The EU’s New Data-Centre Labels Won’t Tell You the Whole Energy Story
A large data centre can use energy efficiently and still place a heavy demand on its local grid. That distinction matters as the EU prepares to give individual facilities public grades for power and water efficiency. The labels should make comparison easier, but they will not show each site’s exact annual electricity consumption.
On 21 September 2026, the European Commission adopted a delegated regulation to create the labels. It is still under European Parliament and Council scrutiny. If it survives that process, the EU database is due to generate the first labels by 15 August 2027. Operators are already reporting the underlying information under rules introduced in 2024. The change is which parts of that information become visible on a standard, facility-specific label.
What a label will actually show
The proposed label gives separate A-to-G classes for power usage effectiveness, or PUE, and water usage effectiveness, or WUE. PUE compares a facility’s total energy use with the energy delivered to its IT equipment. WUE relates freshwater use to IT energy. These measures can reveal differences in cooling and support systems, but neither is a figure for the site’s total annual demand.
The Commission’s annex sets the grade boundaries. A PUE of 1.15 or lower earns an A; a PUE above 1.9 earns a G. Water efficiency has its own class boundaries. There is no overall sustainability score that rolls power, water and other factors into one letter.
The label also identifies the operator and site, gives its size category and reporting period, and includes cooling degree days to help put efficiency in climate context. It shows an energy-sourcing breakdown covering, among other categories, on-site renewable or nuclear generation, power purchase agreements, guarantees of origin and sources the operator has not identified. It says whether the centre provides flexibility functions to the electricity grid and whether it is ready to capture and provide waste heat to external users.
That last word matters. Under the adopted text, “waste heat reuse ready” describes a facility designed or retrofitted with equipment to provide heat at its boundary. It does not mean a heat network is connected or that homes are being heated. Likewise, the energy-sourcing information is about the electricity a site uses and how it is procured. It is not a claim that the centre exports clean electricity.
The total behind the grade
Efficiency ratios answer a useful question: how much total energy or freshwater does a facility use relative to the energy consumed by its IT equipment? They do not measure useful computational work or answer how many megawatt-hours of electricity or how many cubic metres of water the whole site consumes in a year. A very large facility with strong efficiency grades can still have a larger absolute footprint than a smaller facility with weaker grades.
That gap is deliberate in the EU database design. Under Delegated Regulation (EU) 2024/1364, operators already submit facility-level information and performance indicators. The public database publishes totals and averages at Member State and EU level, while the Commission and Member States keep individual facility submissions confidential. The new act would make an exception for the information displayed on the public label, in the form shown there. Its label template includes a size category and an energy mix, but no exact annual site energy total.
That does not mean EU law makes every site figure secret. Article 12 and Annex VII of the Energy Efficiency Directive separately require Member States to make covered operators publish specified facility information, including installed power and energy-related indicators, subject to trade-secret and confidentiality protections. What an operator publishes outside the EU database can therefore depend on those rules and their national implementation. The narrower, verifiable point is that the new EU label itself is not an annual electricity or water bill for each site.
This matters for procurement. A cloud buyer can use the label to compare facilities with similar size, age, climate and service characteristics, then ask the provider for absolute energy and water figures, the period they cover, and any assurance behind them. A strong PUE grade alone is not evidence that a supplier’s total demand is low. Nor does the label certify service resilience: as BlackTree has noted in its critical-infrastructure resilience explainer, a data centre can still depend on a single power route even if its technical controls are strong.
Who is covered, and when?
The underlying duty applies to EU data centres with at least 500 kW of installed IT power demand. This is not a threshold for the entire building’s electricity consumption or its grid connection. The Commission’s short announcement says “above 500 kW”, but the existing regulation’s Article 1 and the Energy Efficiency Directive both say “at least”, which includes a site at exactly 500 kW. The new act would also let smaller centres and facilities not yet operating opt in.
Operators first had to communicate information to the EU database under the 2024 regulation. The September 2026 act builds on that reporting: the database would generate the label automatically from submitted figures, make it available publicly in all official EU languages, and issue a new one each year. An operator would also have to provide its label electronically to anyone asking for it, or direct them to the database. A label should therefore be treated as a dated snapshot, not a permanent rating.
There is still a legal timetable to complete. The Parliament procedure file records an initial two-month period for examining the delegated act. The Directive allows Parliament or Council to extend that by two months. The act would then enter into force 20 days after its publication in the Official Journal. The first-label date in the text is a plan under the adopted act, not proof that a facility can display an official label today.
A label is not a limit
The Commission’s memorandum estimates that EU data centres used 68 TWh of electricity in 2024 and cites a projection of 114 TWh by 2030, equivalent to about 3.2% of projected EU electricity demand. Those figures explain why the Commission wants comparable information as data-centre capacity grows. They are estimates and a forecast, not measured 2030 consumption or a statutory cap.
The rating act sets classes and publication rules. It does not ban a G-rated site, impose a maximum electricity or water budget, or require a given share of waste heat to be reused. The Commission has opened a separate consultation on possible minimum performance standards, open until 14 December 2026, with a proposal planned for the second quarter of 2027. That is the process to watch for future hard thresholds.
For operators, the immediate preparation is to establish which sites meet the installed IT power threshold and whether the already reported data will withstand being turned into a public label. For buyers and local communities, the label will be a starting point: it can expose efficiency, sourcing and readiness claims in a common format, while leaving the question of each site’s total resource demand to other disclosures and direct scrutiny.
Primary sources
- European Commission, adopted delegated act C(2026) 3472 and annexes, 21 September 2026.
- European Parliament, delegated-act procedure 2026/2895(DEA), checked 28 September 2026.
- Directive (EU) 2023/1791, Article 12, Article 34 and Annex VII.
- Delegated Regulation (EU) 2024/1364, existing reporting and EU database rules.
- European Commission, data-centre energy performance policy page, consultation timetable and background, checked 28 September 2026.
Continue the series: European National Cyber & Digital Law Series index
