6 Policy options
6.1 Introduction
The previous analyses show that servers and data storage products include various CRMs and precious metals, but that the amounts especially for CRMs are small per product and component. The components with the largest content of valuable materials (including precious metals) are the printed circuit boards (PCBs), which also are the components containing the largest amounts of CRMS. The analyses also show that precious metals are largely recycled, but that recycling of CRMs is only carried out for very few materials and only to a much lesser extent. The largest barriers for recycling of CRMs are the small amounts present in the products and the lack of a market infrastructure.
In addition, the analyses show that the actual lifetime of the servers and data storage products is shorter than the technical lifetime and that the lifetime tends to be shorter in large data centres than in smaller server rooms. Important barriers for lifetime extension and reuse are:
- lack of design standardisation between models and brands
- lack of design for disassembly and repair
- firmware and soft obsolescence
- lack of information and trust regarding secure data deletion methods.
Regarding plastics, it is found that data servers and storage products only include a small amount and that the main part is in the fan.
This section uses the information and analysis of previous sections for identification of policy options aimed at regulating scarce, environmentally relevant, and critical raw materials in this case CRMs and plastics. The policy options intend to reduce the use of CRMs and plastics in servers and data storage products, and increase lifetime, reuse, recycling, and recovery.
Focus will be on potential policy options that could be implemented within the European ecodesign framework (including ESPR). Various of the mentioned options will require further analysis and development of standards and some of them will probably be difficult to implement in the shorter term.
In some cases, it is difficult to set ecodesign requirements because it is too premature in relation to the technical development, lack of standards or the requirements are more related to a service than a product. Other policy measures such as public procurement criteria, and voluntary agreements will therefore also be addressed.
The policy options will be structured according to the waste hierarchy as shown in Figure 22. The waste management hierarchy places top priority on avoiding waste generation and reducing waste generation as much as possible. After that reuse and recycling has a higher priority than energy recovery and disposal. It should be noted that some policy options are relevant for more than one level in the hierarchy. No policy options are proposed relating to energy recovery and disposal, as these two waste management options are not circular.
Figure 22. Waste Hierarchy Diagram (Source: Own creation).
6.2 Policy options ecodesign
6.2.1 Avoid
It is not possible to fully avoid the use of CRMs in servers and data storage products, but the use might be minimized, and CRMs should only be used where these materials are necessary for the functioning and performance of the products. A total ban could be considered for specific CRMs with high risk for depletion if it is possible to substitute them with other materials
The application of any banning requirement will only be possible in case viable substitutes are identified.
When materials are very expensive and the supply challenged, the manufacturer will typically work to minimize the use. However, this could be supported by the following policy options:
Measure | Specification | Section |
Ban the use of CRMs | Ban the use of CRMs in all other parts than in electronic components (where alternatives are available) for instance in the chassis (enclosure or cabinet) | 4.3.1.2 |
Ban the use of specific CRMs with high risk of depletion and supply (where alternatives are available). Which CRMs would need to be further investigated. | 4.3.1.2 | |
Restrict the number of CRMs | Require that only a limited number of CRMs must be used in specific products or components | 4.3.1.2 |
Ban the use of non-recyclable plastics | Require that plastics used should be limited to ones with established high recyclability rates | 4.3.2.2 |
Ban the use of plastics | Ban the use of plastics in specific components (where alternatives are available for instance in non-electronic components) | 4.3.2.2 |
Table 30. Proposed policy options for the avoidance of CRMs and plastics
It will probably not always be possible to ban or restrict the use of specific CRMs in servers and data storage products or components due to functionality and/or security issues. So, if a ban is introduced in an ecodesign regulation it will be necessary to include a kind of exception. It could for instance be formulated in this way:
- If it is not possible to avoid the use of a specific CRM due to functionality of the product and/or security issues, the need to apply the CRM should be justified in the technical documentation of the product.
Banning of materials is controversial within the ecodesign framework because requirements should be based on environmental performance of the product. However, the current ecodesign regulation for electronic displays includes a requirement that prohibits the use of flame retardants in the enclosure and stand of electronic displays
Commission Regulation (EU) 2019/2021 laying down ecodesign requirements for electronic displays. Annex II, D. 4.
4. Halogenated flame retardants
The use of halogenated flame retardants is not allowed in the enclosure and stand of electronic displays.
Figure 23. Prohibition in ecodesign regulation for electronic displays. Commission Regulation (EU) 2019/2021.
Restriction of substances will probably be possible to implement within the Ecodesign for Sustainable Products Regulation (ESPR).
In the preamble 22 of the proposed ESPR regulation is mentioned
Proposal for a Regulation of the European Parliament and of the Council establishing a framework for setting ecodesign requirements for sustainable products and repealing Directive 2009/125/EC. COM/2022/142 final. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=COM%3A2022%3A0142%3AFIN. There might be changes in the final act, which is not yet published.
- Union law on chemicals and food, however, does not allow addressing, through restrictions on certain substances, impacts on sustainability that are unrelated to chemical safety or food safety. To overcome this limitation, this Regulation should allow, under certain conditions, for the restriction, primarily for reasons other than chemical or food safety, of substances present in products or used in their manufacturing processes which negatively affect products’ sustainability.
The proposed requirements would all require further assessment of the feasibility and improvement potentials.
6.2.2 Reduce use
The use of CRMs and plastics could be reduced by various means. All measures increasing the lifetime of the servers and data storage products will reduce the use of materials because fewer new products will need to be manufactured. For measures to extend the lifetime see section 7.4.
Another measure is to reduce the use of virgin CRMs and plastics by increasing the use of recycled materials. As very few CRMs are recycled so far (there is no or very limited supply of recycled materials) it is still too premature to introduce an ecodesign requirement on minimum share of recycled content for CRMs in servers and data storage products. However, in the longer term, when a stable secondary CRM market is established, it could be a relevant policy option. A stable market requires that the CRMs are recycled and offered for sale on a regular basis and that the materials are bought by the manufacturers and components etc. In the shorter term an information requirement about the content of recycled materials could be considered.
The major hurdle is according to stakeholders the lack of recycling infrastructure, hindering progress toward a circular economy. Redesigning products for easier repair are seen as insufficient without significant improvements in recycling and material collection at the end of life. In addition, the importance of limiting the presence of flame retardants in materials for recycling is emphasized.
It is therefore recommended to assess the possibilities for developing relevant recycling and creating a market infrastructure for recycled CRM. In addition, it is recommended to introduce requirements facilitating recycling and to focus on recycling of a small number of specific CRMs used in larger quantities in servers and data storage products and not on all CRMs used.
The supply of recycled engineered plastics could also be improved, by limiting the number of different plastics used in servers and data storage products and standardizing which types to be used. This would create larger and cleaner waste streams and might facilitate the creation of closed loop recycling.
Potential policy options to support recycling CRMs and plastics are among others:
Measure | Specification | Section |
Limit the use of virgin CRMs and plastics | Information requirement to facilitate recycling (this could be information requirement regarding content of CRMs, disassembly requirements etc.) | 4.5 |
See policy option related to reuse. | 6.2.3 |
Table 31. Proposed policy options for the reduction of CRMs and plastics
6.2.3 Reuse
The next step in the waste hierarchy is reuse – meaning direct reuse of products or components. Direct reuse is when a product can be easily repaired or perhaps simply cleaned, thereby leaving the waste category, and returning to the market as a usable product or component thereby extending the lifetime of the product.
If a larger share of products is directly reused, less materials including CRMs will have to be mined and included in products. Reuse and refurbishment are recommended when the component is still energetically efficient in comparison with new products.
Extended lifetime by repair etc. could, however, lead to increased use of energy. This should be taken into account but is not dealt with in detail in this project. However, various stakeholders have indicated that the improvements in energy efficiency of new generations of servers has slowed down, meaning that the products can be used for longer time and upgraded rather than replaced, without compromising energy efficiency initiatives substantially. One thing that was brought up by stakeholders as standing in the way of upgrading servers rather than replacing them, is the lack of standardization between brands and generations, which greatly limits the possibility of upgrading products with new parts.
To extend the lifetime it is also important to increase the durability of the products, for instance by designing them to be easier to repair. In general servers and data storage products are durable and the actual lifetime is shorter than the technical lifetime. However, some studies indicate that the down time and failure rate increases by a notable amount over the course of the technical lifetime of the product.
It is relevant to see how relative obsolescence can be pushed closer towards the absolute obsolescence of the products.
The current ecodesign regulation for servers and data storage products does include requirements ensuring that joining, fastening or sealing techniques do not prevent the disassembly for repair or reuse.
According to the CEDaCI (WeLOOP, 2020) project the reuse, refurbishment and collection rates are higher in big datacenters (which have internal reuse mechanisms), than in smaller and private data centers. It might therefore be relevant to propose requirements supporting more reuse in smaller data centers.
The ecodesign regulation for smartphones and tablets (EU/2023/1670) could serve as an example for repair requirements for servers and data storage products even though the products are very different.
Various measures that could help improve reuse of the products are still too premature to implement within the ecodesign framework, but they could be implemented within public procurement or voluntary measures. This is for instance measures dealing with standardisation of components or modularity of components. Such measures are therefore only mentioned in section 7.3.
Table 32. Proposed policy options for the reuse of servers and data storage products
Measure | Specification | Section |
Availability of spare parts | Specific listed spare parts shall be available for at least 8–10 years For smartphones the period for availability of spare parts is until at least 7 years after the date of end of placement on the market. | 4.4.1 |
Disassemblability | Fasteners shall be removable and the process for replacement shall be feasible with no tool, or with basic tools. The process for replacement shall be able to be carried out in a use environment and shall be possibly to be carried out by a generalist or expert (depending on the component). This should at least apply to the components in the spare part list. | 4.4.3 |
Standardize design between brands and generations | Require that some specific parts of servers are standardized (for instance racks, sockets of CPUs, and connectors. across brands and generations. | 4.4.4 |
Improve requirements on secure non-destructive data deletion | Require that a secure data sanitization functionality that deliberately, permanently, and irreversibly removes or destroy the data stored on a data storage device shall be made available for the deletion of data contained in all data storage devices of the product. | 4.4.5 |
Information requirement regarding the presence of the secure data sanitization functionality, its application and degree of security, and the supported data deletion standards. | 4.4.5 | |
Require that the functionality for data sanitization can provide a certificate attesting that data are deleted from the data storage product with a high security level. | 4.4.5 | |
Improve the requirements on firmware updates | Require that software and firmware updates including security updates and updates to correct firmware issues should be available free of charge for at least 8–10 years after the date of end of placement on the market of the product | 4.4.6 |
Require that software updates do not make existing hardware and products obsolescent | 4.4.6 | |
Require that essential firmware and software licenses are supported at least for a period corresponding to the technical lifetime of the product (8 to 10 years) and that frequent and necessary updates are provided during the period. | 4.4.6 | |
Prevent part pairing Parts-pairing is a software serial identification system ensuring that all the components in a device are matched to the device. If a component is replaced (with an identical one) by a third-party repairer, the system will identify that component as “other” and will not function appropriately. | Prohibit the use of part pairing of serialised parts ‘Serialised part’ means a part which has a unique code that is paired to an individual unit of a device and whose replacement by a spare part requires the pairing of that spare part to the device by means of a software code to ensure full functionality of the spare part and the device. | 4.4.8 |
In case the spare parts to be replaced are serialised parts, require that manufacturers provide non-discriminatory access for professional repairers to any software tools, firmware or similar auxiliary means needed to ensure the full functionality of those spare parts and of the device in which such spare parts are installed during and after the replacement This requirement is in line with requirement regarding part pairing of serialised parts in the ecodesign regulation for smartphones and tablets (EU) 2023/1670. | 4.4.8 |
6.2.4 Recycle
Plastics and CRMs are the most problematic materials to be recycled in servers and data storage products. Furthermore, the number of different CRMs in servers and data storage products is high and the concentrations are low, which makes recycling and investments in new capacities less economical. In newer servers it is indicated in the ongoing ecodesign study, that only around 1% of newer servers consists of plastics (the rest is 68% metal and 31% electronics). A JRC study from 2015 listed the different plastics found in a typical server at the time (JRC, 2015). The list showed that the majority of plastics used were of a type that is not currently recyclable. Combining this, the indication is the same for plastics as for CRMs, the numbers are high, and the weight is low.
In order to improve the recycling of CRMs and plastics, the disassemblability could be improved. Increasing disassemblability means that it becomes easier and faster to take the products apart, thus improving the economy of recycling. As an example, the CEDaCI project found that with the current server designs and substantial amount of time was required to completely dismantle the PSU (WeLOOP, 2020). Just one PSU was found to include between 10 and 15 screws which took the researchers 6 minutes to fully dismantle. Standardizing which plastics are used, and to the extent possible requiring that they are of types that are recyclable, would further facilitate the recycling of plastics found in servers and data storage devices. This will, however, require alignment between the manufacturers of products, parts and components, and thus would involve many stakeholders. It will have to be determined if the reward outweighs the required efforts. Lastly, as evert CRM needs specific handling and treatment in order to be reclaimed it is a simple necessity for the recyclers and refiners to know which CRMs are present in the products and how much.
The proposed policy options are presented below.
Table 33. Proposed policy options for the recycling of servers and data storage products
Measure | Specification | Section |
Design for recycling | Se requirement for Disassemblability above. | 4.5.1 |
Require that PCBs are produced in the same color, or in specific colors depending on their content | 4.5.4 | |
Reduce the number of different plastics used | Require that plastics should be of the types an established recycling infrastructure (ABS, PP, PA, PC, PC/ABS, HIPS, PE). If not possible the manufacturer should document, why other plastic types are necessary in the technical documentation. | 4.5.2 |
Prohibit the use of polymer blends and foams. If not possible the manufacturer should document, why these materials are necessary. | 4.5.2 | |
Information about content of CRMs in products and components | Require that manufacturer shall provide information about the content of critical raw materials in specific components (such as PCBs, HDDs and SSD, PSUs, CDUs and capacitors. Information should be supplied for all materials in the most recent EU list of critical raw materials, when the product is placed on the market. | 4.5.1 |
Require that the above-mentioned information should be available in a QR code placed close to name of the product and/or in the Digital Product Passport | 4.4.7 |
We propose to update the current information requirements in regulation (EU) 2019/424, among others with an extension to inclusion of other CRMs. In addition, introduction of a digital product passport could improve the exchange of information and declaration of content of materials in products and components.
Inspiration for information requirement could be found in the regulation for smartphones and tablets. According to this regulation manufacturers shall provide information about the content of some specific CRMs in indicative weight ranges:
Indicative weight range of the following critical raw materials and environmentally relevant materials:
- cobalt in the battery (weight range: less than 10 g, between 10 g and 20 g, above 20 g)
- tantalum in capacitors (weight range: less than 0,01 g, between 0,01 g and 0,1 g, above 0,1 g)
- neodymium in loudspeakers, vibration motors, and other magnets (weight range: less than 0,2 g, between 0,2 g and 1 g, above 1 g).
It should be investigated if the information requirement could be set without the use of weight ranges (the market actor shall provide information about the content in the product or component of all CRMs on the EU CRM list). If weight ranges are used, it is important that the weight ranges make it possible to indicate small amounts because various CRMs are only present in very small quantities in the products/components. The standard “EN 45558:2019 General method to declare the use of critical raw materials in energy-related products” can be used in relation to this requirement.
Some requirements may need the development of verification and certification schemes to ensure compliance and reliable information. For example, ERMA (European Raw Material Alliance) has proposed an EU sustainability standard and certification scheme, to be developed by the European Commission with the support of the ISO/TC298 Rare Earth group, the leading standardisation initiative in rare earths worldwide today. This scheme will rely on traceability and independent auditing of standards.
6.3 Other policy options
6.3.1 Green Public Procurement.
Green public procurement criteria could be used as a supplement to ecodesign regulations, in cases where it is still too premature to implement ecodesign requirement or where the measure is more related to a service and therefore is more relevant for procurement contracts. There already exists green public procurement criteria for data centres, server rooms and cloud services, which include technical requirements for servers and data storage products (mainly energy efficiency requirements) and some requirements for end-of-life service.
Experiences have shown that only a few public authorities use the GPP criteria in their procurement process and that the criteria are too difficult to interpret and use (see more in section 3.2.1.1). Additional and better explained guidelines could potentially help both suppliers and procurers in their understanding and application of the GPP criteria.
Based on interviews with stakeholders we below propose several criteria that could be implemented in public procurement in addition to the existing ones. Some of the measures mentioned below are also mentioned in the section with ecodesign policy options, but they might be easier to implement in procurement criteria/contracts or in voluntary schemes.
Proposals for public procurement criteria:
- Include criteria regarding:
- non-destructive and secure data deletion and provision of a certificate
- reused products in procurement (for instance a minimum share of recycled components)
- attempted reuse/reselling before recycling
- Require that:
- CRMs come from mines with responsible mining (for instance IRMA’s standard for responsible mining)
- providers are classified as sustainable under the EU Taxonomy
- suppliers are classified as sustainable under the EU Taxonomy
- providers have not signed contracts requiring the destruction of servers, when taken out of service
- IT consultants providing IT services has green skills
- products bear and ecolabel (type 1 - third part certified)
- some specific highly critical materials are not used in products or specific components
- Challenge the lengths of contracts and require that contracts take into account reuse and recycling
- Look into
- The possibility of establishing a circular economy index to be used in public procurement.
- Making a scoring/weighting system in the criteria to assist procurers
Input from stakeholders
“We experience that the GPP criteria are generally not used, as those responsible for the tender lack the necessary competencies to assess the importance of the individual requirements and also to determine what the additional cost of setting these requirements will be.”
“Procurers do look to the GPP for inspiration, but it is difficult to apply the criteria and translate them to a local context. It would help to have the GPP geared more towards direct implementation in a procurement tender.”
“It's important that the GPP focus on the measurement points that is subject to requirements within the EU. This could be information required under the EU taxonomy, code of conduct, or Digital Product Passport.”
“If you can set minimum criteria as award criteria that give extra points for extending the lifetime of their products, it could help move the market. Here the procurers need help knowing what areas to prioritize and how much weight to assign to different factors.”
6.3.2 EU Code of Conduct
The Joint Research Centre has created the European Code of Conduct for Data Centres (EU DC CoC)
The EU Code of Conduct for Data Centres – towards more innovative, sustainable and secure data centre facilities. The EU Code of Conduct for Data Centres – towards more innovative, sustainable and secure data centre facilities - European Commission (europa.eu)
The initiative sets voluntary standards for participating companies and focuses on key issues and agreed-upon solutions outlined in a Best Practices document. This document is updated annually to incorporate the latest technological advancements.
A similar initiative could be established focusing on circular economy best practices. Thus, we propose the following policy option:
- Creating of an EU Code of Conduct for Data Centre Circularity
This could among others include that servers should not be shredded unless data security reasons require it. It should be made sure that the exemption does not become a loophole.
6.3.3 Harmonization and improvements on data deletion standards
The assessed standard NIST 800-88r1 often recommend destructive data deletion methods, that do not render the servers and data storage devices reusable. Thus, it would be relevant to look into the possibility of making a harmonized European standard on data deletion where the current standards available are revised in order to address methods and recommendations that hinder circularity. The standards should furthermore ensure unrecoverable deletion of the data, in alignment with the proposed improvements of the current ecodesign regulation on secure non-destructive data deletion.
6.3.4 Update of design brief
As the designers and producers are mainly located in Asia, European stakeholders should update their design brief and specifications and include a mandate to minimise the use of CRMs in servers (WeLOOP, 2020).
6.3.5 Due diligence
The new Battery regulation establishes due diligence requirements on economic operators who place batteries on the market. It covers the supply chains of cobalt, natural graphite, lithium, nickel, and other chemical compounds. Economic Operators would also need to establish and operate a system of controls and transparency over supply chains and incorporate supply chain policies into agreements with suppliers (e.g. including risk management measures). These must be consistent with OECD Due Diligence Guidance for Responsible Supply Chains of Minerals for Conflict-Affected and High-Risk Areas (OECD, 2016). This type of requirement could be extended to ICT products for specific raw materials with high risk of illegal sourcing, or high environmental and social risks.
6.3.6 Basel Convention E-waste Amendments.
The Basel convention works to control transboundary movements of hazardous wastes and their disposals including e-waste, which is one of the fastest growing waste streams in the world. It could be considered to develop further mechanisms under this convention to prevent informal recycling of e-waste. It could for instance be increased reporting obligations to prevent illegal traffic of e-waste.