As part of the Green Deal, the EU is striving for environmental sustainability and efficient processes. Not only to reduce harmful impacts on the environment, but also to maintain and promote the EU’s competitiveness.
Especially now that artificial intelligence (AI) is on the rise and playing a role in this field signifies and promises economic strength, data centers—which are essential for AI and among the world’s largest energy consumers—are coming into the EU Commission’s focus. To drive competition in energy efficiency, the EU is revising the Energy Efficiency Directive (Directive 2023/1791), which was already supplemented in 2024 by Delegated Regulation (EU) 2024/1364, in its new draft Commission Delegated Regulation Ares(2026)3247482.
According to the current draft, a Union assessment system with an electronic label is now to be introduced, similar to the Digital Product Passport (Regulation (EU) 2024/1781); see the newsletters here (current status) and here (specifically regarding toys) for more on this. The so-called “Label for data centers” is to be made mandatory for larger data centers (expected to be over 500 kW) and introduced on a voluntary basis for all new data centers or those consuming fewer kW. .
What does this mean for data center operators?
Even though the key metric determining the labeling requirement is IT power consumption, the label is not intended to display only its efficiency. Rather, it focuses specifically on the following information:
- "Power Usage Effectiveness" ("PUE")
- Proportion of renewable energy used
- “Water Usage Effectiveness” (“WUE”)
- Opportunities for “Waste Heat Reuse”
- Information on integration into the power grid
- "cooling degree days"
All values must be determined, i.e., measured, calculated, or estimated—in accordance with current standards. Furthermore, they must be submitted to the relevant national authority, or, if none exists, directly to the European database. In addition, as part of their existing reporting obligations under the Energy Efficiency Directive, operators must also submit the name, owner, and operator of the data center; its location; the type, year, and month of commissioning; the redundancy levels of the electrical and cooling infrastructure; and other performance indicators. The European database then generates the labels and makes them publicly available. Specific data remains confidential. Making the label available to third parties is likely to become mandatory for every data center operator in the future.
The PUE and WUE values are of particular importance. These are expected to be presented in the form of a classification (similar to well-known energy efficiency labels), i.e., on an A-to-G scale. A green A represents the best possible value, while a red G is the worst possible classification. A document containing additional, particularly explanatory and context-relevant information must be provided to complement the label.
When will the requirement take effect?
Following the revision of the Energy Efficiency Directive in 2024 (EU - 2024/1364), data such as the name, owner, or operator of the data center, etc. (see above) had to be submitted by September 15, 2024, and since then by May 15 of each year (“Data Center Reporting”). In addition, further information relevant to the label will be required annually going forward. Starting August 15, 2027, the label is to be regenerated each year by the European database. It will then be valid only until August 15 of the following year.
What is the purpose of the label for the EU?
With the data center label, the European Commission aims to collect information on the current energy efficiency status of data centers. Starting March 31, 2029, this information will be analyzed every three years with regard to sustainability and thus also economic efficiency, and improvements will be addressed. The label is intended to increase pressure on data center operators by creating transparency regarding their energy efficiency. This is expected to result in data centers using more energy-efficient processes and reusing waste heat from cooling processes.
How can the label benefit operators?
The label also offers concrete business opportunities for data center operators and owners. In the future, manufacturers will have to increasingly promote the energy efficiency of their systems, which will further intensify competition. As a result, more efficient technologies will become a key differentiator.
Operators will also benefit from this: more energy-efficient data centers reduce ongoing operating costs and simultaneously become more attractive to customers—not least because of their better environmental footprint.
To take full advantage of these benefits, it is crucial to familiarize yourself with the compliance requirements of the planned Delegated Regulation at an early stage. At the same time, the topic of energy efficiency is likely to become an even greater focus in future contract negotiations with manufacturers.
Co-author: Julius Haas