ASHRAE TC 9.9 technical input to the European Commission on the review of Regulation 2019/424 (Ecodesign of servers and data storage)

Overview

This document is a letter from the ASHRAE TC 9.9 technical committee, dated 8 July 2024 and addressed to the European Commission's DG GROW. It gives technical comment on draft design options during the review of EU Regulation 2019/424, which sets ecodesign requirements for servers and data storage products. The text is a public policy input, not a standard; it carries ASHRAE's area of expertise into a regulatory context.

The letter supports exposing server temperature and fan data. The committee also describes the rapid growth of liquid-cooled AI servers, citing the example that chips dissipating more than 300 W in 2021 led Lenovo, Dell and HPE to launch liquid-cooled products. This part aims to explain to regulators how high-power components strain air cooling. This explanation gives regulators a technical background and shows that decisions on temperature classes are tied directly to hardware capability.

The most important caution concerns operating classes. TC 9.9 states that requiring a minimum of class A2 (in effect banning A1) risks limiting computing performance, because high-power air-cooled servers may need cooler inlet air (class H1). The letter also recalls that the Thermal Guidelines were first published in 2004, with the most recent fifth edition issued in 2021. The committee's aim is thus that regulation should improve energy efficiency without preventing high-performance computing.

The document has limits. The letter is a free download, but copyright belongs to ASHRAE and ASHRAE prohibits entering its content into AI tools, so only a short summary is given here. The letter gives the H1 maximum recommended temperature as 22 C and the maximum allowable as 27 C, whereas the reference card lists the H1 allowable range as 15-25 C; these values should be verified against the book.

Key points

1. Letter from ASHRAE TC 9.9 to DG GROW, dated 8 July 2024.
2. Provides technical input to the review of EU Regulation 2019/424.
3. Supports exposing server temperature and fan data.
4. Thermal Guidelines were first published in 2004; the latest is the fifth edition, 2021.
5. Chips dissipating more than 300 W in 2021 prompted liquid-cooled products from Lenovo, Dell and HPE.
6. Requiring A2 as a minimum (banning A1) risks limiting computing performance.
7. High-power air-cooled servers may need cooler inlet air (class H1).
8. The letter states H1 maximum recommended 22 C and maximum allowable 27 C; the reference card lists H1 allowable 15-25 C, so verify against the book.

Using it in design

• Do not hard-code A2 as the minimum class; allow H1/A1 classes for AI racks.
• Add the ecodesign regulatory context to design notes for EU projects.
• Verify H1 temperature values against the ASHRAE Thermal Guidelines book before using them as a design criterion.
• Consider making server temperature and fan data observable in the monitoring system requirements.

Who should read it

Designers running projects in the EU, regulatory compliance specialists and cooling engineers who use ASHRAE thermal classes.

Related standards

• EU Regulation 2019/424
• ASHRAE Thermal Guidelines 5th ed.

Publication details

Authors

ASHRAE TC 9.9

Publisher

ASHRAE

Year

2024

Document number

Letter to DG GROW, 8 July 2024

Document language

English

Source type

Standard

Access

Free to read

Licence

Copyright retained; citation only — the publisher’s terms apply to the original document

Citation