DIGITALEUROPE Comments on the JRC report on Analysis of material efficiency requirements of enterprise servers

DIGITALEUROPE regrets that there was no opportunity to comment on the JRC report on the material efficiency of enterprise servers before its final publication. We have serious concerns with the fundamentals such as technical feasibility, economic and environmental viability. We are also concerned with the formulae, rationale, in addition to the specific recommendations. Due to possible misinterpretations and omissions, we are issuing this unsolicited comment.

The report notices the scarcity of available research on material efficiency of servers (p.15) and tends in consequence to use general IT equipment or even WEEE based publications and project information (e.g. p.26.ff on the GreenElect project or pages 23-26 on ITIA-CNR) that does not represent adequately the server situation. A case in point is the figure on page 20 displaying the role of independent operators in the ICT equipment sector: in the case of servers OEMs refurbish and sell the refurbished servers with guarantees to customers themselves. This is not reflected in the graph.

Rather than drawing on general publications it would have been interesting to concretely trace existing reuse/refurbishment practices (and estimate reuse percentages for specific spare parts of high value) and EoL collection and recovery depending on the data centre operators (OEM controlled as well as typical operators such as Telcos, etc). As servers are B2B products, partly under lease or OEM ownership, collection rate and material recovery are much higher than for other ICT equipment. OEMs estimate that the total recovery rate is at about 97%. From our perspective the JRC missed an opportunity to provide interesting and valuable insights in to server reuse and recycling.