Feedback reference
F13536
Submitted by
Tom MORIARTY
User type
Company/business organisation
Organisation
Dell EMC
Organisation size
Large (250 or more)
Country of origin
Ireland

Dell EMC appreciates the opportunity to provide feedback on the Lot 9 proposed amendments to Commission regulation (EU) No 617/2013 for servers and online storage systems.

Dell EMC is a leading provider of servers and storage systems into the EU and has a long history of leadership and innovation in environmental aspects with energy efficiency being a key focus area. The company services customers of all sizes across 180 countries – ranging from 99 percent of the Fortune 500 to individual consumers – with the industry's most comprehensive and innovative portfolio from the edge to the core to the cloud.

Dell EMC has serious concerns about the latest draft of the Lot 9 proposed amendments to Commission Regulation (EU) No 617/2013 for servers and storage systems.
1. Aggressive idle power limits fail to properly identify and reward the most efficient servers in the market driving customers to lower performing servers that actually increase energy use.
2. Inadequate adders for components critical to end users ability to optimize servers for their intended use will force end users to sub optimal component choices that increase cost and energy use.
3. Data deletion requirements that do not clearly define “Data” to be deleted and fail to comprehend realities of the business models for sale and delivery of servers or the current state of the art security features in servers and storage products.

The attached document provides more detail on the specific issues identified with the proposed regulation

Download (132.93 KB - PDF - 3 pages)

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