As foreseen in the provisions laid down in Annex II to Regulation (EU)2019/424, manufacturers can – on a voluntary basis – declare a product model as being part of a server product family. For these product models, the manufacturer shall report certain (actually, most of the) information, such as idle state power or the active state efficiency, for the low-end and high-end performance configurations of the server product family (as laid down in Annex II.3.1). In terms of market surveillance of product models declared as being part of a server product family, Annex IV.1 to Regulation (EU) 2019/424 foresees that the Member State authorities can verify:
• the low-end performance configuration, or
• the high-end performance configuration, or
• a randomly selected or ordered model configuration.
In the case of a randomly selected or ordered model configuration, the declared values to be verified shall be the values for the high-end performance configuration only. In terms of testing, Annex IV.2.c foresees that the Member State authorities, in case the manufacturer declared the server to be represented by a server product family, test the low-end performance configuration or the high-end performance configuration of the server product family.
In the specific case of a randomly selected or ordered model configuration, this implies that the Member State authorities will test the high-end performance configuration of the server product family and, consequently, verify compliance with the Ecodesign requirements only for this configuration.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
There are only two categories of products in scope to Regulation (EU) 2019/424: servers and data storage products. Concerning the latter, Article 2.1.(10) of Regulation (EU)2019/424 states that ‘‘data storage product’ means a fully-functional storage system that supplies data storage services to clients and devices attached directly or through a network. Components and subsystems that are an integral part of the data storage product architecture (e.g., to provide internal communications between controllers and disks) are considered to be part of the data storage product. In contrast, components that are normally associated with a storage environment at the data centre level (e.g. devices required for operation of an external storage area network) are not considered to be part of the data storage product ’. This implies that, to understand whether a component belongs – or not- to a data storage product, one must determine whether the component is integral part of the data storage product architecture, or it is associated with the storage environment at data center level.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
As per the provision laid down in Annex II.1.2.1 to the regulation, manufacturers ‘shall ensure that joining, fastening or sealing techniques do not prevent the disassembly for repair or reuse purposes of’ a number of components (data storage devices, memory, etc..).
An elaboration of the technical features related to the ability of the product to be disassembled should be part of the standardisation deliverables in the framework of the ‘Standardisation request to the European standardisation organisations in support of Commission Regulation (EU) 2019/424 of 15 March 2019 laying down Ecodesign requirements for servers and data storage products pursuant to Directive 2009/125/EC of the European Parliament and of the Council and amending Commission Regulation (EU) 617/2013’.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
For the purposes of the regulation, in the case of servers declared as being part of a server product family, Annex IV.1 to the Regulation foresees that the Member State authorities can test the low-end performance configuration or the high-end performance configuration. As per definitions 21 and 22 of Annex I, these configurations always must contain (only) two data storage devices. Manufacturers will then sell a full range of (server) configurations within a server product family which may have more or fewer components than the two ‘designated’ configurations, i.e. the low-end performance configuration and the high-end performance configuration.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
When assessing compliance with regard to the requirements of the regulation for both partially populated and full populated server configurations, the partially populated configurations, such as 2-socket servers with only 1 processor installed, need to be tested as a separate product family from the fully populated configurations, and both product families are required to meet the applicable requirements for the number of processors installed.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
Servers with one or two processor sockets are subject to additional idle state power and active efficiency requirements as set out in Annex II.2 of the regulation. PSU efficiency and power factor requirements (Annex II.1.1), materials efficiency (Annex II.1.2) and information (i.e. data reporting) requirements (Annex II.3) are the same for all servers in scope to the regulation. To be noted that the regulation excludes from the scope servers with more than 4 processor sockets.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
It means that a given server node needs to be powered down first before swapping (without having to power down other server nodes in the system).
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
The information requirements listed under Annex II.3.1, consisting in the obligation to provide specific product information in instruction manuals and on the free-access websites, do not apply to custom made servers, made on a one-off basis. However, for custom made servers, made on a one-off basis, the information referred under Annex II.3.1 shall be part of the technical documentation to be prepared for the purposes of conformity verification by the Member States market surveillance authorities. Finally, the information requirements listed under Annex II.3.3 apply to custom made servers, made on a one-off basis.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
A given product family can have in excess of tens of thousands of possible combinations of components (separate, distinct configurations). This can include many different processor models with differing core counts and frequencies as well as numerous types of components such as I/O devices, memory, storage devices and expansion cards.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
A separate product family shall be defined for a server that does not have all its processor sockets populated, such as a 2-socket server with only 1 processor installed, compared with a server that has all its processor sockets populated, i.e. a 2-socket server with 2 processors installed. Within a given product family the same number of processor sockets and populated sockets has to be maintained.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.
As per the provision laid down in Annex II.1.2.3 to the regulation, manufacturers must make available the latest available version of the firmware (free of charge or at a fair, transparent and non-discriminatory cost) and the latest available security update to the firmwares (free of charge) within specifically defined periods. Annex I.34 to the regulation defines what is meant as firmware. An elaboration of the technical features of firmware and firmware updates should be part of the standardisation deliverables in the framework of the ‘Standardisation request to the European standardisation organisations in support of Commission Regulation (EU) 2019/424 of 15 March 2019 laying down Ecodesign requirements for servers and data storage products pursuant to Directive 2009/125/EC of the European Parliament and of the Council and amending Commission Regulation (EU) 617/2013’.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.