Lot 9 regulations overview

Lot9 regulations overview 

The Lot9 EU regulations, which started to come into effect in 2020 (but are constantly evolving), fall under the broader Ecodesign Directive and are critical for businesses that require or operate data centers. These regulations aim to enhance energy efficiency, promote sustainability, and reduce the environmental impact of data center equipment. Understanding and complying with these regulations is essential for any business in this sector. Since a lot of our partners are affected by this, we thought it would be a good idea to sum up the existing regulations and keep you updated on any new developments in the future.

What is Lot9?

Lot 9 regulations specifically target enterprise servers, data storage products, and related network equipment. The goal is to set minimum energy efficiency standards and design requirements that facilitate repairability and recycling. According to the EU, the effect of the ecodesign requirements set out in Lot9 regulations is estimated to result by 2030 in annual energy savings of approximately 9 TWh (approximately the yearly electricity consumption of Estonia in 2014). These regulations are part of the European Union’s broader effort to promote a circular economy and reduce carbon emissions (European Green deal)

Key requirements of Lot9 regulations

1. Energy efficiency standards:
   • Idle power limits: Lot9 sets strict idle power consumption limits for servers. This means that servers must consume less power when they are not actively processing data.

Source : COMMISSION REGULATION (EU) 2019/ 424 – of 15 March 2019

• Efficiency in active mode: There are also efficiency requirements for servers when they are in active use, which involves measuring the servers’ performance per watt of energy consumed.

Source : COMMISSION REGULATION (EU) 2019/ 424 – of 15 March 2019

2. Power supply efficiency:

1. • Internal power supplies: Lot9 mandates that internal power supplies must meet specific efficiency criteria, typically 80 Plus certification standards, which ensures high efficiency at various loads (20%, 50%, and 100%).

Historically, the Energy Star program by the EPA has set energy efficiency standards that also met other government regulations. However, Lot 9 requirements now mandate compliance for some previously exempt products. Depending on their classification as servers, server appliances, or data storage, products may or may not meet Energy Star criteria. Additionally, Lot 9 requires certain information to be available to end-users for a set period after the product’s last sale. Therefore, companies exporting to the EU must develop new testing and certification processes to meet these updated standards.

Source : COMMISSION REGULATION (EU) 2019/ 424 – of 15 March 2019

3. Material efficiency:

1. • Repairability and upgradability: In line with the circular economy EU goals , products must be designed to be easily repairable and upgradable. Companies now need to provide access to repair information and ensure that critical components can be replaced without specialized tools. These components include: data storage devices, memory, CPU, motherboard, expansion card/graphic card, PSU, chassis, and batteries.
   • Recyclability: Materials used in servers and data storage products must be easily recyclable. This involves using fewer types of materials and ensuring that components can be easily separated for recycling.

4. Information requirements:

1. • Product information: Manufacturers must provide detailed information about the product’s energy consumption, material composition, and instructions for disassembly and recycling.
   • Documentation availability: This information must be made available both on the product and through online platforms to ensure easy access for consumers and recycling professionals.

Details about what exactly should be disclosed is on Annex II part 3 of the COMMISSION REGULATION (EU) 2019/ 424 document.

5. Data erasure requirements:

You might remember our piece about data erasure vs HDD destruction. Well, the Lot9 EU regulations have introduced new data erasure requirements aimed at enhancing data security and privacy for IT products. These regulations mandate that data storage products, such as hard drives and solid-state drives, must include secure data erasure features. This ensures that all data is completely and irreversibly deleted before the devices are reused, recycled, or disposed of.

“The requirement on a functionality for secure data deletion could be implemented by means of technical solutions such as, but not limited to, a functionality implemented in firmware, typically in the Basic Input/Output System (BIOS), in software included in a self-contained bootable environment provided in a bootable compact disc, digital versatile disc or universal serial bus memory storage device included with the product, or in software installable in the supported operating systems provided with the product.”

Compliance with these data erasure standards not only allows the protection of sensitive information but also supports the circular economy by facilitating the safe and responsible reuse of electronic equipment. For detailed guidelines, you can always refer to the European Commission’s Ecodesign documentation.

Impact on MSPs and server users in general

While complying with regulations will involve some extra work in some areas (namely compliance and reporting), we firmly believe that it will be beneficial for your business overall.

In terms of operational costs, it will lead to significant energy savings by reducing power consumption in servers, thus lowering electricity bills. At the same time, the focus on repairability and upgradability will extend the lifespan of your infrastructure, cutting down on the frequency and costs of replacements and upgrades.

Your company’s environmental impact will naturally be much better, supporting broader environmental practices.This will also naturally translate into better market competitiveness as sustainability becomes a priority for both businesses and customers: you’ll be able to enhance your marketability as an environmentally responsible entity.

Data center operators must ensure their equipment adheres to Lot9 standards for compliance and reporting to avoid penalties and reputational damage. The requirement for detailed product information necessitates robust tracking and reporting systems to document compliance and provide transparency to stakeholders.

Future outlook

As we mentioned earlier, the Lot9 regulations are part of a dynamic regulatory environment that continues to evolve. They’re a good starting point, but they still fail to address some issues as FreeICT mentioned in their manifesto. European elections are coming up, so we will have a better idea of the direction the regulations will take after the results, but future updates are very likely to include:

• Stricter energy efficiency standards: Further reductions in permissible power consumption limits.
• Expanded scope: Inclusion of more types of data center equipment under the regulatory umbrella.
• Advanced reporting requirements: Increased demand for transparency in energy consumption and sustainability practices.

Businesses must stay informed about these developments to maintain compliance and leverage the benefits of sustainable operations.

At ynvolve, circularity and sustainability have always been embedded in our DNA, so you can be sure that we will closely monitor future updates on the Lot9 regulations and keep you informed of any evolution. In the meantime, if you have any questions or struggle to navigate the regulations or laws for your business, please feel free to contact our team of experts, who will always be very happy to help or chat about this!