1 Introduction

The Nordic Working Group for Circular Economy (NCE) under the Nordic Council of Ministers (NCM) wants to support the development of the European Union’s product policy, more specifically the increased focus on environmental aspects and circular economy in the EU Ecodesign Directive.

The study focuses on possible regulation of scarce, environmentally relevant, and critical raw materials through information requirements, design for dismantlability and minimum share of recycled raw materials. It identifies current regulations, legislations, and standards and defines and recommends relevant policy options especially related to scarce, environmentally relevant, and critical raw materials.

The background of the study is the increased focus on designing sustainable products and circular economy in European product policies. Examples of this is the revision of the Ecodesign Directive, which will be transformed into a new Ecodesign for Sustainable Products Regulation (European Commission, 2022a), and the Circular Economy Action Plan (European Commission, 2022b). The Ecodesign and Energy Labelling Working Plan 2022–2024 (European Commission, 2022c), which was published in May 2022, also incorporates the possibilities of the existing EU ecodesign rules to strengthen the focus on the circularity aspects of ecodesign, in line with the Circular Economy Action Plan 2020.

The Ecodesign and Energy Labelling Working Plan 2022–2024 identifies three aspects to contribute to the circular economy, with a view of a future increased emphasis on circular economy, and potentially more product-specific requirements. These aspects are:

The Ecodesign for Sustainable Products Regulation (ESPR)

On 4^th December 2023 a provisional agreement was reached between the European Parliament and the Council on the Ecodesign for Sustainable Products Regulation. https://ec.europa.eu/commission/presscorner/detail/en/ip_23_6257

will replace the current Ecodesign Directive. It will be applicable to a broader range of products and make it possible to further expand sustainability requirements for the regulated products.

Requirements under ESPR will go beyond energy efficiency and aim to boost circularity, covering, among others:

An ecodesign regulation for servers and data storage products (EU) 2019/424 (European Commission, 2019) was adopted in 2019 and the first requirements was applicable from 1. March 2020 including the material efficiency requirements and the information requirements regarding Critical Raw Materials (CRMs). The review clause (Article 8) of the current regulation prescribes that the Commission shall assess the regulation and present the results to the Consultation Forum by March 2022. This deadline has not been met, but a review study is on-going and is expected to be finalised ultimo 2023. With regard to circular economy the review study shall address in particular the appropriateness of updating the material efficiency requirements for servers and data storage products, including the information requirements on additional critical raw materials (tantalum, gallium, dysprosium and palladium), taking into account the needs of the recyclers.

The scope of the study is enterprise servers (rack servers and blade servers) and data storage products as defined in the current ecodesign regulation for servers and data storage products. Data centres where these products are applied are one of the main providers of IT e-waste due to their interrupted activity and the high rates of equipment replacement.

The content of the study is based on input from stakeholders via a questionnaire, interviews, and a stakeholder meeting in combination with literature reviews. Comments from stakeholders are presented in text boxes in the report.