Summary

This report is carried out by Viegand Maagøe A/S for the Nordic Working Group for Circular Economy (NCE), Nordic Council of Ministers. The project investigates circular aspects of servers and data storage products and provides proposals for policy options, which can be implemented within the Ecodesign Directive framework

Directive 2009/125/EC of the European Parliament and of the Council of 21 October 2009 establishing a framework for the setting of ecodesign requirements for energy-related products.

. It also addresses other potential policy measures especially green public procurement criteria. The focus areas of the work are critical, environmentally relevant, and scarce materials.

Introduction (section 1)

The introduction describes the background and the focus areas of the report and shortly describes the most relevant policy context such as the ongoing revision process for the current ecodesign regulation for serves and data storage products and the ESPR regulation which will increase the focus on requirements beyond energy efficiency and intend to boost circularity of products.

Scoping and state of play (section 2)

Section 2 describes servers and data storage products and the relevant legislation with main focus on resource efficiency and especially on scarce and critical raw materials (CRMs) and other environmentally relevant materials. Other environmentally relevant materials in servers are primarily plastics.

The main elements of the products are shortly described as well as some important aspects with regard to the expected technical evolution for servers and data storage products. It is found that:

A shift from HDDs (Hard Desk Drives) to SSDs (Solid State Drives) is ongoing, but a total replacement is not foreseen in the near future as HDDs and SSDs have different functionalities. HDDs provide high capacity at lower cost for “cold” data, whereas SSDs outperform “warm” data which needs to be accessed more rapidly and more frequently.
Quantum computing is still a technology in its very early stages, but the technology is already being tested at large scales. If it overcomes its technical barriers, it has the potential to become a market disruptor.

Regarding on-premises servers or cloud bases solutions there has been a paradigm shift towards data virtualization and the utilization of Cloud Data Centres. Although there appears to be consensus that Data centres handle most of the data traffic, there seems to be less of a clear trend in regard to where the majority of servers can be found.

Section 2.3 describes the background for the European and Nordic focus on critical and scarce raw materials and addresses shortly why servers and data storage products are relevant in this context (this is further developed in section 4). Main findings are that the need for CRMs in Europe will increase significantly over the coming decades and that this will cause significant supply risks because the majority of the materials is supplied from countries outside the EU (especially from China). Another finding is that there are various reserves of CRMs in the EU and in the Nordic countries which are currently not utilized (mined).

Legislation (section 3)

This section briefly describes various legislation, voluntary measures and standards for servers and data storage products with a focus on European measures. The content is used as input and inspiration for development of policy measures in section 7.

The described measures and standards are among others:

The current ecodesign regulation for servers and data storage products (EU/2019/424)
The ecodesign and energy labelling regulations for smartphones and tablets as examples of regulations with extended material efficiency requirements
The EU GPP criteria (Green Public Procurement criteria) for servers, data storage and network equipment.
EU Code of Conduct on Data Centre Energy efficiency
Data Centers (DE-UZ 228) - Blue Angel
EU material efficiency standards (the so-called EN 4555X series of standards).
Data sanitation/data deletion standards

Material Aspects (section 4)

This section identifies and analyses the specific technical aspects related to material efficiency and circular economy of servers and data storage products especially regarding scarce, environmentally relevant, and critical raw materials.

Based on literature and dialogue with stakeholders it is concluded:

That servers and data storage products include various CRMs and precious metals, but that the amount especially for CRMs are small per product and component. In addition, the content varies from product to product and from component to component. For instance, the content of CRMs in PCBs varies considerably (due to size, grade, application, included components, manufacturer etc.). The products do only include small amounts of plastics (fans, cables etc.).
The lifetime of servers varies, and the tendency is that the lifetime is shorter in large data centres than in server rooms. In general, the actual lifetime is shorter than the technical lifetime especially in large data centres.
That there has been a slowdown in the increase in energy efficiency performance for servers and data storage products meaning that measures to prolong the lifetime is more relevant than previously.
That there is already an established circular thinking system in datacentres, where the equipment is repaired and recycled, but there is a lack of efficiency due to different interests and approaches of stakeholders along the different life cycle stages. Very important aspects with regard to reuse are availability of firmware and software updates and secure data deletion.
That servers are to some extent modular designed. It is possible to replace some larger parts/components when the servers are in operation, but that there is a lack of modularity and standardisation for the other components and parts of components (too many fixings/fasteners, inconsistent location across models and generations etc.).
That availability of software and hardware updates is of high importance for the lifetime and reuse of servers and data storage products. As software is generally not supplied by the manufacturer with the product, ecodesign regulation on software induced obsolescence might not be possible to implement, but the issue could be addressed through other measures such as Green Public Procurement (GPP).
Various standard with regard to data deletion exist and different appropriate deletion methods can be used depending on the data's sensitivity. But there is among operators (especially for the smaller server rooms and data centres) concerns about the data security, and this might hinder reuse of the products. Further information or education could help to create larger trust in secure data deletion and the appropriate methods to apply.
That increased information on the content of CRMs in servers and data storage products could support the possibilities for increased recycling. This could be through extended product information requirements in a revised ecodesign regulation servers and data storage products or requirements for a digital product passport. Work on developing and preparing a standards-based Digital Product Passport (DPP) aligned with the requirements of the Ecodesign for Sustainable Product Regulations (ESPR) is ongoing under the European CIRPASS project with focus on the electronics, batteries, and textile sectors (CIRPASS, n.d.).
That possibilities for substitution of highly critical CRMs in the ICT sector (Information and communications technology sector) do exist, but that the majority of potential substitutes are currently in the research and development stage, and that market-ready solutions are scarce. However, the physical properties and behaviour of the various materials at atomic level is very particular and the potential for substitution or change of design is very limited/impossible for many components in the foreseeable future.
That it is possible both to substitute plastic types and to reduce the use of plastics, but also that the amount of plastics in servers and data storage products are limited. As for CRMs physical properties of the materials are important and this reduce the possibilities for substitution and use of recycled plastic in servers and data storage products.
That there is a very low recycling rate of CRMs from servers and data storage products and that the main barriers are lack of recycling facilities and market infrastructure for recycled CRMs.
That the PCBs are both the component with the highest environmental impact and with the highest scrap price. PCBs have been identified as the most environmentally impactful components of DC equipment and the ones with the highest economic and environmental benefits if recycled by take-back schemes.

Environmental impacts (section 5)

This section shows that the highest environmental impacts for servers and data storage products are related to the life cycle stages material extraction (mining and extraction process) and the use phase due to intensive energy consumption. When we in this study are only dealing with impacts related to the materials used in the products the most important stage is the mining and extraction.

The main environmental impacts of mining activities include:

Production of large quantities of extractive waste and tailings
Risks from collapse of Extractive Waste Facilities
Acid mine drainage (AMD)
Metal deposition and toxicity
Loss of Biodiversity and Habitat
Other social impacts such as occupational health and safety violations that have effects on worker’s lives, employment conditions including long hours, low wages and temporary contracts.

The importance of the impacts from mining and extracting activities reinforces the need for durability, repairability, and reuse requirements.

For the manufacturing process the impacts are to a high extent related to a huge amount of electricity consumed during the energy intensive production processes of semiconductor components but other impacts relate to a high consumption of water during the manufacturing process and pollution with metals rejected from the production plants.

There are no relevant impacts of the materials embedded in the products in the use phase.

Recycling processes produce environmental impacts as well, depending on the process used and where it is carried out. Impacts are among others related to energy consumption. A larger share of e-waste still ends up being exported illegally and is handled by informal recycling methods which have worse environmental impact than formal recycling processes. Informal recycling results in emission of toxic materials to the environment. Informal recycling is attractive from a cost perspective with the use of nonskilled manual labour, and a disregard of environmental or health hazards.

Policy options (section 6)

The previous sections have identified material aspects of servers and data storage products and addressed the most important impacts.

Section 7 of the report identifies the relevant policy options with the aim to reduce the use of CRMs and plastics in servers and data storage products, and increase reuse, recycling, and recovery. The policy options are structured according to the waste hierarchy.

Policy options for implementation within the ecodesign framework, for green public procurement and other policy options are identified.

The policy options for ecodesign are:

Type	Measure	Specification	Section
Avoid	Ban the use of CRMs	Ban the use of CRMs in all other parts than in electronic components for instance in the chassis (enclosure or cabinet)	4.3.1.2
	Ban the use of CRMs	Ban the use of specific CRMs with high risk of depletion and supply. The specific CRMs would need to be further investigated.	4.3.1.2
	Restrict the number of CRMs	Require that only a limited number of CRMs can be used in specific products or components	4.3.1.2
	Ban the use of non-recyclable plastics	Require that the plastics used should be limited to ones with established high recyclability rates	4.3.2
	Ban the use of plastics	Ban the use of plastics in specific components (where alternatives are available)	4.3.2
Reduce	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
Reduce	Limit the use of virgin CRMs and plastics	See policy option related to reuse.	6.2.3
Reuse	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. . Should include all main elements in the server and data storage products. Spare part should among others include data storage devices (HDDs, SSDs, etc.), Motherboard, PCBs, RAM, CPUs, GPU, chassis/racks, fans, PSUs, integrated switch, capacitors, batteries, RAID controllers, and network interface cards.	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. (the appropriateness of this should be investigated further).	4.4.8
		In case 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	4.4.8
Recycle	Design for recycling	Se requirement for Disassemblability above.	4.5.1
	Design for recycling	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
	Reduce the number of different plastics used.	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 placed close to name of the product and/or in the Digital Product Passport	4.4.7

Policy options for public procurement

The following policy measures are proposed for public procurement as supplement to the proposed ecodesign policy options:

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

Other policy measures

In addition, the following other measures dealing with voluntary initiatives, harmonizations etc. are proposed:

Creation of an EU Code of Conduct for Data Centre Circularity in line with the EU Code of Conduct for Energy Efficiency of data centres
Harmonization and improvements on data deletion to prevent that standards recommend destructive data deletion and to creating of standards to ensure a high data security level
Update of design brief to ensure that servers and data storage products manufactured outside EU (in Asia etc.) and imported EU are design to minimise the use of CRM.
Due diligence requirements on economic operators who place on the market or put into service servers and data storage products in line with the ones in the new battery regulation.