EU Public Policy | Valora | Pelican Engineering

Public Policy

Many jurisdictions have policies that address greenhouse-gas emissions and data-center energy and water use. The European Union offers a useful example of the wider direction: measure energy, water and useful heat.

One connected system

Look at the whole picture.

Valora brings together three ideas: use less power, put heat to work and reuse water. Changing cooling can change water use, and heat recovery can use power too. Looking at the whole system makes those trade-offs clear.

EU rules offer useful measurements and questions. Each project still follows the laws and permits that apply where it is built.

Current reporting framework

What the EU measures now.

Article 12 of the Energy Efficiency Directive requires annual reporting from data centers with at least 500 kW of installed IT power. Regulation 2024/1364 sets the measurement method and database.

PUE

Power Usage Effectiveness

E_DC / E_IT

All data-center energy divided by energy used for computing.

WUE

Water Usage Effectiveness

W_IN / E_IT

All water entering the data center divided by energy used for computing.

ERF

Energy Reuse Factor

E_REUSE / E_DC

Useful energy sent outside the data center divided by all data-center energy.

Count all water and heat.

The rules count all incoming water, and count drinking water separately. Reclaimed water can lower drinking-water use, but WUE only improves if total water used for each unit of computing falls.

Heat is counted where warm cooling fluid enters an exchanger and where useful heat leaves the site. Heat sent back to cool the data center is not counted. A planned heat-recovery system does not count as reuse until it delivers heat.

Waste heat

Above 1 MW, check whether the heat can be used.

This waste-heat rule uses total rated energy input. That is different from the 500 kW IT reporting threshold.

Current directive

Article 26

For data centers above 1 MW of total rated energy input, Member States must consider waste heat or another recovery use unless it does not make technical or economic sense.

Installation assessment

Cost-benefit analysis

New or major refurbished sites above the threshold need a site review. It looks at whether the heat is useful, what it would cost, local and seasonal demand, and available uses.

Local process

Member State procedure

Local rules, exemptions, permits and authorization steps decide what a project needs to do. The Directive does not mean every heat-recovery idea must be built.

Commission Recommendation (EU) 2024/2395 gives current guidance on feasibility and cost-benefit analysis. It does not replace the Directive or local law.

Valora policy map

Three ways to look at Valora.

EU policy offers useful measurements and questions. A real result needs a baseline, meters and a clear record of how the site is operating.

Reduce

Reduce Power Consumption.

Valora could look at cooling and support equipment changes that use less facility power while keeping computing reliable.

Count the whole system: pumps, fans, heat pumps, water treatment and controls.

Reuse

Reuse Waste Heat.

Valora could look at moving heat from computer cooling to a real user, including temperature, upgrades, storage, backup, losses and meters.

ERF needs measured heat that replaces another energy source.

Recycle

Recycle Impaired Water.

Valora could look at whether impaired or reclaimed water can reduce drinking-water demand and total make-up water.

Changing the water source alone does not improve WUE. Count water quality, treatment, discharge, permits and all incoming water.

Proof of performance

Keep track of the whole system.

Moving power, water or heat outside a drawing does not make it disappear from the project.

Measure

Measure facility and computing energy, total and drinking-water input, and heat sent to its user.

Track

Record computing load, weather, treatment chemicals, water left over, support power, seasonal demand, storage and backup.

Separate what is known

Keep measured results separate from models, business assumptions, rules that still need checking and open questions.

Wider EU setting

Different instruments have different status.

EU-level policy direction does not create a facility-specific performance, compliance or emissions result.

Current law and reporting

Climate, Taxonomy and corporate reporting.

The European Climate Law sets Union-wide targets. CSRD and ESRS govern company reporting in scope, while the Taxonomy applies its own activity, DNSH, safeguard, verification and disclosure tests. Neither is a facility PUE, WUE or ERF limit.

Current product rule

Ecodesign and onsite combustion.

Ecodesign Regulation 2019/424 governs covered servers and storage products, not whole-facility performance. The EU ETS can apply to qualifying onsite combustion installations; a data centre is not automatically an ETS installation merely because it purchases electricity.

Current energy instruments

Renewables, PPAs and Guarantees of Origin.

Renewable instruments have defined contractual and reporting roles. They do not automatically prove additionality, hourly matching, physical delivery from a named generator or zero project emissions.

Water-use boundary

Water reuse and industrial use.

The EU Water Reuse Regulation sets minimum requirements for reclaimed urban wastewater used in agricultural irrigation. It does not automatically set the quality or permit rules for data-centre cooling; Member State and local rules remain essential.

Status as checked 28 October 2026

Current rules, guidance and future measures are not interchangeable.

Future status needs refresh before publication.

Status	Measure	Controlled use on this page
Current directive	Energy Efficiency Directive Articles 12 and 26, implemented through Member States.	Reporting and waste-heat framework with thresholds and feasibility qualification.
Current delegated rule	Regulation (EU) 2024/1364.	Reporting method, European database and PUE/WUE/ERF/REF boundaries.
Current recommendation	Recommendation (EU) 2024/2395.	Official feasibility and cost-benefit guidance; not an independent facility obligation.
Under scrutiny	Commission-adopted common data-centre rating scheme.	Not current law or a minimum performance standard.
Future measure	Minimum-performance standards consultation; proposal planned for 2027.	Policy direction only; no final threshold or legal duty from the consultation.
Voluntary	EU Code of Conduct.	Voluntary expected-practice context, not legislation or a permit conclusion.

The proposed rating scheme and draft label classes are not current minimum performance law. This page must be refreshed for the scrutiny outcome, the minimum-performance initiative, revised ESRS effective date and relevant Member State implementation before any public release.

Additional Public Sources

Other governments are measuring and managing data-center demand.

Other governments are also measuring and managing data-center energy, water and grid demand.

Japan

METI and the Agency for Natural Resources and Energy

Official information on data centers and energy policy.

Open Japan source

Australia

NABERS Data Centres

Australia’s data-center rating programme for energy and related performance.

Open Australia source

United States

U.S. Department of Energy

A DOE fact sheet on data-center energy efficiency.

Open U.S. source

South Korea

AI data centers and grid connection

Government policy release on AI data centers and connecting them to the grid.

Open South Korea source

Official EU sources

Primary law, regulation and Commission material.

Source status checked 28 October 2026. Links are provided for public context; this page is not legal advice or a compliance determination.

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