DIGITALEUROPE's comments on the Ecodesign LOT 9 for Server and Storage Material Efficiency Requirements

DIGITALEUROPE would like to express its position on the potential inclusion of material efficiency requirements for the incumbent Ecodesign consultation forum on LOT 9 for enterprise servers and storage products. In summary, DIGITALEUROPE membership believes that material requirements cannot be set at this stage of the LOT 9 developments and that requirements should target the envisioned energy efficiency requirements only, as energy use represents 90% of the environmental impact. In addition, being a B2B market, the reuse and refurbishment of servers and storage devices is part of standard business practices, significantly contributing to the circular economy. Without industry standards on material requirements, there can be no legal requirements set, in particular for products with long development and life cycles such as servers and storage. We suggest to revisit material energy requirements when LOT 9 will be recast. We provide further justification for this position below.