Rating scheme for data centres in Europe

Apto is pleased to contribute to the European Commissions Call for Feedback on amending Commission Delegated Regulation (EU) 2024/1364 as regards the establishment of a common Union rating scheme for data centres. Aptos mission: We deliver world-class, hyperscale data centres to lead the next wave of the digital economy, in high growth and emerging markets across Europe.

RECS appreciates the opportunity to provide feedback on the draft delegated regulation supplementing Directive (EU) 2023/1791 and amending Delegated Regulation (EU) 2024/1364 as regards the establishment of a common Union rating scheme for data centres. Key recommendations: -Data centres should be required to demonstrate 100% renewable electricity procurement, matched by calendar year (or month).

Nkom welcomes the draft regulation establishing a common EU rating scheme for data centres and supports its overall objective of transparent, comparable and science-based sustainability documentation. Our comments focus on one provision: the proposed requirement that guarantees of origin must originate from assets commissioned within the last ten years to count as renewable energy.

As a co-lead for the OCP Heat Reuse Policies workstream, I deal with numerous data centre sustainability-related policies globally. I therefore welcome the effort of simplification and harmonisation across EU policies. A harmonised and clearly labeled rating scheme would absolutely help. That being said, the question is what the rating will be used _for_.

EDF welcomes the opportunity to share its view on the common rating scheme for data centres and wishes to stress the following points: the need to prioritize a location based approach to measure the carbon intensity of electricity supply; the importance of more granular, transparent and harmonized carbon accounting at EU level; the necessity to preserve technological neutrality, allowing for the use of nuclear…

Facility-level indicators (i.e. PUE) alone do not adequately assess the energy performance of data centres because they do not capture the efficiency of ICT equipment, which drives most energy use. For data storage (accounting for most of the energy use in data centres after servers), a harmonised, outcome-based metric such as terabytes-per-watt would enable more accurate comparison of storage energy performance and…

BRE (Building Research Establishment) is a UK-based organisation working globally to develop science-led solutions to built environment challenges. BREEAM delivered by BRE - is the Europe-leading sustainability assessment method for the built environment. BRE welcomes the intent to introduce a ratings scheme for the data centres market in Europe.

The Confederation of Danish Industry (DI) welcomes the European Commissions proposal to introduce a harmonised EU energy efficiency rating scheme for data centres, building upon the established reporting framework under the Energy Efficiency Directive (EED).

STX welcomes the introduction of a datacentre rating scheme under the Energy Efficiency Directive as a tool to enhance transparency, guide procurement and investment decisions, and support the decarbonisation of the datacentre sector. STXs comments focus on the use of Guarantees of Origin (GOs) under Annex III, which are essential for tracking renewable electricity attributes across the EU internal market.

Beyond power and water usage effectiveness: Building a more complete EU data centre labelling framework We welcome the initiative to standardise data centre policies for greater transparency. The framework should build on existing indicators (e.g., PUE, WUE, ERF, REF) yet be extended to better reflect energy system value and environmental footprint - fostering an efficient data centre ecosystem aligned with the…

Schneider Electric welcomes the draft Delegated Regulation establishing a common Union rating scheme for data centres. We support the Commissions objective of improving transparency, comparability and sustainability across the sector through an automatically generated EU label based on reported data.

The Association for Emissions Control and Climate (AECC) welcomes the opportunity to comment on the draft rating scheme for data centres in Europe. AECC notices that energy consumption and environmental resources such as water are covered, but not pollutant emissions. AECC raises concern that the importance of this topic is overlooked.

Telefónica Group fully supports the European Unions objective of strengthening the environmental sustainability and energy efficiency of the data centre sector. We share the ambition of advancing a harmonised framework based on transparent and measurable indicators, and we consider this consultation a valuable opportunity to contribute informed and constructive input based on our experience within the data centre…

The EUHA European Hydropower Alliance welcomes the opportunity to comment on the Energy Efficiency Rating Scheme for Data Centres in Europe, particularly the draft delegated act establishing a common Union rating scheme.

COGEN Europe welcomes the opportunity to provide feedback on the European Commissions proposal for a Delegated Regulation supplementing Directive (EU) 2023/1791 of the European Parliament and of the Council and amending Commission Delegated Regulation (EU) 2024/1364 as regards the establishment of a common Union rating scheme for data centres (hereinafter Union rating scheme for data centres).

VERBUND welcomes the opportunity to comment on the Energy efficiency rating scheme for data centres in Europe and specifically, the draft delegated act establishing a common Union rating scheme for data centres.

AMETIC welcomes the European Commissions initiative to establish a common Unionwide rating scheme for the sustainability of data centres and strongly supports its objectives of improving transparency, comparability and the availability of reliable data in a sector that is critical to Europes digital and economic transformation.

Octopus Energy welcomes the introduction of the Energy Efficiency Rating Scheme for data centres in Europe. This initiative has the potential to significantly enhance transparency and accountability regarding the sustainability performance of the data centre sector.

Connect Europe and the GSMA welcome the opportunity to comment on the European Commission draft Delegated Act developing a common EU scheme for rating the sustainability of data centres, based on Article 33(3) of the Energy Efficiency Directive 2023/1791, and simplifying the reporting scheme that was introduced by Delegated Regulation (EU) 2024/1364.

Connect Europe and the GSMA welcome the opportunity to comment on the European Commission draft Delegated Act developing a common EU scheme for rating the sustainability of data centres, based on Article 33(3) of the Energy Efficiency Directive 2023/1791, and simplifying the reporting scheme that was introduced by Delegated Regulation (EU) 2024/1364.

The European Data Centre Association welcomes the European Commission's draft Delegated Regulation as a significant step toward establishing transparent, comparable sustainability metrics across the industry. However, the proposal requires refinement to deliver on its core promise: enabling fair comparison across Europe's diverse operating environments.

DIGITALEUROPE welcomes the European Commission's draft delegated act establishing a common Union rating scheme for data centres. The rating scheme represents an important step towards transparency and performance improvement across Europe's digital infrastructure sector. The automatic label generation approach demonstrates the Commission's commitment to creating a workable, climate-aware framework.

The sustainability of the ICT sector is central to achieving the EUs climate objectives and to safeguarding the long-term competitiveness of the industry, which cannot overlook ambitious climate, energy and environmental commitments.

At EnBW, we are actively transforming infrastructure to support data centre development and related services. Decommissioned power plant sites within our portfolio are particularly well suited for this purpose, as they already provide ample space, reliable water access for cooling, and, crucially, strong grid connections at scale.

The Enel Group, a leading energy company with extensive experience in electricity networks, considers this consultation highly important in view of the rapidly growing impact of data centres and AI on the European power system. In this context, Enel highly appreciates the opportunity to provide feedback to this consultation; and recommends to: 1.

Following the review of the Annexes to the proposed Delegated Act and of the draft Commission Delegated Regulation amending Regulation (EU) 2024/1364, TIM welcomes the European Commissions initiative to establish a common Union rating and labelling scheme for data center under Directive (EU) 2023/1791.

Public Power Corporation (PPC), the leading electricity utility in Southeast Europe, welcomes the opportunity to contribute to the European Commission's initiative to establish a common Union rating scheme for data centres under Article 33(3) of the recast Energy Efficiency Directive.

EDP supports the European Commission objective to improve the sustainability reporting transparency and credibility for data centers through the proposed delegated regulation on energy efficiency, which includes the development of a common EU rating scheme and the simplification of reporting requirements.

Executive Summary Data centres form the backbone of the digital transformation and are a critical enabler of Europes competitiveness, innovation capacity, and digital sovereignty. They underpin the storage, pro-cessing, and provision of data in an increasingly interconnected and data-driven world.

Energy Traders Europe welcomes the opportunity to provide feedback on the delegated act on energy efficiency in data centres. We support the objective of improving transparency and contributing to the decarbonisation of electricity consumption.

The Italian Internet Providers Association (AIIP) - while supporting the objective of greater transparency and improved energy performance - expresses its concerns about the Energy efficiency rating scheme for data centres in Europe initiative, which should promote the energy efficiency and sustainability of data centres as a response to the growing energy demand of the ICT market.

We support efforts to improve transparency, accountability and environmental integrity in data centre electricity sourcing. In particular, we support the move towards more granular temporal matching of electricity consumption with carbon free generation, as an important step towards enabling data centres to operate on carbon free electricity at all times.

To: The European Commission Brussels, 23 April 2026 Subject: Feedback from Samorka, Icelandic Energy and Utilities, Call for Evidence for Energy efficiency Common Union rating scheme for data centres Transparency Register: REG 054812397925-32 Summary: Samorka, the association of energy companies and utilities in Iceland, welcomes the opportunity to contribute feedback on a draft amending the Commission Delegated…

The Dutch Data Center Association (DDA) welcomes the opportunity to respond to the European Commissions consultation on the proposed common Union rating scheme for data centres. DDA fully supports the comprehensive response submitted by EUDCA and aligns with its overarching position. This response wants to emphasis the lessons learnt from a Dutch perspective.

Uniper welcomes the opportunity to provide a response to the public consultation on the European Commissions proposal for a delegated regulation as regards a common EU scheme for rating the sustainability of data centres in Europe. Our detailed response is provided in the attachment.

Please note that Flow Batteries Europe's full reply is attached. The text below summarises our main points. Flow Batteries Europe supports the objective of the common Union rating scheme for data centres. However, the draft should better reflect not only internal facility efficiency, but also whether a data centre is equipped to contribute to a cleaner, more flexible and more resilient electricity system.

Cloud & Heat welcomes the European Commission’s initiative to gradually use the data obtained from the reporting obligation to develop energy efficiency measures. The energy efficiency label provides a good basis for customers to make informed choices in the future.

Filed in German · English published by the European Commission

nLighten welcomes the Commission's draft Delegated Regulation and the establishment of a common Union rating scheme for data centres. The scheme is a necessary next step after Regulation (EU) 2024/1364 and will increase transparency, enable fair comparison between operators, and inform better public and private procurement decisions.

onsemi, a leading global provider of intelligent power and sensing technologies, welcomes the European Commission's Delegated Regulation establishing a common EU rating scheme for data centres. As Europe scales its AI infrastructure ambitions, onsemi believes that transparency on energy use is the precondition for managing growth responsibly.

DataGreen is a French company specialising in the design, deployment and deployment of local data centers with high energy performance, based on a modular, distributed and resource-efficient architecture. DataGreen supports the European Commission’s objective of establishing a harmonised framework for transparency and rating the sustainability of data centres.

Filed in French · English published by the European Commission

On 26 March, the European Commission launched the consultation on the draft legal act establishing a common EU system for rating the sustainability of data centers in Europe. The German Datacenter Association (GDA) is contributing to this consultation with the present position paper. GDA is the voice of the data centers sector in Germany.

The Information Technology Industry Council (ITI), representing the full technology value chain - from cloud providers and data center operators to equipment manufacturers and technology developers appreciates the opportunity to provide comments and feedback to the European Commissions initiative to develop a common EU framework for rating the sustainability of data centers under Article 33(3) of the Energy…

The draft delegated regulation proposes to amend article 5, paragraph 5 of Commission Delegated Regulation (EU) 2024/1364 of 14 March 2024. However, the proposed amendment does not address the general presumption of confidentiality made in the article which by default classifies the underlying information related to key performance indicators for individual data centers as commercially sensitive information in the…

Energy Efficiency for Europe (formerly EFIEES) is the voice of private energy service companies (ESCOs) and their national associations across Europe. Our members represent over 100.000 professionals committed to the design and implementation of energy efficiency measures in public and private buildings, industrial facilities, as well as to the efficient operation of district heating & cooling networks.

HSCALE Norway Feedback on the Draft Delegated Act on Data Centre Energy Efficiency (GoO provisions) HSCALE Norway welcomes the European Commissions initiative to improve transparency and drive decarbonisation in the data centre sector. As a pan-European operator, we support policies that accelerate the transition to a low-carbon energy system.

EPEE, representing the Refrigeration, Air-Conditioning and Heat Pump (RACHP) industry in Europe, welcomes the opportunity to contribute to the consultation on an EU scheme for rating the sustainability of data centres in Europe based on Article 33(3) of the Energy Efficiency Directive.

Subject: Feedback on draft Delegated Act EU data centre rating scheme Danish Data Center Industry (DDI) supports the overall design of the proposed EU data center rating scheme. In particular, we welcome the streamlined indicator set, the use of existing reporting data, and the automatic generation of labels by the European database.

Iberdrola welcomes the ECs initiative to establish an EUwide rating scheme for DCs. Iberdrola is involved in the development of DC infrastructure through electricity supply, grid access & integrated energy solutions, including a JV with Echelon Data Centres in Spain.

OVHcloud supports the development of a European rating scheme for data centers, which represents a key opportunity to ensure consistent, transparent and comparable communication on their environmental footprint. Given the rapid growth of digital infrastructure, it is essential that the public, regulators, and market actors can rely on accurate, harmonized and independently audited data.

Statkraft is Europe's largest producer of renewable energy and a leading provider of renewable PPAs to industry. In this consultation response, we are commenting exclusively on the proposed criteria for data centre owners and operators to report their consumption of renewable energy.

Å Energi is the largest vertically integrated utility company in Norway, with annually 13 TWh production of renewable energy. We are a large player in the PPA and GoO market, and we are a supplier of PPA and GoOs to the data center industry. We refer to the EU Commissions (EC) initiative for consultation of the Draft delegated regulation - Ares(2026)3247482.

The European Bitcoin Energy Association (EBEA) thanks the European Commission for opening this consultation. We contribute to propose a concrete implementation path for reflecting grid-services performance in the future label, anchored in existing Member State TSO/BSP frameworks. Data-centre-class loads differ in their flexibility profile by an order of magnitude.

Data centres are the foundation of Europes digital infrastructure. They are essential to the provision of fast and reliable digital services for critical infrastructure, businesses, and private users. Sustainable digitalisation must therefore be aligned with the performance and competitiveness of Europe as a data centre location.

The Oeko-Institut welcomes the introduction of an efficiency label for data centres, modelled on existing energy efficiency labels. The aim of such a label should be to provide transparency re-garding the sustainability of services offered on the market and to enable procurers to make more environmentally friendly choices.

The Institut National de Bitcoin (INBI) thanks the European Commission for opening this consultation. We help to draw attention to a point that determines the informative value of the future label: taking into account the flexibility of data centres vis-à-vis the electricity grid.

Filed in French · English published by the European Commission

Equinix welcomes the European Commissions work to develop a common EU framework for rating the sustainability of data centers. A single, comparable label can help improve transparency and support continuous efficiency improvements across Europes digital infrastructure.

RE24 welcomes the opportunity to share its views on the proposal for a common EU rating scheme for data centre sustainability. As a UK-headquartered energy technology company structuring 24/7 hourly-matched renewable energy supply for enterprise data centre clients across the UK and EU, we see the rating scheme as a meaningful step toward transparent and comparable procurement practices in the sector.

The draft Rating Scheme is a positive step towards a harmonised EU framework for assessing data centre sustainability. Aruba supports the simplification of reporting, the use of already available data, the focus on PUE, WUE and REF, and the removal of indicators linked to data traffic or IT metrics.

The Finnish Data Center Association (FDCA) welcomes the proposal and considers it well-designed and proportionate. Our support rests primarily on the Commission's most important design choice: applying a single, uniform efficiency scale across all Member States without climate-zone adjustments. This ensures the label measures actual energy and water performance, which is the right approach.

CEA, a research and technology organisation (RTO), operates several data centres in France, including the CCGT in Bruyères-le-Châtel, and is actively engaged in the development of advanced, competitive and simultaneously more sober and sustainable digital solutions in the long term.

Filed in French · English published by the European Commission

Johnson Matthey welcomes the Commission's leadership in developing a common rating scheme for energy efficiency and sustainability in data centres. It is crucial to ensure digital growth is aligned with sustainability and climate aims so this is an important initiative.

Eurovent supports the EU data centre rating scheme, welcomes its simplification and technology-neutral approach, and calls for a revised WUE scale to better reflect regional conditions and energywater trade-offs. Please refer to the complete position in the attachment.

Please find attached the feedback by The Green Grid (TGG) on the proposed rating scheme for data centers. TGG works globally to create tools, provide technical expertise, and advocate for the optimization of energy and resource efficiency of Data Center ecosystems which enable a low carbon economy.

Finnish Energy considers the Rating scheme for data centres in the EU, for the most part, comprehensive and well-designed. Finnish Energy recommends changes to the Annex III requirements regarding PPAs. The current proposal is unfeasible and risks investments and fragmentation of the current market.

ENGIE welcomes the European Commissions proposal for an EU-wide energy efficiency rating scheme for data centres as an important step toward aligning digital growth with energy transition goals. By incentivising improved energy performance, renewable energy sourcing, reduced water consumption, and waste heat recovery, the scheme has the potential to guide the sector toward more sustainable practices.

SYNERGI welcomes the European Commissions initiative to establish an EU-wide rating scheme for data centres and supports its overall objective of improving transparency on energy performance and sustainability. Data centres are a cornerstone of Europes digital economy and future AI leadership, but their growing energy demand requires focus on efficiency and system integration.

Google appreciates the opportunity to share its views on the proposal for a common EU rating scheme for data centre sustainability. We remain committed to fostering highly efficient operations across Europe, striving to build the most sustainable, energy-efficient computing infrastructure supported by responsible water use practices.

Crusoe is the industrys first vertically integrated AI infrastructure provider. This means that we build infrastructure at every layer of the stack. Starting with the software layer, we provide a reliable, cost-effective AI cloud platform that is commercially available today: Crusoe Cloud.

The Polish Data Center Association (PLDCA) welcomes the European Commissions initiatives to enhance transparency and provide stakeholders with clear insights into the environmental performance of data centers. We believe that maintaining consistent indicators is essential for transparency and fair competition across the Union. The PLDCA proposes the recommendations in the attached document.

Microsoft welcomes the European Commissions efforts to increase transparency and to inform stakeholders about the environmental performance of a datacenter through a sustainability rating scheme that rewards best-in-class datacenter operations.

The Swiss Federal Office of Energy welcomes the introduction of an EU-wide energy efficiency rating and labelling scheme for data centres, as it enhances transparency in a sector whose energy consumption is rapidly increasing and at the same time still offers significant efficiency potential.

Trane Technologies strongly supports the creation of an EU Data Centre Rating Scheme as a foundational tool for the digital energy transition. We encourage the Commission to pair high ambition with climate specific realism, ensuring that thresholds and expectations reflect the diverse operating conditions across EU climate zones.

The proposed draft tries to creates transparency and comparability, but does not take into any consideration the enormous difference between high power density data centres (typically IA) and traditional data centres (typically non IA), between private and public and neutral data centres, between very very large and smaller data centres.

The Federation of Icelandic Industries and Data Centers Iceland support efforts to improve sustainability, transparency and energy efficiency in the European data centre sector. The current KPI framework is a solid basis for assessing performance. Metrics such as PUE, WUE, ERF and REF reflect how facilities actually operate and allow for direct comparison.

With the demand for data centres predicted to surge in the coming years, this delegated act, in combination with the upcoming regulation on minimum performance standards, can establish a legal framework to ensure the sustainable development of digital infrastructure.

CEDECs assessment of the proposal is largely positive. Metrics like power and water usage effectiveness (PUE, WUE) and renewable energy factor (REF) are well reflected The REF factor is particularly important as it underpins transparency and demand for renewable energy through Power Purchase Agreements (PPAs) and Guarantees of Origin.

The Computer & Communications Industry Association (CCIA Europe) welcomes the opportunity to provide feedback on the European Commissions draft delegated regulation establishing a common Union rating scheme for the sustainability of data centres.

A2A Group welcomes the proposal of the European Commission to establish a European rating scheme for datacenters. In the broader context of the Unions energy efficiency and digital sovereignty objectives, the initiative represents an important and timely step towards a more conducive regulatory framework to support the expansion of Europes computing capacity while safeguarding the achievement of its climate targets.

The Association of Municipal Enterprises (VKU) welcomes the Commission’s approach to introduce a rating system for data centres (DCs) in Europe. Sustainability plays an important role in the development of refrigeration centres in Europe. At the same time, regulation should follow the Commission’s current agenda of cutting red tape. Otherwise, there is a risk that the extension will be slowed down.

Filed in German · English published by the European Commission

Dear Sir or Madam, On behalf of Euroheat & Power, the European district heating and cooling association, I have the pleasure to submit the following feedback to the consultation on the rating scheme for data centres in Europe. District heating and cooling networks are the only energy infrastructure able to recover waste heat sources to supply buildings and industry.

Oesterreichs Energie, the Association of Austrian Electricity Companies, would like to express deep concern about the definition of total renewable energy consumption from guarantees of origin in Annex III to the Delegated Act. The current Guarantees of Origin (GoO) system is fundamentally based on the monthly or balancing-based allocation of electricity volumes. A shift to 15-minute granularity, i.e.

Conclusion The proposal will undermine investor confidence, reduce incentives for cost efficient investments in renewable energy, reduce the competitiveness of renewable energy, punish early movers, fragment the internal market, reduce liquidity, impact physical markets, incentivise consumers to locate in zones with a low proportion of renewable energy, punish countries that have loyally followed up delimitation of…

Fortum has submitted a response to the European Commission's public consultation on the draft Delegated Regulation establishing a Common Union Rating Scheme for Data Centres (Ares(2026)3247482). Our position covers key issues including the granularity of Guarantees of Origin, the 10-year asset age requirement, the role of firm low-carbon baseload such as nuclear, and the proportionality of the waste heat reuse ready…

Vattenfall is a leading European energy company with 12 million customers and 21,000 employees. Were convinced theres a way to build a future where everyone can choose fossil free ways to move, make and live. In the context of the datacentre labelling framework under the Energy Efficiency Directive, we believe the focus should be on clear, comparable and practical disclosure, rather than on imposing strict technical…

Cisco welcomes the European Commissions initiative to establish a common Union rating scheme for data center sustainability. As data centers become the backbone of Europes digital economy and AI ambitions, Cisco advocates for a strategic shift from a sole focus on capacity expansion to the intelligent modernization of existing infrastructure.

We support the initiative to standardize DC energy efficiency metrics. However, we recommend shifting the focus from PUE to Energy Reuse Factor (ERF). PUE is an imperfect metric for comparing DCs, as it does not account for redundancy and availability costs, such as that of UPS systems.

Per Article 6 (d) of the supplementing Directive, The Standard Performance Evaluation Corporation (SPEC) notes the goal to introduce indicators to measure the performance of the ICT equipment energy use and introduce (partial) certification or auditing of the reported data, by 31 March 2029.

We are writing in relation to the draft amendments to Delegated Regulation (EU) 2024/1364 published for consultation on 26 March 2026, and in particular on the newly proposed conditions for offsetting electricity consumption of data centres through guarantees of origin (ERES_GOO").

The ODCA explicitly welcomes the introduction of a harmonised EUwide rating and labelling scheme for data centres as an important step towards greater transparency, comparability and investment certainty within the European digital and energy system. The rating focuses on Power Usage Effectiveness (PUE) and Water Usage Effectiveness (WUE) as key indicators.

Submitted by: Rishab Vardhan Harikrishnan Co-Lead, OCP Sustainability Project | Lead, Water Efficiency Metrics & Grading Workstream (OCP) Member, SDEA Board of Experts The regulation is a welcome step, and the move to freshwater-specific reporting is a genuine improvement.

Data Center Excellence GmbH expressly welcomes the introduction of the common EU label for data centres and the chosen form of implementation. The decision to designate PUE and WUE as classified values together with contextual raw values such as Cooling Degree Days (CDD) is correct and brings the necessary transparency to the market.

Filed in German · English published by the European Commission

The province of Zuid-Holland appreciates the initiative taken by the Commission to create a common EU scheme for rating the sustainability of data centres. Seeing that their energy demand and natural resources demand is extraordinarily high, it is vital to have a framework that guides development towards more sustainable datacentres. Even more so because energy-efficiency is gaining urgency every day.

Summary GIMELEC contribution on the draft delegated regulation establishing a common EU rating scheme for data centres In its contribution to the public consultation on the draft delegated regulation implementing Directive (EU) 2023/1791, GIMELEC supports the European Commissions objectives of increasing transparency and improving the sustainability of the data centre sector.

AIB applauds that the proposed change in the Annex II point p, keeps the integration of guarantees of origin (GOs) in the backing of the renewable energy claim, as the prime example to be followed by all policies that enhance renewable energy consumption.

It is considered important to link the PUE value and the data center performance (equivalent). As power density increases, servers’ power consumption changes. In some cases, this reduces the power consumption of the servers, while the technical infrastructure remains firm. This would worsen the PUE while performance is increasing. This makes it difficult to assess. This should be clarified.

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We propose 3 concrete amendment to ensure data centre sustainability is centered around the future needs of europe's power system - renewables and clean flexibility. Proposed Amendment 1 Remove Granular GO Conditionality Proposed Amendment 2 Align ERES-PPA Criteria with ERES-GOO Granularity Criteria Proposed Amendment 3 Replace the Grid Functions Flag with a Flexibility Metric

Response to the Proposed EU Data Centre Sustainability Rating Scheme The proposed Regulation establishing a common Union rating scheme for data centres represents an important and timely step towards improving transparency, comparability, and sustainability in a rapidly growing and energy-intensive sector.