Resources, Conservation & Recycling 154 (2020) 104426 Contents lists available at ScienceDirect Resources, Conservation & Recycling journal homepage: www.elsevier.com/locate/resconrec Full length article Advances towards circular economy policies in the EU: The new Ecodesign T regulation of enterprise servers Laura Talens Peiróa, Davide Polverinib, Fulvio Ardentec, , Fabrice Mathieuxc ⁎ a Beatriu de Pinós at Sostenipra, Institut de Ciencia i Tecnologia Ambientals (ICTA-UAB), Universitat Autònoma de Barcelona, 08193 Cerdanyola del Vallès, Barcelona, Spain b European Commission, DG Internal Market, Industry, Entrepreneurship and SMEs, Brussels, Belgium c European Commission, Joint Research Centre (JRC), Directorate Sustainable Resources, Ispra, Italy ARTICLE INFO ABSTRACT Keywords: The concept of a circular economy has been widely accepted by governments and industries. In Europe, the Circular Economy (CE) European Commission adopted the Circular Economy package in 2015. The Ecodesign Directive has been Ecodesign identified as one of the most suitable legislative tools for achieving some of the objectives in the package because Enterprise servers it has the potential to translate the circular economy principles into specific product material efficiency re- Policymaking quirements. This paper applies the Ecodesign policy process to “enterprise servers” to illustrate how circular Critical raw materials (CRMs) Material efficiency economy strategies can be implemented by European product policies. Indeed, the paper introduces a potential novel approach to “operationalize” circular economy principles in product policies. The evolution of the material efficiency requirements for a more circular economy is described up to their final formulation, which is the one in the published Ecodesign regulation. This legal act includes requirements on design for disassembly, firmware availability, data deletion, and presence of critical raw materials. The process for enterprise servers has been successful as the early discussions between stakeholders, policymakers and experts, supported by appropriate metrics along an iterative debate, comes to the publications of material efficiency requirements in a regulation. This study represents a 'first-of-a-kind' experience, and sets precedents for the development of similar require- ments for other product groups. 1. Introduction definitions that reveals heterogeneity in the understanding of it (Kirchherr et al., 2017). Discussions on the Circular Economy (CE) concept itself date back to At EU level, a broad consensus on energy efficiency policies in the 1970s and 1980s so they are not new. Stahel and Reday-Mulvey, 1976 last decade has helped the attainment of ambitious energy efficiency described a vision of an economy in terms of loops and its impact on job targets in Europe (European Commission, 2010a). Now, especially after creation and competitiveness (Stahel and Reday-Mulvey, 1981). In the the publication of the EU Circular Economy Action Plan (EU CEAP) late 1980s, other authors initiated a discussion on the importance of adopted by the European Commission (EC) in December 2015, the ef- closing material loops in industrial processes (Ayres, 1989; Frosch and ficient management of materials is becoming an area of key focus Gallopoulos, 1989). Indeed, the Ellen MacArthur Foundation, one of the (European Commission, 2015a). The EU CEAP consists of legislative organisations that contributed the most to spreading the concept of CE, proposals on waste and an action plan covering the whole life cycle of considers that CE is deep-rooted in several so-called schools of thought: products and materials. The focus of the EU CEAP is broader than cradle to cradle, the performance economy, biomimicry, industrial simple waste management as it aims to increase material efficiency and ecology, natural capitalism, the blue economy, and regenerative design close loops by improving reuse and recycling. The use of product life (The Ellen MacArthur Foundation, 2019). Several definitions of CE cycle strategies in product policies is also gaining momentum outside have been suggested by a great many organisations in recent years the EU (Ometto and Filho, 2006). (Kirchherr et al., 2017). CE is most frequently depicted as a combina- Although aspects of CE (such as reparability, durability, upgrad- tion of reduction/reuse/recycling activities, potentially linked to the ability, recyclability, or the content of certain materials or substances, sustainable development concepts but expressed with a large variety of including reuse and recycled content) have been discussed in the ⁎ Corresponding author. E-mail address: fulvio.ardente@ec.europa.eu (F. Ardente). https://doi.org/10.1016/j.resconrec.2019.104426 Received 14 November 2018; Received in revised form 3 May 2019; Accepted 23 July 2019 Available online 28 September 2019 0921-3449/ © 2019 The Author(s). Published by Elsevier B.V. This is an open access article under the CC BY license (http://creativecommons.org/licenses/BY/4.0/). L. Talens Peiró, et al. Resources, Conservation & Recycling 154 (2020) 104426 literature, their implementation in mandatory regulations has been Section 6 summarizes the main findings and identifies further research very limited (Dalhammar et al., 2014; Bundgaard et al., 2017). Indeed, that could strengthen the EU CEAP. the publication of the EU CEAP represents an initial commitment to systematically examining CE aspects in future mandatory legislation, 2. Challenges in developing circular economy measures in especially as part of the EU Ecodesign Directive (European Parliament product policies and the Council of the European Union, 2009). Action 1 of the EU CEAP states that the EC will “emphasise CE aspects in future product re- Three high-level policy goals concerning CE measures for products quirements under the Ecodesign directive” (European Commission, have been identified which are: reduction of the environmental impact, 2015a). Before that, only a few examples of material efficiency re- extension of the lifetime, and reduction of waste (Tecchio et al., 2017). quirements were implemented in European Ecodesign Regulations, These goals are to be achieved by implementing material efficiency mainly concerning the communication of general information to end-of- requirements together with other environmental requirements in po- life operators. Examples include the declaration of the content of licies (e.g. climate change mitigation). Synergies among environmental mercury in televisions (Dalhammar et al., 2014; Bundgaard et al., policies can trigger greater change in the production systems and re- 2017). Indeed, the publication of the EU CEAP represents an initial present a “tipping point for industries: soon it will be too expensive to commitment to systematically examining CE aspects in future manda- continue with business as usual” (Levänen and Eloneva, 2017). tory legislation, especially as part of the EU Ecodesign Directive There are several articles and studies explaining how including (European Parliament and the Council of the European Union, 2009). material efficiency requirements in product policies improves recovery Action 1 of the EU CEAP states that the EC will “emphasise CE aspects and recycling of materials contained in end of life products, and so in future product requirements under the Ecodesign directive” contributes to a more Circular Economy (Dalhammar et al., 2014; (European Commission, 2015aa). Before that, only a few examples of Bundgaard et al., 2017). For example, Ardente et al. (2015) discussed material efficiency requirements were implemented in European Eco- how the enforcement of features such as ‘design for dismantling’ design Regulations, mainly concerning the communication of general through mandatory product policies such as the Ecodesign Directive information to end-of-life operators. Examples include the declaration could facilitate the end-of-life treatment of commercial refrigeration of the content of mercury in televisions (European Commission, 2009b) appliances and hence ease compliance with the waste legislation and lamps, water consumption in washing machines (European (Ardente et al., 2015). Commission, 2010b), and the provision of generic information for The challenges to enabling a transition to CE in policy development disposal of electrical motors and circulators (European Commission, can either be technical and practical in nature. One of the greatest 2009c). Only a few of the most advanced Ecodesign regulations include technical challenges is to include concepts as reparability, durability, material efficiency requirements. One of them is the durability re- upgradability and recyclability in the product policy debate. Although quirements of some critical parts in vacuum cleaners, namely the hose these are sometimes ‘familiar’ to the general public, how much stake- and the motor (Commission, 2013). In lamps, durability aspects are holders understand can differ. Although conceptually different, these measured by the lumen maintenance factor as well as a number of other concepts are generally very similar and are even used interchangeably, factors such as the number of switching cycles before failure, premature for example, ‘design for disassembly’ and ‘design for dismantling’ failure rate, and for some lighting products, colour rendering (European (Vanegas et al., 2018). While ‘design for disassembly’ refers to the ap- Commission, 2009a; Maitre and Dalhammar, 2016). In both cases, the plication of design principles to allow a non-destructive separation of availability of test methods and technical standards to ensure the en- the parts in a product, the ‘design for dismantling’ implies the use of a forceability of the regulation has been crucial (European Committee for broader set of strategies, including the destructive separation of parts in Standardization (CEN), 2013; Bobba et al., 2016). a product that disables their re-construction. ‘Design for dismantling’ Besides these regulations, following the recommendations of the strategies therefore include reversible and irreversible operations that “Roadmap to a Resource Efficient Europe” Communication (European separate certain valuable components for their recovery and recycling. Commission, 2011), the EC Joint Research Centre has published several The second technical challenge is the development of assessment studies discussing potential material efficiency measures for several methods, using scientifically robust metrics, to measure the perfor- example products that could be implemented in European product mance of the product. One or more indicators related to CE aspects such policies, including Ecodesign requirements for electronic displays as durability (Stamminger et al., 2018) or disassembly (Vanegas et al., (Ecodesign and EU Ecolabel) (Ardente and Mathieux, 2014a,b; Ardente 2018) can be defined. Furthermore, these metrics are fundamental to et al., 2015; Bobba et al., 2016; Talens Peiró et al., 2017; Ardente et al., stipulating the correct material efficiency requirements in the legisla- 2018). tion. Finally, assessment methods and metrics need to be un- Establishing compulsory minimum requirement on material effi- ambiguously verifiable by market surveillance authorities before the ciency has been a challenge for several reasons, including: the lack of product is launched on the market. For instance, once a requirement for discussion of material efficiency concepts during the policy debate, the ‘design for disassembly’ has been formulated, it is necessary to define absence of appropriate metrics (commonly accepted material efficiency the procedures to prove that a certain product fulfils the disassembly assessment methods, e.g., in standards), and the related problems of requirement. verifying requirements, the variability between product groups, and The development of accurate metrics to measure certain aspects diverging interests of stakeholders along the value chain. This paper (e.g. durability) can be very different product by product, requiring the illustrates a method that was developed to cope with these challenges development of a dedicated testing method and potential standards. For during the formulation of material efficiency requirements for en- instance, the durability of lamps is measured by the lumen maintenance terprise servers. First, the paper discusses these challenges in detail factor whereas the durability of vacuum cleaners is assessed according (Section 2). Then, it analyses the current European Ecodesign policy to the fatigue life testing of the motor and hose. Products can also differ process and how it could adapted to ‘operationalize’ CE principles for greatly in their end-of-life treatment. For wasted lamps, particular at- the development of EU product policies (Section 3). Section 4 describes tention needs to be paid to regulated hazardous substances such as the practical case-study experience on building CE requirements for the mercury, which requires a dedicated treatment line. Vacuum cleaners ‘enterprise servers’ product group, including the analysis of problems do not generally contain mercury or other regulated substances and encountered and solutions adopted. Then, following a bottom-up ap- therefore, they can be treated in shredders together with other small proach, the paper analyses the lessons learnt and how these could be household appliances. Detailed knowledge of the pre-treatment and generalized into a novel lesson strengthening the development of CE recycling processes of each product is crucial in defining a benchmark measures under the EU Ecodesign regulation (Section 5). Finally, of current practices and to propose measures and targets for material 2 L. Talens Peiró, et al. Resources, Conservation & Recycling 154 (2020) 104426 Fig. 1. A conceptual representation of ‘policymaking’ using the ‘Travelling-by-ship’ metaphor. efficiency, as demonstrated for the electronic displays product group efficiency and its indicators; 3) the involvement of stakeholders in CE (Ardente and Mathieux, 2014a). during the preparatory study needs to be strengthened. Hinchliffe and Bundgaard et al. (2017) highlighted the need to expand the stan- Akkerman (2017) also argued that more time and effort should be de- dardization work to define test methods and verification procedures voted to material efficiency aspects so that its importance can be concerning material efficiency requirements for the products to en- weighed up against energy efficiency and other parameters. The hance an increasingly Circular Economy (Bundgaard et al., 2017). shortest ‘inner cycles’ described in the CE, namely maintenance, repair, Tecchio et al. (2017) provided a first example of a framework to and remanufacture have the greatest potential to generate the highest identify key material efficiency considerations relevant to product po- environmental and economic benefits as they help the products keep licies in support of sustainable engineering, and map out the generic their value longer. A greater involvement of the original equipment and product specific standardisation requirements (such as appropriate manufacturer (OEMs) is crucial in defining requirements aimed at im- metrics, tests, calculation procedures, reference tables, and structured proving these stages. When defining regulatory measures on these templates for results) (Tecchio et al., 2017). Regarding the development stages, it has also been observed that the interests of stakeholders in CE of CE standards for policies, the standardization work currently being strategies for products are often not aligned and so they diverge in some undertaken by the European standardization bodies under mandate M/ cases (Dalhammar, 2016). For example, some manufacturers claim that 543 (European Commission, 2015b) has been a big step forward they are exclusively charged with the costs and the burdens related to worldwide. First horizontal standards (i.e. non-sector-specific, non- an improved ‘design for recycling’ of the products, whereas these product-specific) concerning the provision of information on material strategies mainly benefit waste treatment and recycling companies. efficiency aspects and on the use of critical raw materials (CRMs) were Similarly, reuse and repair operators have interest in extending the recently delivered, whereas additional standards are expected in 2019 lifetime of products as much as possible while some OEMs may be more (CEN-CENELEC, 2019). These standards will lay down basic principles oriented towards maximize the volumes of sales of new products rather for consideration when addressing aspects such as: the extension of the than making them more durable. Some authors have highlighted the lifetime of products; the ability to separate components for reuse or for importance of involving waste treatment and recycling companies recycling; and the use of re-used components and/or recycled materials among the stakeholders in the early stages of the Ecodesign policy in products. Moreover, these standards will provide a complete set of process and the formal consultation process of the Ecodesign Directive definitions of key terms related to different CE strategies, and con- (Ardente et al., 2015). Experience shows that even though these com- tribute to overcoming some of the challenges highlighted above. panies might not have a special focus on improving the ‘inner cycles’ The challenges of the so-called practical nature mainly refer to the strategies like repair and maintenance, they tend to be highly colla- development of the policymaking process itself and to external factors borative. This collaboration in many cases facilitates the development influencing stakeholders, and more directly the representatives of EU of trial tests on samples of the product group under study, e.g., for the member states who have the final say on approving or amending reg- purpose of performing analyses of ‘design for disassembly’ which can ulations. This paper explains the development of the EU Ecodesign particularly benefit the CE ‘inner cycles’ as well as the ‘outer cycles’. policy process, and how the EC can guide the process to guarantee a fair Fig. 1 represents some of the practical challenges of the policy- and objective discussion of material efficiency aspects from the begin- making process via the metaphor of ‘travelling by ship’. Policymakers1 ning of the process. Some authors have examined the integration of pursue various policy targets, one of them being current CE policies. To material efficiency into the Ecodesign Directive in detail by ex-post achieve the target, different policy instruments are available based on analysis of several Ecodesign processes (Bundgaard et al., 2017; several inputs of information, like ships floating in a 'sea' of knowledge Gabarrell Durany et al., 2017). The recommendations improving the and moving towards the target islands. The effectiveness of the parti- focus on material efficiency requirements in the Ecodesign Directive cipatory modelling and stakeholder involvement has already been are: 1) material efficiency aspects need to be analysed in the early phase (i.e. in the preparatory studies) so that they have a chance of being considered during the political discussion; 2) the analysis of Energy- 1 Here the term “policymaker” refers to people responsible for formulating related Products (ErP) should include a specific focus on material policies (whatever the regulated field). 3 L. Talens Peiró, et al. Resources, Conservation & Recycling 154 (2020) 104426 proved in various contexts; especially those related to resource man- 2012, 2014). This research has already inspired several revisions of the agement and to environmental impact assessment (Hedelin et al., MEErP, which have been carried out by (Mudgal et al., 2013) with the 2017). In many cases, conflicting interests between diverse groups of introduction of CE aspect indicators into the MEErP, such as recycl- stakeholders arise and, together with the areas of ‘lack of knowledge’, ability benefit rates, recycled content, and lifetime. However, this re- stand as barriers to the development of the policy and the achievements vision of the methodology has not been enough to push the develop- of the targets. In practical applications, different stakeholders con- ment of more material efficiency requirements forward, mainly because tribute to policy instruments by having different interests (i.e. eco- of the challenges already discussed in Section 2 and more especially due nomics, business models, interest and power) as if they are 'rowers' to the timely involvement of relevant stakeholders. pushing in different directions (towards different target signer) with In 2015, the DG JRC and the DG GROW2 started collaborating in different intensities. Generally, these barriers can be bypassed by ad- research for the purpose of investigating further integration of material ditional scientific knowledge, evidences, data, and methods. efficiency aspects into EU Ecodesign regulations. This collaboration The policymakers are responsible for driving the policy instruments developed by building on the respective knowledge bases and experi- as if they are metaphorical 'steersmen' in this 'sea' of knowledge and ences of both organisations: the research on resource efficiency as- interests, identifying the potential barriers to be overcome and con- sessment carried out by DG JRC and the experience matured by DG veying all of the various stakeholder ‘forces’ towards the target(s). GROW in implementing the Ecodesign Directive for several product More in general, Dalhammar et al. (2014) found that the potential groups. In particular, this collaborative research focused on the policy for setting rules for CE aspects in Ecodesign regulations is very de- process to develop EU Ecodesign requirements for the ‘enterprise pendent on the product group. Therefore, they argue that it is worth server’ product group. starting to work more coherently with material efficiency requirements This paper presents a critical analysis of this case-study experience under the Ecodesign Directive, and that it is wise to ‘advance slowly’ to (from 2015 to 2018) starting from the development of a more general avoid setbacks (Dalhammar et al., 2014). This paper follows the advice concept of CE aspects and continuing up to the approval of concrete from Dalhammar et al. (2014) and analyses how CE strategies can be material efficiency policy measures. Challenges encountered during the formulated as material efficiency requirements. The results of the case various policy steps are analysed including solutions adopted and study on enterprise servers help understand the advances towards a methods implemented. Lessons learnt from this case study are then used more CE policy in EU product policies. to suggest novel strategies to ‘operationalize’ CE principles into the Ecodesign product policy. With its concrete applicative nature from 3. Methodology conceptualization up to the adoption in legislation, this research re- presents a ‘first-of-a-kind’ experience in the EU and worldwide that led The EU CEAP identified the European Ecodesign Directive as a key to the identification of ambitious and measurable mandatory require- instrument in enhancing CE strategies in production and consumption ments now formulated in draft EU regulation. systems in the EU (European Commission, 2015a). This Directive re- quires product manufacturers to improve the environmental perfor- 4. Case study: the development of material efficiency mance of their products, typically by meeting minimum energy effi- requirements for enterprise servers ciency requirements as well as other environmental requirements such as water consumption or emission levels. It also aims to remove the This section illustrates an analysis of CE aspects in a real-world worst-performing products from the EU market and help individuals Ecodesign implementation policy process: the development of the and companies to reduce their utility bills (European Commission, Ecodesign requirements for enterprise servers. Enterprise servers are 2016a). By acting at the level of the EU single market, it also avoids computers used for business-to-business applications, e.g. typically in costs for business and consumers due to otherwise fragmented national data centres or a company’s server room. These products were in- environmental requirements. Finally, the implementation process of the vestigated in the context of the Ecodesign directive for reasons of their Ecodesign Directive benefits from well-structured and broad support market penetration and their environmental impact. First, increasing from stakeholders (Tanasescu, 2009), including industry, EU member market projections (related to trends in the Information and states, consumer organisations, and non-governmental organizations Communications Technology (ICT) sector such as the Internet of (NGOs) because the transparent and regular consultation process in Things3, the Industry 4.04, and Cloud Computing5) suggest that the establishing implementing measures is much appreciated. environmental impact of these products will increase in the short to In order to identify relevant Ecodesign measures for products, the medium term. Secondly, as demonstrated in the supporting study (van EU developed the so-called ‘Methodology for Ecodesign of Energy-re- Elburg et al., 2011) for the Ecodesign Working Plan 2012-14 (European lated Products’ (MEErP) (Kemna, 2011). This is a well-established Commission, 2012), these products could also potentially involve a method built on various technical and political steps (Fig. 2) that have significant environmental saving from the material efficiency point of been consolidated along its application for the assessment of many view. Based on the above, the determinants of the environmental im- product groups (European Commission, 2018a). Please see Box 1 for a pact of enterprise servers, with specific regard to the CE aspects, have detailed description of the Ecodesign policy process. been analysed and discussed in previous papers (Talens Peiró and As discussed in Section 2, until now EU Ecodesign requirements Ardente, 2015). Details about the material composition of enterprise have mainly targeted energy efficiency. CE strategies such as repar- servers are provided in the Supplementary Materials. ability, durability, upgradability, recyclability, or the identification of certain materials or substances will be systematically examined in the 2 future (European Commission, 2015b). The development of material Directorate General for Internal Market, Industry, Entrepreneurship, and efficiency requirements for product policies should be prioritized in line Small and Medium Enterprises. 3 with the more prominent role of CE in the EU policy agenda. The im- The Internet of Things (IoT) represents the next step towards the digitali- sation of our society and economy, where objects and people are interconnected provement of product design making the use of raw materials more through communication networks and report about their status and/or the efficient has been recognized as an EU policy interest in the past surrounding environment. (European Commission, 2011). Since then, the Directorate General 4 The current trend of automation and data exchange in manufacturing (DG) of the Joint Research Centre (JRC), the EC’s science and knowl- technologies. edge service, has been developing life-cycle environmental indicators 5 The practice of using a network of remote servers/storage devices hosted on related to material efficiency using a method called “Resource Effi- the Internet (rather than a local server or a personal computer) to store, ciency Assessment of Products” (REAPro) (Ardente and Mathieux, manage, and process data. 4 L. Talens Peiró, et al. Resources, Conservation & Recycling 154 (2020) 104426 Fig. 2. The proposed approach to 'operationalize' circular economy into product policy (Ecodesign) effectively. Box 1 The EU Ecodesign Directive policy process. The EU Ecodesign implementation process starts by analysing a number of product groups that are deemed relevant for the development of potential Ecodesign regulations, and the publication of a list of the most relevant products in the so-called ‘Ecodesign working plan’ (Step 0). In general, product groups are prioritized according to the potential environmental savings, to be attained if the Ecodesign regulations are enforced. The EU Ecodesign implementation process starts once a list of prioritized product groups is published. The development of an EU Ecodesign regulation for a product group can be conceptualized into five steps (see coloured blocks in Fig. 2). The preparatory work (Step 1) prior to any Ecodesign policy measure is a complex exercise, which entails technical, procedural, and legal steps in accordance with a well-defined procedure. The analyses carried out in the preparatory studies are based on the application of the ‘Meth- odology for Ecodesign of Energy-related Products’ (MEErP) (Kemna, 2011), which consists of a techno-economic-environmental assessment structured on a series of tasks. This is the step where most of the technical challenges discussed in Section 2 arise and are subsequently addressed. The next step of the Ecodesign process is the policy impact assessment (Step 2). Various policy options are analysed in this step against cost competitiveness, impact on small and medium enterprises, technological development and innovation, product functionality, and end-user affordability (European Commission, 2015c). The aim of the impact assessment of the potential policy is to provide an estimation of the potential benefits (in terms of resource savings, cost savings, industry competitiveness, etc.) of the improvement in the environmental per- formance of the product. As part of this assessment, a Consultation Forum meeting is convened in order to present proposals concerning the Ecodesign requirements to the stakeholders. Once the impact assessment has been successfully finalised, a draft of the potential Ecodesign regulation (step 3) is formally discussed in the EC (this process is known as ‘interservice consultation’). After that, notification of the draft Ecodesign regulation is sent to the World Trade Organisation (WTO). The draft Ecodesign regulation is then voted on by the EU member states in a Regulatory Committee (step 4). Following the three-month scrutiny period by the European Parliament and by the Council, Ecodesign regulations are finally published in the Official Journal of the European Union (Step 5). The publication of an Ecodesign regulation for a certain product group may be followed by mandates to the European Standardisation Organizations (ESO) to develop standard methods for the assessment of the regulated parameters. It is worth noting that not all of the steps in the EU Ecodesign implementation process are open to stakeholders. Indeed, stakeholders typically provide inputs in the product’s preparatory study (step 1) and the policy impact assessment (step 2). Of the various stakeholders, it is important to distinguish the EU Member States Experts who are part of the regulatory committee and so have the final say on approval of the regulations (step 4). As an effect of their inclusion in the Ecodesign Working Plan 2012- group under analysis, the proposed requirements were identified as a 14 (European Commission, 2012), enterprise servers were selected as a response to these hotspots. Products compliant with these requirements product to be subject to the Ecodesign implementation process. Mate- will improve their material efficiency performances, overcoming the rial efficiency measures were addressed from the earliest stages of the previously identified hotspots. After this first phase, in October 2015 a preparatory study (step 1), which started in June 2013, in order to cope dedicated policy study, named as ‘impact assessment’, was started with with the technical challenges to improve the presence of CE in product the aim of in depth identification and development of the best reg- policies. Indeed, it was decided to pair the Ecodesign preparatory ulatory solution for enterprise servers. Different policy options were study6 (Berwald et al., 2015) with a specific material efficiency analysis investigated across different impact dimensions (economic, social, and conducted by the DG JRC (Talens Peiró and Ardente, 2015). The set of environmental) (), and further data on the material efficiency aspects proposed CE requirements for enterprise servers is the main result of was gathered and analysed. The potential material efficiency require- the technical analysis carried out by the authors of the latter study. ments for CE were discussed with the stakeholders at the Consultation Starting from an analysis of the environmental hotspots for the product Forum meeting in the first quarter of 2017, and the feedback from this consultation helped to improve the formulation of the requirements, as discussed in the remainder of this section. All things considered, in the 6 context of the initiative on the Ecodesign of servers, a wide range of The preparatory study also tackled the assessment of data storage devices consultations took place for the purpose of ensuring that the interests of but these were not discussed in this paper. 5 L. Talens Peiró, et al. Resources, Conservation & Recycling 154 (2020) 104426 all relevant sectors as well as citizens, non-governmental, and stan- policy analysis carried out under the ‘impact assessment’ confirmed that dardization organizations were duly taken into account. The feedback the proposed material efficiency requirements were justified in en- from stakeholders significantly contributed to the data gathering and vironmental-economic terms. Indeed, the CE principles could be “op- analysis process. erationalized” in terms of Ecodesign requirements for enterprise servers In June 2018, the draft regulation of the Ecodesign of enterprise thanks to both: servers was made publicly available (European Commission, 2018b), allowing stakeholders a further month for specific and detailed com- - the robust technical analysis supporting the policy (mainly in step 1, ments on the draft legislative text. The Regulatory Committee vote in but also continuously throughout the whole process), in which the step 4 (see the Ecodesign implementation process of Fig. 2) took place CE aspects were systematically identified, analysed, and discussed in mid-September 2018 and, finally, the Ecodesign Regulation on en- with solid methodological grounds; terprise servers was published in the Official Journal of the European - the timely and continuous involvement of relevant stakeholders, Union in March 2019 (European Commission, 2019). The regulatory together with policy makers and material efficiency experts. process has reached its full conclusion, which represents a great achievement especially considering the novel aspects involved in in- More in detail, the evolution of the formulation of the requirement troducing the material efficiency requirements. on design for disassembly (from step 1–2) resulted in the proposal of a Of all of the possible aspects related to material efficiency, the clear and enforceable requirement. Indeed, the requirement as drafted discussions were narrowed to three main aspects: a) material compo- at the Consultation Forum stage (i.e. step 2 in Table 1) would have sition of enterprise servers; b) recycling of servers at end of life; and c) banned welding or firm gluing as joining techniques for certain com- the potential for reuse and remanufacture of servers. The discussion on ponents such as batteries, HDDs, or processors. Although these tech- these topics resulted in the proposal of four potential requirements niques were recognized as critical in fostering the repair of enterprise concerning: servers as well as being effective in improving recycling, OEM in par- ticular (Digital Europe, 2017) claimed that the ban on these joining 1) the design for disassembly of key-components (covering aspects b techniques could hamper future innovation and competitiveness in the and c); IT industry. Following discussions at the stakeholder consultation 2) the declaration of content of CRMs7 (covering aspects a and b); forum, the requirement was reverted into (from step 2 to step 3) a more 3) the provision of the latest available version of firmware (covering technologically neutral formulation. aspect c); The changes in the material efficiency requirement 2 on the pre- 4) the availability of built-in functionality for secure data deletion (also sence of CRM show how the requirement was streamlined on the one covering aspect c). hand for the purpose of providing useful information to recyclers and on the other hand not overburdening OEM. So requirement 2 was de- A fifth additional requirement on the reusability of parts in servers fined using the feedback from OEM, recyclers, and market surveillance initially proposed by Talens Peiró and Ardente (2015) was dropped8 authorities. The final version of requirement 2 considers a limited during the steps of the process that followed. number of materials (i.e. Neodymium and Cobalt) and components Table 1 shows the formulations of these five material efficiency (batteries and HDDs), also prescribing a weight range (i.e. less than 5 g, requirements for the CE of enterprise servers at steps 1, 2, and 3 of the between 5 g and 25 g, above 25 g) instead of the specific weight which Ecodesign implementation process. was judged by industry to be very burdensome, and difficult for the Table 1 shows how well the changes in the formulations of the market surveillance authorities to enforce. material efficiency requirements for enterprise servers in the Ecodesign The main change in the formulation of requirement 4 on secure data implementation process, in particular in the first three steps, improved deletion of the information contained on a HDD is the opportunity for these requirements. It should be noted that steps 4 and 5 are the most manufacturers not only to provide data deletion functionality via pre- ‘political’ ones where the amount of technical modifications to the installed software on the machine but also using other technical solu- legislative act is typically not significant. Indeed, the formulation at tions such as pre-installation in the firmware (typically in the Basic step 1, i.e., that resulting from the scientific work (Talens Peiró and Input/Output System) or also in software included in a self-contained Ardente, 2015), was correct from the technical point of view. However, bootable environment (such as an USB drive). The final version of this some amelioration in terms of legal drafting was required as well as for requirement was developed in response to the comments of the in- the enforceability of the requirements, i.e., the verifiability of com- dustrial stakeholders (Digital Europe, 2017). While keeping the ratio- pliance by market surveillance authorities. The feedback from stake- nale and the aims of this specific requirement unchanged, the resulting holders, in particular industry, was also instrumental for the identifi- requirement ensures manufacturers can take a more flexible approach. cation of less burdensome formulations of the requirements. Finally, the Repairers vocally supported requirement 4 on the availability of the latest firmware while OEM (Digital Europe, 2017) claimed that fi- nancial compensation is necessary. Finally, consensus was built around 7 Securing reliable and unhindered access to certain raw materials is a the compromise that OEMs have to provide the latest available version growing concern within the EU and across the globe. To address this challenge, of the firmware at a ‘fair, transparent, and non-discriminatory cost’. the European Commission has created and continuously updated a list of ma- While the expression ‘fair, transparent, and non-discriminatory’ cost is terials that are recognized as ‘Critical Raw Materials (CRMs)’ for the EU, i.e., already present in EU law (European Commission, 2016b), it is possible raw materials that are of great importance to the EU economy and have a high that some market surveillance authorities will judge this formulation to risk associated with their supply (European Commission, 2017). be difficult to verify and enforce. If needed, guidance documentation 8 This requirement was rejected because while conceptually and methodolo- could be produced in order to help with this specific aspect. The re- gically correct, it would not have been practically enforceable for the two main quirement on firmware availability is expected to be the most effective reasons. First, at the time when the technical analysis was carried out by Talens in fostering the repair of enterprise servers (Polverini et al., 2018). Peiró and Ardente (2015), no method for the evaluation of the total energy Overall, researchers and policy makers have made a constant effort consumption (TEC) of a server was available. Moreover, the correct enforcing of requirements on reused components would involve the need for traceable and throughout the whole process to ensure actual enforceability of the reliable information, e.g., at the level of the bill of material for the product and/ proposed requirements on material efficiency. The situation referred to or in the supply chain in order to identify and trace the reused components. This in the case of the requirement on 'fair, transparent, and non-dis- kind of information is still not available for enterprise servers marketed in the criminatory cost', i.e., the potential need for guidance documentation, is EU (as well as for most other products). a rather peculiar case. In the context of this ‘first-of-a-kind’ experience 6 L. Talens Peiró, et al. Resources, Conservation & Recycling 154 (2020) 104426 Table 1 Comparison of the formulations of the material efficiency requirements for circular economy at steps 1, 2 and 3 of the Ecodesign implementation process. Formulation of material efficiency requirements at different steps of the Ecodesign policy process of enterprise servers In the JRC study (step 1) Discussed at the Consultation Forum (step 2) In the draft Regulation (step 3) Requirement 1: Design for Manufacturers shall ensure that servers are From 1 January 2019, manufacturers shall From 1 March 2020, manufacturers shall disassembly designed so that external enclosures can be ensure that welding or firm gluing is not used ensure that joining, fastening, or sealing removed by hand or with commonly available as joining or sealing technique for the techniques do not prevent the disassembly of tools. The following four types of components following types of components, when present: the following components, when present: (when present) shall be identified, accessible, (a) HDD and SSD (a) data storage devices; and removable by hand or with commonly (b) Memory (b) memory; available tools: (c) Processor (CPUs) (c) processor (CPU); • printed circuit board assemblies, including memory cards (larger than 10 cm2); (d) Motherboard (e) Chassis (d) motherboard; (e) expansion card/graphic card; • batteries; (f) Expansion cards/graphic cards (f) power supply. Instructions on the • hard disk drives; (g) Power supply disassembly operations referred to (…) of this • the processor. The abovementioned components shall be: Accessing components shall be ensured by documenting the sequence of dismantling Appendix, including the following information for each necessary operation and component: • accessible: this shall be ensured by documenting the sequence of disassembly operations needed to access the target components, including the following (a) the type of operation; (b) the type and number of fastening technique operations needed to access the targeted information about each of these operations: (s) to be unlocked; components, including the following type of operation, type and number of (c) the tool(s) required. information for each operation: type of fastening technique(s) to be unlocked, and tool operation, type and number of fastening (s) required. technique(s) to be unlocked, and tool(s) required; • extractable: servers shall be designed so that no fastening by welding or gluing is encountered for all of the disassembly operations leading to the extraction of the above-listed components (some exemptions should be foreseen for thermal paste and adhesives used to bind heat sinks to printed circuit boards). Requirement 2: Statement Information about the location and quantities of Total weight per product of the following Weight range (less than 5 g, between 5 g and of the content of CRM CRMs, especially rare earth elements contained critical raw materials if present, and indication 25 g, above 25 g) of the following critical raw in hard disks (HDDs), shall be provided by of the components in which the following materials at component level, if present: manufacturers for each product family critical raw materials are present: (a) Cobalt in the batteries; architecture. This information shall be submitted (a) Cobalt, expressed in grams rounded to the (b) Neodymium in the HDDs; to a centralised database organised by industry to nearest integer; consolidate the volume of CRMs in servers, (b) Neodymium, expressed in grams rounded which will provide reports or be accessible to to the nearest integer; recyclers or their representative organisations. (c) Palladium, expressed in grams to one decimal place Requirement 3: Provision The latest version of firmware to test the The latest version of firmware to upgrade and The latest available version of the firmware of the latest available functionality and compatibility of different test the functionality and compatibility of the shall be made available for a minimum period Firmware components in the server shall also be available various components in the server shall be of eight years after the placing on the market made available. of the product, at a fair, transparent and non- discriminatory cost. Requirement 4: Data deletion of potentially reusable data storage Data deletion from potentially reusable data Built-in functionality for secure data deletion Availability of secure equipment (i.e. hard disk drives, memory cards) storage equipment (i.e. hard drives and solid shall be made available for the deletion of data data deletion shall be ensured by using the methods described state drives) shall be made possible by contained in all the data storage devices of the in section 3.2.1.3 of this report. securing availability of built-in software based product. Information on the secure data data deletion tool(s). Information on the data deletion built-in functionality (…) including deletions tool(s) referred to in (…) instructions on how to use the functionality, the techniques used, and the supported secure data deletion standard(s), if any; Requirement 5: Reused The annual total energy consumption of servers, (discontinued) (discontinued) parts in enterprise reusing at least the HDD, memory card, CPU, and servers motherboard, shall not exceed the value “δj ∙ E_TEC” (in kWh/year). δj will have a value of between 7% and 20% depending on the number of components reused. on mandatory CE requirements, the proposed formulation of the re- in the early steps. Indeed, starting the discussion at the beginning of the quirement on firmware availability was judged to be the best trade-off Ecodesign implementation process allowed9 the development of the between, on the one hand, the expected effectiveness of this require- four original material efficiency requirements which are part of the ment and, on the other hand, an obligation on manufacturers that is not final version of the regulation voted by the EU Member states. A excessively burdensome. In conclusion, potential material efficiency requirements for CE were described thanks to the close and continual interaction with the 9 The preparatory study also formulated several potential measures con- stakeholders, and to the collaborative work in parallel, the Ecodesign cerning energy efficiency such as the efficiency requirements for the internal implementation process for the enterprise server product group. This power supply unit; requirements for product performance (both in idle and experience was the first of its kind to include scientific and technical active state); and requirements on product operating conditions (mainly: re- data input and a quantitative assessment of material efficiency aspects garding operation at higher temperatures). 7 L. Talens Peiró, et al. Resources, Conservation & Recycling 154 (2020) 104426 summary of the of the main steps for the implementation of CE stra- the most important role. On one hand, having required their input on tegies in the development of Ecodesign requirements for enterprise multiple occasions, and on the other hand, shared the data and analyses servers is presented in the Supplementary Materials (Table S2). in the stakeholder meetings for the preparatory study as soon as they became available, was certainly helpful. It was also crucial to involve 5. Discussion: a novel policy approach to progressing towards a new types of stakeholders (e.g. recyclers, reuse and refurbishing com- circular economy in EU product policy panies) during the course of the analysis whose participation has been generally lacking in other Ecodesign processes. This is in line with the The steps in the EU Ecodesign implementation process (see Fig. 2 findings of other authors about the relevance of identifying stake- and Table S2 in The Supplementary Materials) with the greatest tech- holders related to the whole supply chain of goods and services in- nical and practical challenges were identified. Most of the technical vestigated (Fritz et al., 2018). Furthermore, thanks to the involvement challenges arise in the preparatory study (step 1) and the policy impact of material efficiency experts, it was possible to identify and tackle the assessment (step 2). Indeed, Fig. 2 is completed with a series of icons “lack of knowledge” encountered during the policy process in a timely that represent the type of inputs proposed that would partially help to manner, for example, concerning the collection of technical evidence overcome the technical challenges discussed in Section 2. Each icon about the recycling and reuse of servers. Although the importance for represents a type of information provided during the policy im- involving recyclers and other material efficiency experts in Ecodesign plementation process. A ‘people icon with M’ represents the stakeholder policy process had already been highlighted by some authors, e.g. input in the field of material efficiency and CE. A ‘database icon’ il- (Ardente et al., 2015), the server product group was the first policy lustrates the scientific and technical data input. A ‘histogram icon’ re- process in which these kinds of stakeholder were involved from the very presents quantitative assessments that allow metrics to support MEErP early stages. This leads on to the next novelty of the proposed approach: on material efficiency aspects. Material efficiency indicators from JRC could also be used to support scientific and technical data as well as • Novelty 4: to involve material efficiency experts (including re- provide a quantitative assessment and support MEErP. For instance, cyclers, re-use operators, etc.) during the whole process, including Table S1 in the Supplementary Materials includes an example of the early stages. recyclability benefit indicator, which expresses the potential environ- mental savings that can be achieved from recycling the product over the The Ecodesign regulation on enterprise servers was finalized in environmental burdens of virgin production followed by disposal. To March 2019 (European Commission, 2019). However, there have al- support a more comprehensive and scientifically based debate about ready been clear reactions from diverse stakeholders. Some reuse op- material efficiency measures for the EU CE, the authors suggest that erators are in favour of the concrete CE policy requirements but OEMs detailed technical evidence is collected during the product preparatory are not fully supportive of potential material efficiency policy measures study (step 1) and the policy impact assessment (step 2). (Digital Europe, 2017). Such scepticism is also in line with previous Following a bottom-up approach, five novelties have been identified studies (Dalhammar et al., 2014; Bundgaard et al., 2017). The main to address the challenges identified in Section 2. criticism from OEMs is that enterprise servers are business-to-business products, and, given the significant investments required when pur- • Novelty 1: to ensure early (preferably during the product pre- chasing these products, most OEMs have already well developed take- paratory study, step 1) interaction between policymakers, material back and asset recovery schemes, e.g., within service provision con- efficiency experts, and other stakeholders specialised in the pro- tracts. Some examples of these take-back schemes are the ‘Global Asset duct group under analysis. Recovery Services’ (IBM, 2019), the ‘IT Asset Lifecycle Solutions’ (HP, • Novelty 2: to have a policy process fully equipped with relevant 2019), and the ‘Dell Asset Recovery Services’ (Dell, 2019). The lack of material efficiency data inputs and indicators. common definitions and technical descriptions of these existing server recovery services hindered comparison of the systems implemented by The additional information on material efficiency aspects gathered many OEMs. According to OEM associations, this proves that it is in thanks to stakeholder meetings and consultations is extremely valuable their own interest that the enterprise servers are designed for efficient to the scope of the analysis. Inputs collected from manufacturers, in- maintenance, allowing the products to be repaired, updated, and re- dependent IT service providers, end-of-life operators, and ESOs con- configured. However, not all OEMs have implemented such virtuous tribute to both the data gathering process and to increasing the ro- practices. bustness, effectiveness, and acceptability of requirements for the The present research confirmed that servers have high reuse and approval of the draft policy proposal. The approach proposed suggests recycling rates. However, in contrast to the arguments brought by that the intensity of quantitative assessments should be gradually in- OEMs, the analysis revealed that a significant share of servers (around creased throughout the process. The more available data on the product 15%–20%) do not actually return to OEMs, being collected and treated group and on the potential end-of-life scenarios is, the more consensus by other stakeholders (such as refurbishing companies, spare parts on the relevance of a given material efficiency requirement, and the providers, and WEEE recycling plants). Moreover, the analysis carried greater the chances of material efficiency requirements being included out with some end-of-life operators proved that not all the servers are in newer EU Ecodesign product policies. Including information pro- optimally designed for repair and re-use by third parties. Relevant in- posed in this new approach is in line with the conclusions from formation for recycling is not systematically provided by all of the Bundgaard et al. (2017). The consultation forum included in the policy OEMs for all product models. While reuse companies pointed out the impact assessment (step 2) represents a good step to fine-tune material unavailability of firmware as the major obstacle to reusing servers, efficiency requirements, and the related methods to verify the proposed OEMs were concerned about the provision of firmware as it is generally requirement. This leads to another novelty of the proposed approach: strictly proprietary. • Novelty 3: to maintain a continuous and iterative process based on • Novelty 5: to develop material efficiency requirement based on multiple stakeholder consultations. available (or under development) standardised methods. The detailed analysis of material efficiency aspects of enterprise Another barrier encountered during the process was the lack of servers represents a sound evidence base, which will be of fundamental standardised methods for the assessment of the material efficiency re- help in the legislative process. In terms of collecting the inputs from quirements. Requirements need to be measurable (ideally with stan- stakeholders, the industrial ones (i.e. the manufacturers) certainly had dards) in order to be enforceable by market surveillance authorities. 8 L. Talens Peiró, et al. Resources, Conservation & Recycling 154 (2020) 104426 The lack of standards is an area of “lack of knowledge” according to the technical evidence to support material efficiency assessment and representation in Fig. 1. For example, to date there is no standardised iterative discussions throughout the process; 4) the enlarged involve- method to describe the sequence of dismantling operations of electr(on) ment of relevant stakeholders generally not present during the ic equipment nor assessing their ease of disassembly. Research work on Ecodesign stakeholder meetings (such as reuse and repair centres, and this topic is currently on-going (Vanegas et al., 2018) and could be fed recyclers); 5) the push towards the development of relevant standards. into EU horizontal standards on material efficiency aspects currently The successful application of the approach was facilitated by close under development (European Commission, 2015b) or, if more granu- collaboration between EU policy officers and material efficiency experts larity of the analysis were available, under a dedicated standardisation with experience in policy formulation. In particular, to the authors' mandate on the Ecodesign of enterprise servers. Standards developed knowledge, the case study experience of enterprise servers represented under this latter mandate would be built on the basis of the general the first example in Europe and one of the first examples in the world in methods laid down in the horizontal standards on material efficiency which the reusability of the products and the composition of the pro- aspects. This need for standardisation is also in line with outcomes of duct in terms of CRMs have been assessed in detail and successfully other studies in the literature (Dalhammar et al., 2014; Bundgaard implemented in mandatory policy measures. The proposed material et al., 2017; Tecchio et al., 2017). In the case of enterprise servers, efficiency measures for enterprise servers are also original as for the requirement 1 on design for disassembly was formulated to be verifi- first time they combine the minimum requirements for the hardware able despite the current absence of standards on the assessment of ease and physical aspects (e.g. requirement 1 on design for disassembly), the to disassemble. On the other hand, the presence of ‘first-of-a-kind’ documentation requirements (e.g. requirement 2 on presence of CRMs), material efficiency requirements for CE could stimulate the standardi- and the minimum requirements for software aspects (e.g. requirement 3 sation process. For example, the requirement on the content of certain and 4 on firmware and secure data deletion). CRMs in the servers is aimed at improving knowledge of product On the other hand, the main limitations of the approach were: composition and its trends over the time, and consequently to en- couraging more efficient recycling in the future. Following the example - conflicting interests and objectives of stakeholders, which can po- of this requirement, the recent standard EN 45558 has further defined tentially hinder the general consensus; and detailed how information on CRMs in the products could be - legal problems applying to specific issues (e.g. liability for the dis- practically collected and communicated by manufacturers (including tribution of certain information; proprietary knowledge); information from the supply chain). On the other hands, initial drafts of - a lack of a detailed picture of all the flows of waste servers within all the standard EN 45558 were used by policy makers to refine the for- the EU member states; mulation of the requirement on CRMs. - a lack of specific figures on the size of investments for recyclers; The comments discussed so far clearly show the essence of the - the full verifiability of certain requirements (for example, due to the consultation process: stakeholders engage in the discussion putting lack of standards to describe the sequence of dismantling opera- forward their viewpoint on technical and policy aspects, trying to in- tions). fluence the decision towards more favourable conditions for them. Considering the schematization of the policy process in Fig. 1, this case Further tailored policy innovations (e.g. additional metrics to assess study was indeed characterized by the participation of heterogeneous circularity strategies, such as remanufacturing (Ardente et al., 2018); stakeholders with very different objectives, and by the continuous standardised metrics to measure performances of products) and ex- “pull” by the policymakers towards, among other things, the “circular perience with several product groups will probably be necessary to economy” target (not forgetting more “traditional” targets such as en- overcome these limitations. ergy efficiency). In conclusion, albeit with some limitations, this experience and the The novel elements presented in this paper will have to undergo novel approach proposed is very capable of enhancing the im- further testing in the context of Ecodesign by applying them in other plementation of CE strategies in a product policy instrument like the product groups in order to refine and streamline them. Moreover, al- Ecodesign Directive. The legislative work on enterprise servers was fi- though the proposed approach has been formulated in the context of nalized in March 2019 (European Commission, 2019) once again con- the Ecodesign Directive, it could also be valuable for other product firming the robustness of the technical analysis behind the policy. The policy instruments such as the EU Ecolabel Regulation (European experience on the enterprise servers product group triggered the gen- Parliament and the Council of the European Union, 2010) and Green eral interest of many actors in the material efficiency requirements for Public Procurement (GPP) (European Commission, 2008) to foster the CE and their related impacts and will also contribute to a more sys- CE product performances. Material efficiency requirements in those tematic emphasis on CE aspects in future product requirements under cases are likely to be more restrictive as the objective is shifted towards the Ecodesign Directive. increased environmental sustainability. In the EU Ecolabel and GPP, the goal is to identify environmental excellence among the existing pro- Disclaimer ducts while Ecodesign aims to restrict the access of the worst per- forming products to the EU market. The views expressed in the article are personal and do not ne- cessarily reflect an official position of the European Commission. 6. Conclusions Neither European Union institutions and bodies nor any person acting on their behalf may be held responsible for the use that may be made of This article discusses a case study that demonstrates how CE stra- the information contained therein. tegies are enabled in European product policy. The lessons learnt during this case study help formulate a novel approach to “oper- Acknowledgments ationalise” CE principles into product policy. The results of this analysis are of general interest whenever an effective implementation of CE into The results of this research were partially supported by the product policy is needed, and applying the approach to a case study ‘Environmental Footprint and Material Efficiency Support for Product proved to be effective. Policy’ project funded by European Commission – Directorate General The main novel features of the proposed approach were: 1) con- for Environment (Administrative Arrangement 070307/2012/ENV.C1/ sideration of CE aspects and objectives in the early stages of the policy 635340). Dr Talens Peiró would like to thank the support of the Beatriu process; 2) use of dedicated (and innovative) metrics to measure ma- de Pinós postdoctoral programme of the Government of Catalonia's terial efficiency along the process; 3) continual collection of detailed Secretariat for Universities and Research of the Ministry of Economy 9 L. Talens Peiró, et al. Resources, Conservation & Recycling 154 (2020) 104426 and Knowledge. European Commission, 2012. Commission Staff Working Document: Establishment of the The authors would like to thank Re-Tek, Relight, ITIA-CNR, and Working Plan 2012-2014 Under the Ecodesign Directive, SWD(2012) 434 Final. European Commission, 2015a. Communication from the Commission to the European Free ICT Europe and other stakeholders for their expert views and Parliament, the Council, the European Economic and Social Committee and the contributions, especially for sharing primary data for the research. Committee of the Regions ‘Closing the Loop - An EU Action Plan for the Circular The authors are also grateful to BIO by Deloitte and Fraunhofer IZM Economy’. COM(2015) 614,. . European Commission, 2015b. Commission Implementing Decision of 17.12.2015 on a for leading the Preparatory Study on enterprises servers, for all dis- Standardisation Request to the European Standardisation Organisations as Regards cussions and helpful comments and interactions we had during the Ecodesign Requirements on Material Efficiency Aspects for Energy-Related Products research.’ in Support of the Implementation of Directive 2009/125/EC of the European Parliament and of the Council. C(2015) 9096 Final: 1-13. European Commission (EC), 2015c. 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