements on product materials efficiency, such as extraction of key-components and of critical raw materials, availability of built-in data deletion tools (while not jeopardizing data privacy) and of firmware updates. The study also concluded that, for the time being, it was not possible to outline requirements based on overall energy performance at computer server level, given the lack of a metric for the evaluation of such an evaluation. It was also concluded that any proposal for an energy label on computer servers was premature because of a) lack or a well-established metric and b) such energy label as a tool for informed choice is not considered as strong as in the case of domestic products, being servers a business-to-business products, where buyers usually have high level of technical knowledge and very peculiar needs. Following the conclusions of the preparatory study, a dedicated impact assessment was started. The present report constitutes the knowledge base for this impact assessment. Specifically concerning the formulation and the analysis of impact of the material efficiency requirements, the main reference study is a JRC report on the analysis of material efficiency requirements of servers29 (named as 'JRC report' in the remainder of the text), which presented the Life Cycle Assessment (LCA) of servers as well as recommendations for potential ecodesign requirement on material efficiency. The technical work prior to this impact assessment also entailed an analysis of the standards (or draft transitional methods, when needed) for the assessment of the compliance with regard to the potential ecodesign requirements for servers and data storage products under discussion; this is reported in the deliverables of the Technical Assistance Study for Enterprise Servers and Data Storage99 (named as 'the technical assistance study' in the remainder of the text). 1.2.Structure of this impact assessment

The present report basically consists of a policy analysis entailing technical, economic and environmental aspects. The structure of the report reflects the European Commission Better Regulation Guidelines. These Guidelines establish a set of questions, to which an impact assessment should answer: 1. What is the problem and why is it a problem? 2. Why should the EU act? 3. What should be achieved? 4. What are the various options to achieve the objectives? 5. What are their impacts and who will be affected? 6. How do the different options compare? 7. How will monitoring be organised? To guide the reader throughout the report, the specific question (among those ones in the list above) which is dealt with is highlighted in the heading of each page of the report. 2.Problem definition 2.1.What is the issue or problem that may require action? Servers and data storage products are very large energy consumers and the energy consumption of these devices is steadily increasing, because more services with increasing levels of sophistication and data and computing requirements are being created and subsequently demanded in increasing volumes by end-users in all sectors and by automated systems (such as video surveillance, financial systems, transportation etc.) .This is also leading to a shift from personal devices and smaller organisational servers to larger data centres including cloud services to manage the exponentially increasing amount of data being produced, processed and stored. A server is a computing product that provides services and manages networked resources for client devices, such as desktop computers, notebook computers, desktop thin clients, smart phones, tablets, as well as telecommunication, automated systems or other servers. To fulfil their computing role, servers are designed to be more powerful and reliable, and are typically housed in data centres and office/corporate environments where primary access is via network connections, and not through direct user input devices such as a keyboard or a mouse. The specific technical characteristics that designate a computing product as server are given in Annex 5. Servers can have many types and forms; among the four different ones shown in the figure below, rack-mounted servers cover the largest share of the market. These forms are generally designed to enable as much computing performance to be housed in the available space. A data storage product is a storage system that supplies data storage services to clients and devices attached directly or through a network. A data storage product may be composed of an integrated storage controller, connected to the storage devices such as hard drives, or solid-state drives, as well as embedded network elements, and software etc. The specific technical characteristics that designate a computing product as data storage product are given in Annex 5. Data storage products can look similar to certain server forms, but they typically have more storage capacity, storage access interfaces and data retrieval and management utilities than servers. See figure below for examples of data storage products.

Typically, slightly more than 50% of the electricity consumption related to data centres is due to direct energy consumption of critical ICT equipment: servers, data storage products and networking equipment. The rest is for the cooling and UPS demand associated. As established by the Lot 9 preparatory study, energy consumption in the use phase constitutes about 90 % of the total environmental impact of servers and storage. Since services are required for all businesses, servers are purchased and operated by a wide range of businesses, but typically servers are used in one of the following three cases: 1) Where the users of all data centre equipment and service provider coincide: There are a few very large scale (hyper scale) global IT companies such as Google, Microsoft and Amazon operating up to a million servers in global networks. They have their own data centres and they pay the energy costs of running them, so they are aware of the energy consumption both due the high total energy costs and due to a growing use of “acting green” as part of their image and therefore they try to optimise. The end customers buying the services (rent of servers and rent of server services such as file storage, mail services, cloud services etc.) can be individuals, SMEs and larger companies. Additionally, there are also many smaller data centres and typically located nationally and with national customers. 2) Where the data centre owner provides the infrastructure such as area, racks, secure access system, cooling etc., and the servers and/or data storage products are owned either by the customer or by the data centre itself: these are known as colocation data centres. Most often, there is only little focus on the energy consumption, because the number of servers owned by a customer typically is low and the customers are not very conscious on the energy consumption. One factor that may push for energy awareness is the fact that colocation data centres often put a surcharge on the electricity price, when reselling to the server owners. However, the total size of electricity purchase may still be considered as insignificant for the customers and the invoice line for electricity purchase may be less visible because it is included in the overall bill for infrastructure. In addition, data centre costs are rarely passed on to the department within the customer organisation which has requested the particular server or service. This barrier of split incentives is typical for energy efficiency and seen in other sectors as well, as the buyers of a service or a product do not pay the yearly energy cost for operating the service or product, therefore little incentive to take the operating costs into account of initial purchase. Therefore, there is no information or incentive to improve the efficiency of the service or a mechanism to consider whether a service provides value for money to the organisation. This can result in both inefficient services or unrestrained demand and growth of services with limited or no value to the business. Unrestrained growth is even more likely when they are assumed to be operating efficiently within a highly virtualised or private cloud environment. 3) Where the customers, typically SMEs – though larger companies and public organisations may also have their own data centres – use servers and/or data storage products owned by themselves and they are located in a dedicated IT equipment room or space with air conditioning or other cooling in the premises of the company: These customers usually have less focus on the energy consumption of servers and data storage products, because most often there is no dedicated electricity meter installed in the server equipment and the consumption is just one contributor of many to the overall electricity bill. Again, for organisation of all sizes there is rarely a mechanism to pass on the cost of operating the servers and service to the departments within the organisation using them. There are millions of SMEs in the EU operating as few as one server to provide basic file management and e-mail functions or operating as many as several hundred servers. The diverse range of operators means that the resources and knowledge to select, purchase, and manage the data server and data storage product varies just as much. Alternatively, instead of operating servers, the server services may be purchased directly, commonly from cloud and hosted services providers (e.g. e-mail, file and web services) and from providers of pure server capacity (e.g. for installation of own server software and special applications), see the first case above. This solution is increasingly popular, particularly for smaller businesses and the potential market is enormous and growing because also medium sized and larger companies are increasingly moving to cloud and hosted services partly due to improved high speed internet connections from the company to the data centre. The storage market is similarly increasing, because it is directly related to the growth in cloud and hosted services. A specific market for companies running their own servers or data centres is remote backup in order to secure the data in a remote location e.g. in relation to fire or theft. Moving services to cloud may be hindered by the technical difficulty as well security and data protection concerns and the legal issues by having other countries’ legal framework regulating your data, but there is much focus on reducing these barriers. The customers of hosting and cloud services are not directly billed their electricity consumption, but only indirectly where the electricity consumption is one of many costs that the hosting or cloud company has. Additionally, the price of the services is very much market based for standard products such as hosted exchange, Microsoft Office 365 and remote backup. The most significant environmental impact from servers and data storage products is the in-use energy consumption. This is well understood by some parts of the industry but not an important purchasing consideration for some operators. For large scale IT operators, the energy costs are a significant part of total cost of ownership (TCO). They have the resources, skills and information to analyse and optimise the energy efficiency across the entire system and design the products to meet their specific requirements. However, energy efficiency is one of many factors when designing and constructing data centres and it may still not have same priority as other factors. Additionally, the market transformation due to ecodesign requirements will also result in more energy efficient equipment being available for the large scale IT operators and they will also benefit from this development. For medium sized to smaller operators it is even more difficult to react on the size of the in-use energy consumption despite lifetime energy costs being a significant part of the products’ TCO. The energy consumption costs have big impact on the TCO due to servers and data storage products typically being always on; due to lifetime often being higher than e.g. client computer devices and due to need of removal of the heat dissipated from the products, which often will be removed by electricity powered mechanical cooling systems, Since 2007, manufacturers have focused more heavily on energy efficiency, partially because data centres’ large energy consumption has caught much attention, especially due to the US report to congress on data centre energy consumption. While this is due in part to environmental awareness, many operators were also reaching their data centre power and cooling capacity limits, and increasing consumption was an unsustainable business model. Server and data storage products continue to develop rapidly with new components and models being released on an annual basis. Smaller manufacturing techniques for CPUs (Central Processing Units), SSDs (Solid State Drives) and RAM (Random Access Memory) continue to reduce energy consumption and/or increase performance within the same power envelope. Design evolutions also continue to make progress, while whole new product niches promise new solutions and approaches to efficiency. Outside of the product design, virtualisation (i.e. by having many virtualised servers running on one hardware server) and cloud services enable greater efficiency by increasing the utilisation of the hardware. Additionally, highly optimised power supplies, UPS (uninterruptible power supply) systems and cooling in the data centre reduce associated power without sacrificing resiliency. Many of the large scale IT operators nowadays focus on low energy solutions when building new data centres e.g. by reducing most of the mechanical cooling (by using free ambient air for cooling) and using surplus heat to external purposes like heating water and space heating. This means that large data centre services can be an order of magnitude more efficient than in-house servers and storage. By use of efficient design and free cooling, some newly designed and constructed data centres could reduce the energy consumption by 10% - 20%, compared to older data centres. For users who are seeking to maximise the efficiency of the server, there is a lack of unbiased, publicly available information available to make an informed comparison between different server products based on the users’ needs. Since technology changes so rapidly and there are millions of potential configurations of CPU, RAM, storage for a single server model, making an informed decision requires a lot of resources. As a result, users tend to ensure that the product is suitable for their requirements by over-configuring the product with more capable and power-consuming components which leads to low utilisation levels and inefficiency. Part of the reason is that under-capacity could create substantial issues for the core activities for an organisation, while over-capacity increases purchase and operating costs. In spite of large potential, energy efficiency is often not the first priority for the users of servers and data storage product as described above and in the next sections, therefore the Business as Usual scenario will only release a smaller portion of the energy efficiency potential. This would mean an unnecessary and significant increase in energy consumption in the EU due to the increase in need of servers and data storage if the EU does not provide incentive or legislative measure to set energy efficiency as a higher priority. In addition, in light of EU’s Circular Economy Action Plan, servers and data storage products should also contribute to circular economy objectives by promoting reuse and recycling and hence reduce GHG emissions as well as other environmental impacts. 2.2.What is the scale of the problem? Electricity consumption of data centres (servers, storage and network equipment combined) in EU-28 in 2015 is estimated at 78 TWh by preparatory study for Lot 9, corresponding to a significant 2.5% of the total electricity final consumption in the EU. This total includes the network equipment, which is not included in the scope of current impact assessment. The electricity consumption of servers and data storage products alone are estimated to be 53 TWh in 2015, corresponding to 2 % of the total consumption in the EU. This number is estimated to reach 55 TWh in 2020 and 78 TWh in 2030. In addition, sufficient cooling needs to be provided so that the equipment operates within its thermal limitations. This additional cooling is provided in data centres or server rooms and can be directly attributed to the server and data storage product. The additional cooling requires electricity and in this impact assessment will be referred to as electricity consumption for "infrastructure". The electricity consumption of servers and data storage product including infrastructure are expected to be 96 TWh in 2015, this corresponds to 3.2% of the EU total consumption; this is estimated to be 96 TWh in 2020 and 121 TWh in 2030. Energy savings potentials have been estimated for the years 2020 – 2030 for different policy scenarios in this impact assessment. With a potential Ecodesign measure for servers and data storage products, the projected saving is 6.5 TWh (approximately the yearly electricity consumption of Latvia in 2014) in 2020 and 8.9 TWh (approximately the yearly electricity consumption of Estonia in 2014) in 2030 in the case of the preferred policy option (see section 6.1 for the in-depth analysis). More in detail, the effect of the ecodesign requirements for servers in the preferred policy option is estimated to result by 2030 in direct annual energy savings of approximately 2.4 TWh and indirect (i.e. related to infrastructure) annual energy savings of 3.7 TWh, summing up to a total saving of 6.1 TWh, corresponding to a total of 2.1 Mt of CO2 equivalent. The effect of the ecodesign requirements for data storage products in the preferred policy option is estimated to result by 2030 in direct annual energy savings of approximately 0.8 TWh and indirect (i.e. related to infrastructure) annual energy savings of 2 TWh, summing up to a total saving of 2.8 TWh, corresponding to 0.9 Mt of CO2 equivalent. Long-term assessments should however be viewed cautiously, as they can be uncertain due to the rapid technological development in the sector. The 8,9 TWh/yr electricity savings (as of 2030) under the present initiative in the case of the preferred policy option would account for ~22,5TWh of primary energy, i.e. ~4% of the total savings under the Ecodesign Working Plan 2017-19. As a reference value, the overall electricity consumption at EU level in 2015 was ~3041TWh. Overall, it was estimated that all the measures (new ones and reviews) under the Ecodesign Working Plan 2016-2019 have an estimated potential to deliver a total in excess of 600 TWh (or 50 Mtoe, Megatonnes of oil equivalent) of annual primary energy savings in 2030. This is comparable to the annual primary energy consumption of Sweden, and is also equivalent to reducing CO2 emissions by approximately 100 million tonnes per year in 2030.

2.2.1.Data centre consumption share by servers and data storage products 2010 2015 2020 2025 2030 IT (servers, storage and network equipment etc.) 52% 57% 65% 65% 65% Infrastructure (mechanical and electrical systems) 48% 43% 35% 35% 35% Table 1 Table 1 shows the estimated proportion of energy consumed by IT and consumed by the rest of data centres i.e. the infrastructure, including cooling, ventilation, UPS, etc. The IT energy consumption share from 2010 to 2030 is expected to increase and the PUE is improved as a result of possible ecodesign regulation and general increase in focus for energy efficiency in data centres. 2010 2015 2020 2025 2030 IT (servers, storage and network equipment etc.) 52% 57% 65% 65% 65% Infrastructure (mechanical and electrical systems) 48% 43% 35% 35% 35% The percentage of electricity consumption for the IT equipment was calculated from the percentage of IT and infrastructure in the US for period 2010 to 2020 estimated by the Lawrence Berkeley National Laboratory report. During the period from 2020 to 2030, the proportions were calculated based on an interpolation assuming a PUE factor of 1.55 (Business as Usual scenario) in 2030. From the above, it can be concluded that any initiative aimed at decreasing the energy consumption at product level would certainly have a significant effect on the overall consumption at data centre level. 2.2.2.Data centre locations According to a European survey, the majority (68%) of companies choose their own country when considering locations for their new data centres, and the most important factors when choosing the site are security and connectivity. Most locations considered for a new data centre are in the three largest countries in Europe, the UK (London), France (Paris) and Germany (Frankfurt). More recently, relocation or expansion of data centre space to northern locations is occurring for a few known hyperscale data centres such as Facebook and Apple, but it is not a general visible trend for all. Although there might be a trend to build new data centres in colder regions, it also highly depends on other beneficial factors such as above-mentioned security, connectivity, accessibility, latency and power costs etc. for data centres. Data center relocation projects are expensive. The average data center relocation costs 10,000 USD/rack. It is therefore assumed not to be the first preferred option for an existing data centre that is already located in warmer regions. 2.3.What are the underlying drivers of the problem? Servers and data storage products are not all standard off-the-shelf products, some of them are configured to the purpose of the customer regarding redundancy, number and type of processor sockets and processors installed at delivery, number of blades (for blade servers), disk capacity and number of disks at delivery etc. The typical users for servers and data storage products are technical experts rather than common consumers as seen for household ICT equipment. Although they may have the competences to choose energy efficient devices, typically they do not include the energy consumption and energy efficiency as important purchasing requirements as argued previously in Section 2.1 but rather focus on other aspects. This market failure in terms of economic sound purchasing decision is due to the following reasons: split incentives due to the division between budgets for purchasing (typically a specific IT budget) and running costs (typically part of an administrative budget), lack of functional information, lack of tools for assessing the TCO and user prioritisation including traditions e.g. for selecting specific brands and specific solutions. These market failures are seen less for the large scale global IT companies, however, also here may be seen not fully optimised choice of solutions and brands. These large companies often have a data centre design concept including purchasing principles for servers and data storage product, which is followed when constructing new data centres. Furthermore, a general market introduction of more efficient servers and data storage product due to ecodesign regulation would also push the energy efficiency of the products that the large scale IT companies purchase for their data centres. In terms of material efficiency of servers and storage products, market failure lies in several aspects, which hinder a high rate of reuse and recycling: Difficulty in disassembly and separation of products, lack of information of embedded critical raw materials, lack of standardised data deletion method and unavailability of firmware updates. These problems can be addressed by the current initiative by introducing requirements regarding material efficiency. Concerning the existing literature in support to the abovementioned problem drivers, in general terms it has been found that there can be multiple reasons why economic actors do not spontaneously choose the products which are the most cost-effective over the product's lifetime. In several cases companies (as well as some public services sectors) are less likely to undertake energy saving measures, even if they would have the same economic viability as other investments , .

Specifically in the case of servers and data storage products, given that it is a B2B (business to business) sector, gathering the information was possible thanks in particular to bilateral contacts occurred with industry, data center managers and users. The collection of available literature/reports was more challenging, as some stakeholders were not willing to publicly disclose sensitive commercial information; nevertheless, references are given for each of the market failures described in the next subsections. 2.3.1.Lack of functional information – energy related aspects In the open public consultation (described with more detail in Annex 2) run in the context of this impact assessment, one of the questions was intended to understand how the respondents judged the information made available by manufacturers to 'users' (i.e. data centre/server rooms operators) in terms of energy consumption of servers and data storage products. Results were as follows: ·38% of the respondents think that information is available, however in a non-standardised way, with big differences between the various manufacturers ·31% of respondents declared that specific information is usually missing. Only 15% of respondents was of the opinion that manufacturers already today provide users with the necessary information, while the rest of respondents did not reply, or replied 'don't know'. Lack of functional information concerns the lack of a reliable parameter to measure the energy efficiency of the products. The problem is complex as energy consumption depends amongst others on two highly variable parameters – the type of work performed by the machine and the computing platform (server technology, operating system and applications). For large enterprise clients purchasing servers in high volume for specific purposes, it is possible to work with vendors to test configurations against actual work at the specific enterprise, by replicating the data processing through traces. However, this is not a realistic solution for the majority of users due to the costs of doing these specialised tests. There are many different performance tests and a large range of information for servers, which are not functional for objective comparison. Many manufacturers have server and data storage product sizing and configuration tools but in terms of energy, they often only provide the maximum power and cooling needs. Sometimes efficiency benchmark data can be found for certain server models, but it cannot be used for comparison with products from other brands etc. Since there is no standardisation, all vendors will heavily optimise and select the tests, which show their products in the best possible light. This makes accurate and unbiased comparison impossible. Concerning the first market failure (lack of functional information), relevant industry actors have been working for some time on the development of a standardized and appropriate testing methodology for energy efficiency (i.e. energy performance vs energy consumption), in particular the SERT (Server Efficiency Rating Tool) for servers developed by SPEC (Standard Performance Evaluation Corporation) and the SNIA (Storage Networking Industry Association) Emerald™ programme for data storage product. The task proved extremely complex since the energy consumption depends on several parameters, inter alia, the type of work performed by the machine, and the computing platform, which are both highly variable elements. Further development of such methods into standards would play a key role in addressing the provision of reliable functional information, which is one of the causes of market failure. However, two elements limit the degree of effectiveness of these standards: firstly, voluntary coordination among firms is difficult and costly for this class of products, due to the technical difficulties in defining a standardized measure of energy performance and energy consumption. Secondly, the uptake of such standards would likely be incomplete in case of voluntary participation. For these reasons, the effectiveness of such standards would be greatly limited if they were not accompanied by an obligation to use them to transparently publish energy performance data, among other environmental impacts. 2.3.2.“Non-optimal economic behaviour” of the users Energy efficient products are already available on the EU market today, but many customers do not purchase energy efficient products as the majority of users prioritise low purchasing cost, to low electricity costs and environmental savings. The two market failures are mutually supportive and feed each other in the sense that the absence of interest from large sectors of customers allows for a continued lack of functional information which together result in an environment that does not stimulate investments and efforts towards designing more energy efficient products. It emerged during the preparatory study that, DG GROW Lot 9 products, in particular servers and data storage products, are perceived by users only as components of a much more complex system - the data centre. Even if it is sometimes recognised that electricity costs are increasingly important, service availability, performance and security still have priority over energy (and resource) consumption. Moreover, service availability, performance and security dictate the technology, configuration and resulting product costs; the intended quality of service is setting the parameters for the products design including its options for power management and efficient resource utilisation. For these reasons, as emerged in the preparatory study (in particular in Task 3), customers tend to overlook possible (money and energy) savings over the product's life cycle deriving from increased energy efficiency, which does not put service availability, performance and security at risk. This “non-optimal economic behaviour” can be considered as a market failure. Even though more efficient equipment exists, which is at least at the same level of reliability etc. as the less efficient equipment, many data centre owners and operators still neglect their consideration when taking purchasing decisions. In some cases, it is because of budgetary reasons that they choose less efficient instead of more efficient equipment, which is feasible over a lifetime, but is more expensive to buy. Other reasons include that it requires less resources to continue with the same choice of solutions, product brands and suppliers that to switch to other solutions, brands and suppliers. This is a fact, which is seen not only in the data centres, but also in other B2B markets. Surveys such as those conducted for Digital Realty have shown that the importance of green issues is much lower than other factors in this product market. Power reliability and requirements and data centre operations/management were considered extremely important for over 34% of participants when planning a data centre, whereas green issues were considered extremely important for just 21% and the least important of 9 different issues. Similarly, for data centre expansion, security, disaster recovery and power issues were the most important reasons for expanding, while green issues were the 13th most important out of 15 factors. Furthermore, a specific situation occurs for colocation centres, where the data centre owner provides the infrastructure, such as area, racks, secure access system, cooling etc., while the customers bring their own servers. The technical expertise of these customers for the purchase of servers and data storage products can be smaller, therefore they are more likely to choose cheaper and less efficient equipment. 2.3.3.Lack of functional information - resource related aspects The identified market failures for enterprise servers and data storage products mainly concern incomplete information when customers and other stakeholders which play a role throughout the product lifecycle, such as repairers or recyclers, are given neither sufficient nor good-quality information for their purchase, reuse, disposal or recycling. The reasons for this incomplete information vary from case to case, being linked e.g. to lack of standardized methods (such as in the case of energy consumption, as shown earlier) or to overcautious end-of-life practices (as in the case of the sanitization of hard disk drives (HDDs)). Specifically, in the case of the (lack of) availability of firmware updates, which will be described in detail in the remainder of this section, this market failure is usually referred to as 'market power' (i.e., the ability of a firm to profitably raise the market price of a good or service over marginal cost). Concerning data deletion issues, there are an increasing number of cases in the literature concerning personal data found in second hand components, like HDDs put back on the market (El Emam et al., 2007; NAID, 2017). In the context of reuse of enterprise servers, reuse operators need to grant the deletion of personal data contained in waste electrical and electronic equipment (WEEE) before their further treatments. The data privacy concerns, along with the lack of specific guidance, have led more customers to ask end-of-life operators to ensure that their devices are (physically) destroyed after their first use in order to avoid the threat of any potential access to personal information. In other cases operators are specifically paid by their clients to certify the destruction of data bearing equipment (e.g. by the physical destruction of the equipment). Alternatively, when such request did not occur, operators developed specific procedures to grant the sanitization of data bearing equipment. The physical destruction of the data storage device is therefore considered as “extreme”, whereas in most cases the proper sanitization of the storage media could, in many cases, suffice to ensure the proper erasure of personal data in the device. The availability of firmware updates has been also highlighted by reuse operators as a crucial aspect for the reuse of servers. In the last decade original equipment manufacturers (OEMs) have decided to restrain the access to firmware updates for some ICT products, typically granting access only to the users who were signing a maintenance agreement with them. This practice of restricted access to firmware can hinder the reusability of products as enterprise servers and data storage products. The difficulty for third parties dealing with maintenance, reuse and upgrading of enterprise servers and data storage products to access the market of reused and refurbished products is the reason for which the market failure concerning the (lack of) availability of firmware updates has been classified as 'market power', by also taking into account that the enterprise servers and data storage products market is a highly concentrated one (e.g. in 2013, 78% of the market was covered by the top five international vendors)8. Moreover, the unavailability of firmware updates for buyers of second hand equipment does not only impact their interoperability with other hardware and software, but also endangers the security of these devices and the digital services they support Finally, repair and end-of-life operators generally identified the ‘ease of disassembly’ of WEEE as an essential prerequisite for their reuse. WEEE need to be disassembled to permit their checking and to allow the repair and replacement of faulty and/or obsolete components. Barriers to disassembly have been observed29 mainly in the case of servers and are related to different aspects as: the use of welded or glued components; the use of several different fastening techniques (e.g. the used of several different screws and snap fits); the use of proprietary fastening systems (e.g. special screws that necessitate special tools); and in general the low visibility or accessibility of certain fastening (e.g. screws that are covered by labels). These difficulties have been also observed especially when the disassembly is performed by reuse operators, independent from OEMs, who do not know exactly the architecture of the server and the required disassembly procedures. That is why this market failure can be considered as a case of incomplete information. It is highlighted that the ease of disassembly of servers relates also to data privacy issues, since the extraction of data bearing components (e.g. HDDs and SSDs (Solid State Drives) can be necessary to grant their proper sanitization or destruction. The JRC study also indicates that there is a significant amount of critical raw materials (CRM) found in the servers and storage products e.g. Neodymium. As they are often contained in components that are boxed inside a casing, the lack of information of present critical raw materials and amount of the materials provides little incentive for recyclers to disassemble difficult casings for extraction.

2.4.Who is affected, in what ways and to what extent? There is a complex global supply chain involved in the server and data storage product manufacturing industry that will be affected. There are a small number of large global product manufacturers (vendors) which sell products to the users (i.e. the customers). A few large contract manufacturers assemble the products for these manufacturers. The main components are sourced and supplied by a number of large specialised manufacturers. Servers and data storage product provide services for all of society, however they are operated directly by businesses and the public sector. This means the private end consumer are not affected by the problem of servers and storage market failures. Several types of stakeholders would be affected by the different options in this impact assessment: Large Manufacturers (Vendors) The main industry vendors include HPE (Hewlett Packard Enterprise) (US), Dell (US), Lenovo (China), IBM (US), Cisco (US) and Fujitsu (Germany). Hitachi also manufactures data storage products. There are also three other large Chinese manufacturers, which do not yet have significant European market share but may grow in future, Huawei, Inspur and Sugon. Fujitsu has manufacturing facilities in Augsburg, Germany, which produces up to 950 servers and storage products daily, that equals to approx. 250,000 units in a year . Hitachi assembles storage products in The Netherlands and Lenovo has also disclosed plans to manufacture in Europe. Manufacturers will be most affected since they directly implement policies and are responsible for showing compliance. The manufacturer designs the product, which will require greater focus on energy efficiency in research and development, and provides users with the appropriate information. However, around 75% or more of the energy consumption and efficiency opportunities are determined by the main components not produced by the server and storage manufacturers themselves, including the Power Supply Unit(PSU), central processing unit(CPU), random-access memory (RAM) and storage. Manufacturers will therefore also need to work with component manufacturers in their supply chains to help developing and source the most efficient parts and ensure future component design road maps meet future efficiency requirements. Contract Manufacturers (CMs) Contract Manufacturers are used by the majority of the large vendors. The main CMs are Hon Hai, Inventec, Wistron and Quanta, all Taiwanese companies. They are increasingly involved in the design of sub-assemblies, particularly the motherboard, and have started to design and sell products directly. Their manufacturing bases include Eastern Europe (mainly Czech republic), China and Mexico. CMs assembling the final product will not be greatly affected by the policies policies (as long as they are not responsible for placing the product on the market) but will need to work with the vendor if they are designing the product. However, where the CMs are selling directly to the user (i.e. they are responsible for placing the product on the market), they will be responsible for compliance in the same way as other manufacturers. Component manufacturers Many components currently only have 3-4 major component manufacturers that supply to all the server and data storage product vendors. A large proportion of the efficiency gains are achieved through component efficiency and may require increased research and design (R&D). R&D costs, as well as new manufacturing facilities to produce more efficient components may increase component costs. It may also change the existing market structure where older, less efficient components which offer proven, reliable options and lower cost alternatives to the latest state of the art tend to remain on the market for a number of years. System Integrators and independent manufacturers There are a large number of local system integrators across Europe that use off the shelf components, which are then custom-assembled for the client. There are also a smaller number of independent manufacturers who design and manufacture products. The system integrator or manufacturers would be affected by the regulatory approaches envisaged in this impact assessment (in a direct way, when they would be responsible for placing servers and data storage products on the market). Data centre and server operators New policies should help operators select and purchase more efficient products, which lowers their energy consumption and operating costs, while possibly increasing one-off purchase costs. 2.5.How are existing policies and legislation affecting the issue? At present, servers are partly covered by the Ecodesign regulation on computer and computer servers , which quantitatively regulates only power supply efficiency for the servers, while there is no requirement on Minimum Energy Performance Standards (MEPS) for these products. The current Ecodesign regulation on computer and computer servers has also an exemption for blade server systems and components, which means that potentially excludes ca. 800,000 blade servers a year, equivalent to approx. 18% of the total server market. Other product groups are also exempted: server appliances, multi-nodes servers and computer servers with more than four processor sockets. Several other pieces of EU and non EU legislation, as well as voluntary initiatives, affect at present servers and data storage products; they are described in detail in ' Annex 11: Existing Policies, Legislation and Standards on servers and Data storage products '.

2.6.Baseline scenario: How will the issue evolve in absence of intervention? Based on the current trend, it is predicted that with or without EU intervention, the following development in the servers and storage market can be expected: ·Server and storage sales increase more slowly than recent years. As indicated in the preparatory study, continuous growth of virtualisation is leading to dematerialisation and lower demand in physical servers and storage product alike. However, as shown more in detail in Annex 4, the effect of virtualisation on the decrease of server and storage sales is deemed to cease around 2016, and from this year onward the growth rates for these products are nevertheless assumed to be positive. ·Growth of cloud applications and workloads and fall in sales of hardware to be used by SMEs and large companies with own server and data centre facilities as well as fall in the number of SME manufactures of servers and storage due to lower demand of physical servers and mainly of low end physical servers. However, the growth will stagnate after reaching very high cloud workloads of approximately 90%. This development is due to better and cheaper cloud services combined with faster data connections, making it attractive to move from own organisational servers and data centres to cloud and hosted services. There are however limits to the move to cloud services, see Annex 4, therefore the sales proportion of traditional to cloud servers is maintained at 30:70 for the baseline scenario. The baseline assumes that current policy measures at Member State level will not change, that means impact of above mentioned national programmes as well as EU Energy Star have been included in baseline scenario and no further action at EU level will be introduced. No EU intervention would mean that there will be no realisation of the full saving potential and persistence of the mentioned market failures: lack of standardised methodology and not-optimised behaviour of users. This implies that: ·Efficiency and performance improve due to natural improvement as follows the technical development but at a limited scale because of little focus by the users. ·Metrics may be developed for use by Energy Star and other schemes but without being implemented broadly and without achieving full impact compared to a MEPS regulation. ·The Energy Star server specification will continue to be in effect and further developed into new versions stimulating the development of more efficient servers but due to the voluntary nature of the scheme, the uptake would be rather limited. ·Energy consumption of servers and storage will continue to increase, because the increase of data centre service needs exceeds the limited efficiency improvements. The baseline assumes the average power of servers is expected to decrease gradually from current level, depending on the type of the servers it can decrease by 1-18% by 2030. However, rack servers with 1 socket and 4 sockets as well as blade servers with 1 socket will increase 1 – 6% by 2030 as a result of higher utilisation rates and higher performance. Data storage product capacity doubles every 2-3 years, but storage density increases 20-30% every year, which means the average power consumption is assumed to increase ca. 6% annually up to 2020, and there onwards 2% increase up to 2030. The baseline also assumes servers’ average PSU efficiency will increase by 7% point by 2030 from current level of 78% - 82% depending on the type, and data storage products’ average PSU efficiency will increase by 5% point by 2030 from the current level of 87%. In terms of baseline operating conditions, most servers and data storage products can already operate at ASHRAE A2 conditions (max. 35 °C), but without a binding agreement to declare this information, most data centres and server rooms do not have the confidence to operate accordingly. Hence, average PUE was assumed 1.8 currently and will gradually decrease to 1.55 by 2030 due to the market development into more efficient new data centres. More detailed description of baseline assumptions can be found in Annex 4: Inputs, assumptions, calculations . 2.6.1.Base Cases The base cases with major market share should be included in the baseline scenario to establish the energy consumption most representative of the sector. In this subsection, sensible base cases have been established in close consultation with the industry. It should be noted that the base cases identified for the Impact Assessment are different from the ones in Preparatory Study Lot 9 which defined 3 base cases: rack server, blade server and storage; there are now more sub-categories within rack and blade servers as well as data storage products in the current assessment in order to be more representative of the market. Servers The server base cases listed in Table 2 were identified during consultation with industrial stakeholders.

Form Sockets/CPUs Resilient Tower 1 No Rack 1 No Rack 2 No Rack 4 No Rack 2 Yes Rack 4 Yes Blade, incl. enclosure 1 No Blade, incl. enclosure 2 No Blade, incl. enclosure 4 No For tower servers only the one socket system is assessed separately from the rack systems. The 2 socket tower server is close to the two socket rack server in terms of resource requirements and components, and is thus covered by this base case. 3-socket servers were not included in the base cases, as they are not common and can largely be addressed by the evaluation of the 4-socket options. The base cases will be built on managed server technology, which is a suitable representation of unmanaged servers of the same type in assessing the impacts of the different scenarios. The base cases assumed all sockets to be used, and hence configurations such as two socket servers with one socket populated are assumed to be sufficiently covered by the ‘one socket, one processor’ and ‘two socket, two processors’ cases. The two and four socket resilient servers comprise only a small share of the market, but are included as base cases, since their configuration and thus energy consumption differ significantly from the non-resilient servers. The three socket servers are not included as a base case, as they are even less common and largely addressed by the evaluation of two and four socket resilient servers. With regards to multi-node blade server systems, the power and performance characteristics of a 2 socket or 4 socket blade servers are comparable to the performance of dual or multi-node blade server enabling the 2 and 4 socket blades to adequately represent the product set. Blade server base cases are assumed to include both the blades and the blade enclosures. Storage These base cases are chosen based on the Storage Networking Industry Association (SNIA) taxonomy of Online 1 – 6 products . There are 3 base cases for data storage products; online 2, 3 and 4 products, which are the most common low-end and mid-range products. Online 1 products were omitted since these are consumer products whereas current initiative has a focus on enterprise products. Online 1 storage cover a small market, and are technically different from Online 2, 3 and 4 products, therefore would need a separate analysis. Online 5 and 6, usually high-end and mainframe products, only have limited sales due to the large size and more specialist roles. These systems have also a limited number of manufacturers and building and testing an Online-5 or 6 systems is specialised and very complex, therefore they were excluded from the Energy Star scope and likewise excluded here. Storage Classification Online 2 Online 3 Online 4 These base cases have been developed based on the different configuration, device details and SNIA Emerald test data of seven storage products Digital Europe has provided. The performance for each base case is averaged out of the performance of the seven products with different configurations, however it is difficult to determine a typical average product for each base case as it is possible to have a wide range of number of drives, which is a key determinant of energy consumption. 2.6.2.Sales The market of servers and storage products is global, as a few very large international vendors cover the most of the market share. Generally, the market of these products in the EU is expected to follow the global market trend. Servers In 2015 the total sales of identified server base cases is estimated to be 3.2 million, this covers 80% of all servers in the EU, as some micro-servers, unmanaged servers, 3 socket servers and a small portion of resilient servers are not represented by the base cases. This total is expected to increase to around 5 million in 2030. This gives a collective growth rate of 1.2% per year. However, the growth is not distributed equally between the eight base cases. Table 4 shows the predicted sales for each base case until 2030 and the compound annual growth rate (CAGR) from 2000 to 2030. See details about sale estimation in Annex 4: Inputs, assumptions, calculations . For all server types, the sales show a decreasing trend from 2010 to 2016. For all but the 1 socket tower servers, this is expected to shift to an increasing trend from 2017, with the growth rates shown in Table 4 . The sales forecast is based on sales data for servers in units in the EU-28 supplied by Digital Europe, which is higher than the sales figures found in the preparatory study Lot 9. The sales provided represents 77% of the EU market, therefore the total shown above is scaled up to the whole EU market. Base case 2010 2015 2020 2025 2030 CAGR 2000-2030 Tower 1 socket 258,148 231,269 198,599 170,544 146,452 -1.4% Rack 1 socket 559,471 543,057 570,758 599,872 630,472 0.4% Rack 2 socket 1,836,718 1,633,409 1,987,291 2,417,844 2,941,677 1.6% Rack 4 socket 103,122 85,773 104,357 126,966 154,473 1.4% Rack 2 socket resilient 30,474 27,513 33,474 40,726 49,549 1.6% Rack 4 socket resilient 1,673 1,511 1,838 2,236 2,721 1.6% Blade 1 socket 179,844 169,704 178,361 187,459 197,021 0.3% Blade 2 socket 595,715 511,811 622,696 757,605 921,743 1.5% Blade 4 socket 33,061 27,418 33,358 40,586 49,378 1.3% Total 3,562,232 3,231,465 3,730,732 4,343,837 5,093,486 1.2 %

Storage The three base cases Online 2, 3 and 4 should represent approx. 53% of the entire storage market. In 2015, the total sales for the identified base cases are estimated ca. 550,000 units. The annual growth rate of 2 % is assumed from 2017 onwards, due to the sales data from market research companies show that there are swings in sales during 2009 - 2014, so it is also reflected in the modelled sales. From 2000 to 2009, the sales are steadily increasing due to the growing demand. The compound annual growth rate (CAGR) in Table 5 is the average growth rate per year from 2000 to 2030. It can be observed that there is currently a downward trend in 2010 -2015 period. While demand for more storage continued to increase, unit sales actually decreased. This is because the total storage capacity of each unit has increased and more than offset the drop in sales. Type 2010 2015 2020 2025 2030 CAGR 2000-2030 Online 2 305,314 282,603 308,957 341,114 376,617 4.5% Online 3 190,289 135,778 148,440 163,890 180,948 3.2% Online 4 39,083 35,419 38,722 42,753 47,202 3.9% Total 534,687 453,800 496,120 547,757 604,767 4.0% The sales are provided by Digital Europe via IDC for units sold in Western Europe. No information is obtained about the market share in proportion to the whole EU-market, so the data is not scaled up and these figures are considered conservative estimates. The sales data is higher than the figures supplied by market research companies in the preparatory study; however, in line with the model used by preparatory study and for the servers above, the sales data provided by Digital Europe is used for the Impact Assessment model. It is assumed Online 2 products account for 40% of the sales for the entire group of Online 1 and 2. 2.6.3.Product lifetime and stock Servers For calculating the stock of the base cases, a lifetime of 5 years with a standard deviation of 1 year was assumed. The lifetime is based on the findings from preparatory study Lot 9, that the economic lifetime varies according to user segment, primary users typically switch servers every 3 – 5 years and secondary users 5 – 7 years. The stock for server base cases, seen in Table 6 , is estimated to be 18 million in 2015 and is estimated to reach 26 million in 2030 based on the sales forecast and expected lifetimes. See details about stock estimation in Annex 4: Inputs, assumptions . Base case 2010 2015 2020 2025 2030 Tower 1 socket 1,221,844 1,299,250 1,173,436 1,008,941 866,412 Rack 1 socket 3,077,090 3,059,884 3,068,257 3,223,567 3,388,001 Rack 2 socket 10,101,948 9,422,302 10,004,073 12,155,464 14,788,981 Rack 4 socket 567,170 507,183 525,339 638,307 776,598 Rack 2 socket resilient 167,607 158,101 168,509 204,747 249,105 Rack 4 socket resilient 9,203 8,681 9,253 11,243 13,678 Blade 1 socket 989,141 963,702 958,826 1,007,357 1,058,742 Blade 2 socket 3,276,433 2,976,130 3,134,694 3,808,800 4,633,988 Blade 4 socket 181,837 161,603 167,928 204,040 248,245 Total 19,592,276 18,556,897 19,210,375 22,262,519 26,023,818 Storage According to Digital Europe, data storage products such as hard disk drives, solid-state drives, hybrid drives and storage systems have an average economic lifetime of 5 to 7 years. The stock for the three base cases of data storage product is estimated with normal distribution by assuming an average lifetime of 7 years with a standard deviation of 1. The stock for data storage product base cases, seen in Table 7 , is estimated to be 3.4 million in 2015 and is estimated to reach 4.2 million in 2030. Base case 2010 2015 2020 2025 2030 Online 2 1,546,870 2,018,778 2,179,988 2,390,988 2,639,844 Online 3 979,636 1,151,388 1,059,698 1,148,765 1,268,329 Online 4 202,467 259,817 275,060 299,669 330,859 Total 2,728,973 3,429,983 3,514,746 3,839,422 4,239,032 2.6.4.Expenditure Servers

The purchase price for the base case servers is shown in Table 8 . The price ranges are from the preparatory study, where the typical purchase price was estimated by expert. There are large price variations within each group dependent on a number of factors such as number and speed of CPUs, capacity and speed of the memory, type, number and size of disk drives, operating system, years of warranty included. Base cases Range of purchase price (€/unit) Estimated typical purchase price (€/unit) Tower 1 socket 750 – 4,600 1,200 Rack 1 socket 700 – 1,300 1,000 Rack 2 socket 1,300 – 76,100 3,500 Rack 4 socket 30,500 Rack 2 socket resilient 35,000 Rack 4 socket resilient 3,400 – 72,050 37,500 Blade 1 socket 375 Blade 2 socket 3,500 Blade 4 socket 3,500 – 11,800 6,500 Storage Price bands for Online 2, 3 and 4 base cases have been supplied by Digital Europe. An average purchase would be needed to calculate the user expenditure in later sections. However it is again difficult to determine a typical cost for the data storage products as it depends very much of the configurations, table below shows the price range and assumed price in the impact assessment. In preparatory study for Lot 9, the product price for storage is assumed € 23,000 regardless of storage classification, since current purchase price assumed for Online 3 and Online 4 products are much higher, the total storage turnover from product price would be higher than that of preparatory study. Table 9: Purchase prices (excluding VAT) for each base case in Euros/unit. Storage Classification Range of purchase price (€/unit) Assumed purchase price (€/unit) Online 2 < 22,766 20,000 Online 3 13,659 – 91,066 50,000 Online 4 91,066 - 227,665 160,000 2.6.1.Industry revenue The total revenue of servers and storage industry is estimated 55 billion euros in 2015, out of which 13 billion euros from OEM and 9 billion euros from the original design manufacturers (ODMs) for servers, and 19 billion from OEMs and 13 billion euros from ODMs for storage. As seen above the data storage products are in average much more expensive than servers and is a much less off-the-shelf product, therefore much higher revenue have been estimated. 2.6.2.Employment Europe has a number of companies which carry out high volume final assembly of servers and storage products. These are mainly based in Eastern Europe (Czech Republic) as well as Germany and the Netherlands. Independent manufacturers and system integrators are located throughout Europe. Fujitsu in 2013 manufactured 300,000 servers/storage units, and had 1,500 employees. Hon Hai in Czech Republic has 4000 employees and manufactures 12 million units per year, although it is not clear how many of them are servers/storage, as it manufactures various types of electronic equipment such as mobiles, smartphones, tablets, game consoles etc. Based on the sales estimation and approximate average purchase prices of servers and storage, the employment due to the manufacturing and sales of servers and storage in baseline are estimated in the table below. It is assumed an average ratio of annual industry revenue per employee, because it requires a much higher level of detailed data from the industry stakeholders to establish a dynamic employment assessment of the sector. The table presents the employment of Original Equipment Manufacturers (OEMs) who sell and customise the servers to the users, SMEs are also included in the figures. In some cases, the Original Design Manufacturers (ODMs) sell the servers and storage directly to the users, but the result presented in this report assumes that ODMs produce, design and manufacture products, which are specified and branded later by the OEMs. 2015 2020 2025 2030 OEM - servers 50,153 68,151 92,855 126,772 ODM - servers 48,147 65,425 89,140 121,701 OEM - storage 71,246 88,125 110,083 137,512 ODM - storage 68,396 84,600 105,680 132,012 2.6.3.Energy consumption and GHG emissions Servers The annual energy consumption and greenhouse gas (GHG) emissions for servers including infrastructure such as cooling is shown in Table 11 . In a data centre, there will also be approx. 10-12% additional energy consumption for network equipment. This equipment is not a part of the IA scope and not included in the infrastructure. For rest of the report, network equipment is not included in any energy consumption, primary energy consumption and GHG emissions.

2010 2015 2020 2025 2030 Energy consumption servers, TWh 45.8 37.9 35.7 40.7 47.9 Energy consumption including infrastructure, TWh 93.6 68.9 61.7 66.9 74.5 Total primary energy including infrastructure, PJ 842.6 620.0 554.9 601.7 670.2 GHG, including infrastructure, Mt CO2-eq 38.4 27.2 23.4 24.1 25.3 The annual energy consumption of servers is based on the stock model and data of energy consumption in idle and max on-modes for the eight base cases . Energy consumption including infrastructure is calculated as the product of energy consumption of server and the average PUE factor in a given year, the PUE factor takes into account of autonomous development in data centre energy efficiency. The PUE factor is dependent on the climatic conditions and is an average of all the Member States. The climatic conditions are assumed to impact the PUE with less than 10%. See further in Annex 4. The CO2 emission factor used in the calculation is decreasing as the renewable energy share in the grid electricity is anticipated to increase. See more details for the calculation in Annex 4: Inputs, assumptions . Storage The annual energy consumption and GHG emissions for servers including infrastructure such as cooling, is shown in table below. 2010 2015 2020 2025 2030 Energy consumption storage, TWh 11.0 14.7 19.7 25.0 29.9 Energy consumption including infrastructure, TWh 22.5 26.6 34.1 41.0 46.5 Total primary energy including infrastructure, PJ 202.7 239.7 307.0 369.3 418.4 GHG, including infrastructure, Mt CO2-eq 9.2 10.5 13.0 14.8 15.8 Similar modelling methodology applied to servers is applied to the data storage products. The annual energy consumption is based on the stock model and data of energy consumption in idle modes for storage base cases38. Idle mode consumption is used for calculation due to the small difference between idle and max on-mode consumptions for these base cases. Total servers and data storage products The total electricity consumption of servers and storage including infrastructure is estimated ca. 96 TWh in 2015 and this is estimated to increase to 121 TWh in 2030. 2010 2015 2020 2025 2030 Energy consumption servers and storage, TWh 56.8 52.6 55.4 65.7 77.8 Energy consumption including infrastructure, TWh 116 96 96 108 121 Total primary energy including infrastructure, PJ 1045 860 862 971 1089 GHG, including infrastructure, Mt CO2-eq 47.6 37.7 36.4 38.8 41.1 2.6.4.Improvement potential In consultation with stakeholders, the preparatory study identified a number of cost effective options for improving the energy efficiency of server and data storage product. It was established that the following options could reduce societal costs: ·Higher efficiency PSUs. Installing 80 Plus Platinum efficiency PSU in on/standby mode could reduce energy consumption by up to 7% compared to 80 Plus Silver PSUs in balanced mode. ·Using solid state drives (SSDs) rather than HDDs. SSDs are rapidly falling in price and in certain cases are becoming cost competitive with performance enterprise HDDs. ·ASHRAE thermal guideline A2 or A3 operating conditions. Extending the operating temperature and humidity range reduces the need for mechanical cooling of the data centre, if free air cooling is a possibility for the data centre. This allows the chillers and cooling units set points to be raised, or switched off when the outdoor air is sufficiently cool. ·Servers only - advanced processor and platform power management. By monitoring the utilisation and switching off, or lowering the operating frequency and voltage, it is estimated that power can be reduced by approximately 5%.

·Data storage products only - Capacity Optimization Method Software (COMS). COMS monitor the data and apply techniques such as deduplication and compression to maximise the use of available storage. Power savings can range between 20-30%. 2.7.Should the EU act? Article 15.1 and 15.2 of the Directive 2009/125/EC provide guidance on when intervention at EU levels is justified. It states that in case a product represents a significant volume of sales, has a significant environmental impact within the Union, presents a significant potential for improvement (without entailing excessive costs), while taking into account an absence of other relevant Union legislation or failure of market forces to address the issue properly and with a wide disparity in environmental performance of products with equivalent functionality, the product can be covered by an implementing measure or by self-regulation. The EU should not act if the objectives of the action can be achieved sufficiently by Member States acting along. However, action by Member States could not solve the problem for the following reasons: ·Servers and data storage products are a global market, and a few very large global companies are covering 2/3 of the EU market, and an EU action would be more cost-effective. ·Technology for these products is very complex; hence it would be highly difficult for Member States to develop national schemes and regulations, while an EU action would eliminate additional costs needed in each Member State to regulate a technology that does not vary from country to country. ·Manufacturers expressed views that national schemes and regulations would create more obstacles and administrative burden for entering national market, and would prefer to comply with an EU wide legislation. The preceding sections showed that the sales volume is large enough to be significant, as is the environmental impact from energy consumption and emissions. The current trend in sales and characteristics of equipment placed on the EU market does not significantly reduce the overall energy consumption of these products. The preparatory studies have established for the products within scope a significant potential for improvement (wide disparity in environmental performance), which can be achieved without excessive costs (improvement of average product results in lower life cycle costs). Moreover, it is expected in absence of regulatory interventions, the market failures analysed in chapter 2.3 could not be solved, and they would represent missed opportunities to move the market from a non-optimal situation. 3.Policy objectives This impact assessment focuses on specific objectives, since the general ones have already been set out in the impact assessments for the Ecodesign Directives. 3.1.General objectives The general objective of the initiative is to contribute to the EU climate and energy targets i.e. the 2030 targets, while ensuring the functioning of the internal market. Following the legal basis of Directives 2009/125/EC and 2010/30/EU in the TFEU, the general objectives are to: ·ensure free circulation of (energy-related) products within the internal market; ·increase energy efficiency; ·ensure security of energy supply in the Union; ·contribute to sustainable development by increasing the level of protection of the environment. ·contribute to circular economy objectives by promoting reuse and recycling, in light of EU’s Circular Economy Action Plan

whilst ensuring (as from Directive 2009/125/EC, article 15) that there will not be : ·significant negative impacts on the functionality of the product ·significant negative impact on industry’s competitiveness ·excessive administrative burden imposed on manufacturers ·significant negative impact on product affordability and the life cycle cost of the product. 3.2. Specific objectives The specific objectives for this impact assessment are: ·Raising awareness regarding energy efficiency and environmental performance of servers and data storage products and facilitating a comparison between corresponding products among users via inter alia establishing standard measurement methods of energy versus performance and providing product information. ·Complementing or integrating the provisions of the EU Energy Star program ·Gradually removing the worst-performing products from the EU market ·All the above, minimizing the increase in the purchase cost of products, also considering the specificities of the B2B sector of servers and data storage products. 3.3.Consistency with other EU policies The improved energy efficiency of servers and data storage products will be in the framework of the initiatives which contribute to reduce the energy consumption at EU level by at least 30% by the year 2030, as foreseen in the ‘Proposal for a Directive of the European Parliament and of the Council amending Directive 2012/27/EU on energy efficiency’. At a more global level, the improved energy efficiency of servers and data storage products will contribute at enabling the EU to deliver on its Paris Agreement commitments in terms of emissions reduction. 4.Policy options 4.1.Introduction In order to address the issues identified in Section 2 and to meet the targets defined as policy objectives in Section 3, several policy options and possible requirements described in the following table are considered. Option 1 No EU action (“BAU”, Business-as-Usual) Option 2 Self-regulation Option 3 Ecodesign requirements for servers and data storage products a.Minimum efficiency for power supply b.Operating temperature information or minimum requirements according to ASHRAE c.Minimum requirement for idle mode energy consumption d.Requirements (information or MEPS ) on servers’ performance (e.g. based on SERT tool ) e.Information requirements e.g. from Energy Star f.Material efficiency Option 4 Energy Labelling Option 5 Regulatory approach such as the Energy Star Programme Option 1 is the baseline where servers and storage business will continue without EU regulatory intervention, it will also serve as a reference for the assessments of the impacts of the different policy options.

Option 2 has been discarded, because the industry has so far not proposed any kind of self-regulation, which is a minimum condition in accordance with Article 17 and Annex VIII of the Directive 2009/125/EC to even consider this option. Option 4 has also been discarded for a variety of reasons. First of all, there are no or very little direct sales to private household to whom the energy label would be normally targeted. Moreover, servers are B2B products; in order for the label to be a relevant tool for an informed choice when buying the product, it should be carefully designed in order to provide concise but at the same time relevant and effective information (and this can be a difficult task, e.g. considering that the already existing provisions on servers under Energy Star require an extensive list of information items). In any case, the lack of a well-established metric for the energy efficiency of servers, and of the necessary data on product performances and efficiencies would be the main obstacle for the existence of an energy label for servers: the preparation of the scaling and of the ranges of values of each energy class of a labelling system entails a knowledge of the efficiencies of products on the market, and of how they are split in the various potential energy classes, with a level of detail which is even higher of the one needed to set minimum threshold requirements for Ecodesign. That is why a minimum critical mass of data related on product performances and efficiencies would be needed, before proceeding with this option. This means that policy Option 3 and Option 5 are the viable policy options to address the issues in Section 2 and the objectives given in Section 2. Details about these options are presented below. 4.2.General scope and definitions The scope is based on the findings of preparatory study ENTR Lot 9, however a few more specific types of servers and data storage have been excluded, because they are not enterprise products or special products with very low sales volume. The product scope for servers includes products that are: Defined as computer servers according to the definition of the Energy Star® specification for computer servers (version 2.1). See recommended definition in Annex 5: Definitions and glossary . The product scope for data storage products includes products that are: Defined as storage product according to the definition of the Energy Star® specifications for data centre data storage product (version 1.0). See recommended definition in Annex 5: Definitions and glossary . The product scope for servers excludes products that are: ·Intended for domestic users or embedded (machinery) applications The product scope for data storage products excludes products that are: ·Domestic and portable data storage products such as SNIA Classification Online 1 data storage products ·SNIA Classification Online 5 and 6 storage products 4.3.Option 1: No action (Business-as-usual, BAU) Option 1 is the business-as-usual scenario, where the EU takes no further action and where the users remain focusing on cost and reliability of the product group rather than also on energy. The option will serve as a reference baseline for the other policy options to compare with. This option follows largely the trend described for baseline scenario under Section 2.6. The main assumptions for this option are detailed in Annex 4: Inputs, assumptions . 4.4.Option 3: Ecodesign requirements for servers and data storage products

This section is devoted to assess the possibility of setting Ecodesign Minimum Energy Performance requirements (MEPS) that can be imposed on servers and data storage products, and their economic, environmental and social impacts. The analysis of ecodesign requirements feasibility for servers and data storage products, respectively, are carried out separately, as the characteristics are different for the two product groups and the conclusions may be too. Several requirement options (presented in the following sub-sections) are considered across several areas. These are combined into several scenarios (3.1 to 3.3) that differ by stringency of the requirements (3.1 being the least and 3.3 the most stringent scenario). 4.4.1.Minimum efficiency requirements for power supply units The power supply units (PSU) are used for both servers and data storage products. There are two types of PSUs, i.e. single output and multi-output PSUs. Both types can technically be used for servers and storage. Multi-output PSUs are however more stable and reliable for high power draw associated with a lot of hard drives motors spinning and therefore they are used in storage. The proposed minimum efficiency requirements for power supply units used for servers and data storage products are shown in Table 15 . The equivalent efficiencies of the different levels (Gold, Platinum, etc..) are shown in Annex 4: Inputs, assumptions , Table 50 . Policy scenario Tier 1 Tier 2 Tier 3 PO 3.1 2019: Gold for servers, silver for storage 2023: Platinum for servers and gold for storage - PO 3.2 2019: Gold for multi-output PSUs and Platinum for single-output PSUs 2023: Platinum for multi-output PSUs and Titanium for single-output PSUs 2026: Titanium PO 3.3 2019: Platinum for servers and gold for storage 2021: Platinum for servers and storage 2026: Titanium for servers and storage 4.4.2.Operating temperature information requirements 4.4.2.1.Background information Estimating the average operating temperature of data centres and server rooms is a challenging exercise, in particular due the variability of (EU) geographical conditions, together with the fact that these are business-to-business specific applications. Based on existing literature,, , it can be approximated that the server and data storage products are typically operated at temperature in the range of 20°C-22°C as any systematic (i.e. not only due to temporally limited variations) temperature increase is seen as potentially problematic concerning reliability issues. Despite this, some big companies explicitly declare higher temperature values (up to 29.4°C inlet temperature), proving that a proper thermal management of the data centre allows these solutions. If the data centre or server room is cooled by energy driving cooling systems – which is the case for most of them – the energy consumption for cooling can be reduced by allowing a higher temperature. which again requires that the server and data storage product can withstand the higher temperatures. Increasing the range of operating temperature would typically result in energy savings at the cooling system level. First of all, if a mechanical cooling system (i.e. using compressors as in household refrigerators) is used, the cooling efficiency (COP – Coefficient of Performance) will increase as the temperature difference between the cold and the hot side of the system decreases. Furthermore, cold losses from the data centres reduce when temperature difference between outside and inside is reduced and if free cooling (e.g. using ambient air for cooling) is used, the amount would increase with an increase in allowable temperature. Furthermore, it allows the data centres to use a higher degree of free air cooling, i.e. using outside air for cooling instead of a mechanical cooling system. Finally, an increase of the date centre hot air temperature will increase the usefulness and the energy potential in the hot air, when used for other purposes such as water and space heating. When setting potential requirements on operating conditions for servers and storages, it is important to assess whether this is being addressed by other initiatives already to avoid overlapping. One important initiative is the Commission’s publication “An EU Strategy on Heating and Cooling” , but the possible effects it may specifically have on servers and data storage product, at product level, is limited. The publication mentions that the service building sector consumes a large amount of energy, and space cooling account for 25-60% of data centres’ operating costs. The overall recommendations that concern data centres are that: ·the Commission will look into making advanced tools for metering, control and automation based on real time information standard requirements for service sector buildings, and ·in general, the focus on lowering heating and cooling demand, deployment of district heating and new innovative approaches to low temperature heating (e.g. waste heat from data centres) in industry, which could complement a potential ecodesign requirement on servers and data storage products (being these products able to tolerate higher ambient temperature). The organisation ASHRAE has established thermal guidelines for data centres and a possible operating temperature requirement can be based on thermal classes (A1, A2, A3 and A4) from these guidelines, see Table 16 . Compliance with the requirements does not directly result in energy savings, but it allows the data centre operator to increase the set point temperature of the cold air, when all equipment in the data centre or in a specific zone of the data centre can withstand the higher temperatures. It also allows the operator to have a more flexible air handling due to the wider temperature and humidity ranges, which increases the opportunities for free air cooling. ASHRAE class Dry bulb temp °C Humidity range, non-condensing Max dew point (°C) Maximum rate of change (°C/hr) A1 15- 32 –12°C DP and 8% RH to 17°C DP and 80% RH 17 5/20 A2 10-35 20% - 80% RH 21 5/20 A3 5-40 -12°C DP and 8% RH to 85% RH 24 5/20 A4 5-45 –12°C DP and 8% RH to 24°C DP and 90% RH 24 5/20 As seen in table above, the temperature range widens as the ASHRAE Class increases. However, it is important to note that an A2 capable or A3 capable server is not designed to operate continuously at 32 or 35 °C. The allowable temperature range is the range in which the server or storage product can be operated for a limited period of time while remaining reliable, however this limited period of time is not universally defined across the sector. Although the max temperature for A2 conditions and above seem too high for servers, the benchmarking results of maximum temperature in Figure 3 show that a majority of them already declare that they can operate at A2 conditions, however without defining how long they could operate at this max temperature. Nearly 300 models of servers from 6 leading suppliers and nearly 200 models of disk storage from 7 leading suppliers show that a majority of servers and data storage products are capable to operate at A2 conditions. However, this does not necessarily mean that data centres are already operating at A2 conditions, despite that they are willing to as some data centre installers have expressed. Even if a very small portion of the servers are not ready to operate at A2 conditions, the whole data centre would need to ensure the reliability of these servers and operate at ca. 21 °C (the standard operating temperature for data centres up until recently) continuously, instead of being able to utilise free cooling for a period of time before exceeding 35°C. However, it is possible to separate equipment with different operating requirements in different zones of data centres, so some equipment can be allowed higher surrounding temperatures, but this is not often done because 1) current data centre buildings are not designed in zones, 2) moving equipment is very difficult to coordinate when the space is rented out to many clients and 3) because of the risk of unexpected failure and limited time and resources to carry it out without incentives.

4.4.2.2.Proposed requirements on servers and data storage products operating temperature Against the background described in the previous section, a specific formulation for the Ecodesign requirements on operating temperature was studied. The Ecodesign requirement could consist of two reporting obligations: ·the first one is the idle power consumption at high operating temperature (only in the case of servers, for which a testing method is defined under SERT24, whereas similar methods for data storage products are currently not available), ·the second one is on the declared operating condition class, i.e. a temperature range in which the product (either a server or a data storage product) is expected to reliably perform its operations. The Ecodesign requirement consisting in the compulsory presence of information on the product energy consumption and reliability at higher operating temperature is expected to foster the increase, when feasible, of the operating temperature of data centres and server rooms, without entailing risks on the system's reliability. The proposed approach would be to allow servers and data storage products to be placed on the EU market independently of their operating conditions class, but requiring information of the temperature range at which the product can work (leaving freedom to the manufacturer to choose such temperature range). Moreover, the requirement would be at product level, whereas the environmental benefit would be realised at system level (data centre/server room). The proposed solution is judged to be the best trade-off between the aim of solving the identified market failures (in particular the one related to the lack of functional information) and a precautionary approach towards the specificities of servers and data storage products market. Possible effects of the proposed information requirements on the operating temperature by servers and data storage products are shown in Table 17 , together with the associated energy savings at infrastructure level in 2030. The associated Power Usage Effectiveness (PUE) factor is assumed based on the PUE factors given in the preparatory study. A1 level requirement is assumed to have no impact on PUE factor: as most servers and storage can already achieve A2 level in BAU, manufacturers would leave the products as they are and so data centres would continue to operate as in BAU scenario. The policy scenario 3.1 assumes no requirement on operating conditions, therefore the same PUE level as BAU are assumed. The policy scenario 3.2 assumes that 30% of the data centres and server rooms would adopt higher operating conditions, and therefore achieve the associated PUE factor, due to information requirement. The policy scenario 3.3 assumes a mandatory requirement to reach the levels in Table 17 , therefore 100% adoption is considered. It is important to highlight that assuming 100% adoption (under option 3.3) is somehow overly optimistic, as it means assuming tout court that all (i.e. 100%) data centers would work at higher operating temperature, which is not realistic, as some specific users/applications will always require not to raise the operating temperature. Moreover, in legal terms making compulsory to place on the market only products capable to function at higher operating temperatures, does not automatically pose an obligation to use them in these temperature ranges in actual operations. The mandatory requirement applies only to the server/data storage devices manufacturers (who would be allowed to place on the market products capable to perform at a minimum operating temperature). The actual increase of the operating temperature in the data centers would be decided by the data center operators, who are expected to do so in presence of the relevant information at product level on its reliability and performance at higher operating temperature. Therefore, the actual realisation of the increase of the operating temperature lies in a behavioural change of data center operators, whose likelihood is more difficult to predict than ‘standard’ requirements based on a technical feature of the product and not relying in a change of the boundary conditions at system level (linked, in turn, to a behavioural change of a stakeholder). As shown more in detail in section 5 and in the sensitivity analysis of section 6.1.1, the difference between the environmental savings of option 3.2 and 3.3 lies in the adoption rate of data centers working at higher operating temperature. A very high adoption rate (100% hypothesis, with the limitations described above) is associated to the policy option 3.3, where the requirement on the higher operating temperature would be mandatory, whereas in the case of option 3.2 (compulsory information requirement) a much lower adoption rate (30%, see, Annex IV for the rationale) has been assumed. To conclude, on one side option 3.3 should be seen (from the specific point of view of the expected increase of the operating temperature) as an ‘extreme/overly optimistic’ scenario, as the actual adoption rate would be linked to a behavioural change of the data center operators, which is not easy to predict. On the other side, the adoption rate assumed under option 3.2 is judged as a plausible if not cautious value. Policy scenario 2019 2023 2026 2030 Savings, TWh/year Baseline A1 (PUE = 1.75) A1 (PUE = 1.68) A1 (PUE = 1.56) - PO 3.1 A1 (PUE =1.75) A1 (PUE = 1.68) A1 (PUE = 1.56) - PO 3.2 A2 (PUE =1.45) 30% adoption A3 (PUE = 1.30) 30% adoption - 5.67 PO 3.3 A2 (PUE =1.45) 100% adoption A3 (PUE = 1.30) 100% adoption - 20.8 4.4.3.Requirement on the idle mode energy consumption During use, servers spend a significant part of their operating life in 'idle state' (‘idle state’ means the operational state in which the operating system and other software have completed loading, the server is capable of completing workload transactions, but no active workload transactions are requested or pending by the system, i.e. the server is operational, but not performing any useful work). Full extensive reports or data on the utilization and load profile of servers are not available; based on existing reports8,, 99, it can be concluded that there are a large number of servers, in particular those ones operated in server rooms or small data centers, which are unused and others that are spending a considerable amount of time in idle mode waiting for transaction requests. A recent and complete analysis on the utilisation rate of servers in the EU has been finalised in the framework of a Horizon 2020 project, Eureca (www.dceureca.eu). Over 350 data centres of public administrations in the EU were investigated (ministries, universities, etc), the conclusion being that the average annual server utilisation rate (for the inspected data centres) is around 20%; in other terms, the rate of server time in idle mode is quite high, and this ‘pushes’ the average utilisation rate towards such a low value (