PassPer / Resources / Servers & data storage DPP outlook
Honest outlook

Servers and storage: no DPP yet — but the direction is clear.

Straight answer first: there is no scheduled DPP delegated act for servers or data-storage products, and no confirmed date. But this is not a product group the EU has ignored — servers already carry ecodesign rules under Regulation (EU) 2019/424, ICT featured in ESPR preparatory work, and the ESPR framework is built to expand product group by product group. Here is what applies today, what is expected, and how to prepare without betting on a date nobody can honestly give you.

In one line: servers and data storage have no scheduled DPP delegated act today, but they already carry EU ecodesign rules (Regulation 2019/424) and ICT is a widely expected candidate for later ESPR working plans — so the smart move is data readiness, not waiting.

What applies to servers today

Servers and online data-storage products are already a regulated ecodesign category: Regulation (EU) 2019/424 sets requirements covering energy efficiency and material-efficiency aspects for these products. That is not a digital product passport — there is no passport obligation for servers today — but it matters for two reasons. First, it means the EU has already defined the product group and built regulatory muscle around it. Second, the kind of structured product information ecodesign compliance requires is exactly the kind of data a future DPP would draw on.

Where servers sit in the ESPR pipeline — honestly

The Ecodesign for Sustainable Products Regulation (EU) 2024/1781 rolls out DPP obligations per product group through delegated acts. The first working plan (April 2025) prioritised textiles, furniture including mattresses, tyres, and the intermediates iron & steel and aluminium — servers and data storage are not on it. Two things keep ICT in the conversation nonetheless: electronics featured in ESPR preparatory studies, and the working plan includes horizontal requirements — repairability, recyclability — that can cut across product groups including electronics. The honest framing: an expected candidate for later working plans, with no dated obligation yet. Treat any specific year you read elsewhere as speculation.

What a server DPP would likely involve

If and when a delegated act covers this group, the ESPR template gives a reasonable picture of the themes: material composition and critical raw materials, recycled content, repairability and spare-parts availability, firmware and security-support commitments, disassembly and end-of-life information — much of it echoing what ecodesign rules and customer ESG questionnaires already ask for. Note one passport that is already dated for the data centre: industrial batteries above 2 kWh — UPS and battery energy storage systems — need a battery passport from 18 February 2027 under the separate Batteries Regulation. See our energy storage guide.

Prepare via data readiness, not panic

The pattern across ESPR groups is consistent: once a delegated act enters into force, company obligations bite roughly 18 months later — a comfortable window for organised companies and a brutal one for everyone else. For server and storage vendors the preparation is concrete: consolidate bills of materials, supplier declarations, test reports and repairability documentation so a passport can be assembled when — or if — the obligation lands. PassPer's AI extraction builds structured product records from the documents you already have, and a free readiness check shows your current gap. That investment pays off in customer ESG responses today, whatever the regulatory timetable does.

Frequently asked questions

Is there a confirmed date for a server or data-storage DPP?
No. The first ESPR working plan (April 2025) prioritised textiles, furniture including mattresses, tyres, iron and steel, and aluminium — servers are not on it, and no delegated act for them is scheduled. Anyone quoting a firm server-DPP date is guessing.
Does Regulation 2019/424 already require something like a passport?
No. Regulation (EU) 2019/424 sets ecodesign requirements for servers and online data-storage products — including efficiency and material-efficiency provisions — but it is not a digital product passport. It does mean the EU already regulates this product group and already expects structured product information, which is why ICT is widely seen as a natural later candidate.
Do any passport rules hit data-centre operators sooner?
Yes, via batteries: industrial batteries above 2 kWh — the packs in UPS systems and battery energy storage — need a battery passport from 18 February 2027 under Regulation (EU) 2023/1542. If you place such systems on the EU market, that obligation is dated and real today.
What should server and storage vendors do now?
Treat it as data readiness rather than a compliance sprint: know your bill of materials, supplier declarations, repairability and firmware-support information, and where each document lives. If a delegated act arrives, obligations typically bite about 18 months later — companies with organised product data will absorb that easily; companies starting from scratch will not.

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