Comprehensive sustainability for data centres – proposed EU rating scheme needs expansion
CSC welcomes the establishment of an EU-wide data centre sustainability rating scheme. For full delivery, however, the rating scheme and the label still need to be tuned to better capture overall sustanability through improved waste heat reuse indicators and life-cycle-based rating.
The sustainability of the ICT sector is central to achieving the EUs climate objectives and to safeguarding the long-term competitiveness of the industry, which cannot overlook ambitious climate, energy and environmental commitments. CSC welcomes the establishment of an EU-wide data centre sustainability rating scheme and appreciates the effort of the draft regulation to address the sustainability during the operational phase of data centres. A transparent data centre label applied uniformly across the EU allows informed comparisons and choices, incentivising sustainable data centre practices. CSC thus supports a single set of PUE and WUE thresholds across all Member States, with Cooling Degree Days (CDD) shown on the label and an explanatory document for context.
To deliver its full potential, however, the rating scheme and the label still need to be tuned to better capture overall sustanability through improved waste heat reuse indicators and life-cycle-based rating. We positively welcome the suggestion that the energy needed to make waste heat reusable is subtracted from the total data centre consumption in the reporting. This compensates for the inherent tradeoff between energy reuse and PUE, creating a level playing field that encourages data centres towards greater energy reuse in the future for better overall sustainability.
However, having waste heat reuse only as readiness and as a binary yes/no doesnt fully support this. At the very least this should be complemented by a badge indicating that waste heat is actually in use outside the data centre. Moreover, for data centres delivering waste heat, the Energy Reuse Factor (ERF) indicator must be shown on the label to indicate how well and efficiently a centre reuses energy externally. Being already reported based on the regulation 2024/1364, it would not create additional burden for operators. But by demonstrating concrete support to green transition and positive contribution to local economy, it can be a powerful tool to advance sustainable solutions.
Energy purchases backed by guarantees of origin should be treated on an equal footing with power purchase agreements (PPAs) in the reporting, as guarantees of origin are explicitly recognised under the EU Renewable Energy Directive as a valid means of demonstrating renewable energy use and should therefore be marked in green on the label. The directive sees them as a key tool for consumer information as well as for the further uptake of renewable energy purchase agreements. The intention of the guarantee of origin is that consumers can trust that the energy marketed and sold as renewable is in fact produced from renewable energy sources, thus green. This should not be undermined by marking it in yellow. In many respects the proposal aligns the scheme with other EU legislation (e.g. by making the WUE indicator compatible with EU water policy directives). This is positive and should extend also to renewable energy.
Finally, the scheme needs to cover the entire lifecycle of a data centre, from construction and operation through to decommissioning. The construction footprint is best reduced by prioritising brownfield sites, where existing facilities are repurposed rather than building anew. CSC therefore recommends adding on the label a simple yes/no indicator to identify whether a data centre is located on a brownfield (i.e. repurposed) site. This would promote the reuse of existing infrastructure over greenfield development, most likely reducing costs and environmental burden. In addition, an indicator on reuse and recycling rates at the decommissioning phase should be developed. A comprehensive, lifecyclebased rating scheme would provide a strong foundation for advancing efforts to reduce the climate and environmental footprint of energyintensive industries through EU regulation, funding programmes, KPIs and incentives, and the opportunity must be seized already now.
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Irina Kupiainen
Irina Kupiainen is responsible for CSC’s public affairs.