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.