How to Comply with Lot 9 Regulations

Aug 09, 2019

UNICOM Engineering EU Lot 9 Regulations

Products that are imported into a country or trade region usually have to meet certain standards that guarantee consumer safety, environmental friendliness, and other criteria. This usually means that a certain product must undergo testing to certify that it meets or exceeds the standards before it is allowed to be imported or exported.

Lot 9 regulations are a new set of product standards that deal with data storage devices like enterprise-level servers. This directive lays out a strict list of requirements that servers must demonstrate they can meet, such as power usage and product life cycle, or they won't be allowed into Europe after March 1, 2020. Complying with Lot 9 is a necessary part of acquiring the CE mark, which is a certification that indicates conformity.

The European Parliament (ErP) is one of seven institutions of the European Union (EU) that handles all legislative matters. In this scope, they are responsible for setting the ecological standards for products that are imported into the EU. These standards often have mirrored global standards but the Lot 9 regulations, which cover products in the realm of online data storage, currently signal a significant departure from other global standards such as Energy Star.

As of now, by March 1st, 2020, the European Union (EU) will enforce updated standards and regulations concerning products that are produced and imported into the EU. More specifically, these new standards are broken down into sections called lots, and numbered with respect to their various industries. While Lot 9 covers data storage devices and servers, it currently denotes a difference between those and server appliances, which are specialized servers designed for a specific purpose, often with pre-installed software.

Lot 9 Regulations vs. Energy Star

Historically, the standards laid out by Energy Star, an energy efficiency program run by the United States Environmental Protection Agency (EPA), have been stringent enough to also satisfy the regulations of other governmental bodies. The Lot 9 requirements have introduced a necessity for some products to now comply, when previously, they did not. Depending on the product and how it fits specific definitions for server, server appliance, or data storage it may or may not be in line with Energy Star performance requirements. Additionally, Lot 9 now has requirements for information that must be provided to the end user for a certain amount of time after the last sale of the product.

This means companies that export their server and data storage products to the EU must come up with a new process for testing and certifying that their devices meet the new standards.

Products meeting the definition of Server, which is essentially a computing device meant to run server operating systems and run user-installed enterprise applications, now have testing requirements that are the same as Energy Star, with the Energy Star requirements being slightly higher than Lot 9. This means if you meet Energy Star, you meet Lot 9.

For Server Appliances that used to perform some dedicated function and not run end-user installed software, the Lot 9 requirements are not applicable.

The biggest change, however, is for Data Storage products. These have not had any requirements in the past and now must meet power supply efficiency and power factor requirements. These new requirements are in line with the “80 PLUS” requirements currently being used by most power supply vendors to denote their levels of efficiency and power factor. Multi-output power supplies be rated 80 PLUS Gold, and single output power supplies must meet 80 PLUS Platinum by 1-Mar-2020. Data Storage products containing power supplies meeting these 80 PLUS levels will be compliant to the Lot 9 requirements.

How to Best Comply with Lot 9 Regulation

For Server products, the testing methodology for Energy Star and Lot 9 are identical. Products that are tested to Energy Star requirements, and pass, will comply with the Lot 9 requirements. Of particular note is that even if a product fails to comply with Energy Star, the power supply efficiency and power factors measured during the Energy Star testing may still be in compliance with Lot 9, whose requirements are slightly less rigorous.

Data Storage products, under Lot 9, do not require any special testing of the final product. The power supplies must meet the efficiency and power factor requirements. Most power supply manufacturers today gain certification under the 80 PLUS program and label their power supplies according to the level achieved. As stated above, multi-output power supplies must be rated 80 PLUS Gold and single output power supplies must meet 80 PLUS Platinum. An 80 PLUS Verification & Testing Report contain the information necessary to show compliance to Lot 9.

For both Server and Data Storage products, Lot 9 requires other information to be provided to the end users, either via a website, which shall remain live for at least 8 years after the last sale of the product, or information added to the user’s manual shipped to the product. Additionally, the latest firmware releases and security updates must also be available online.

Data Storage products must also provide functionality for secure data deletion and provide information regarding this functionality in the user manual.

Although test reports resulting from Energy Star or 80 PLUS testing can be used to demonstrate compliance, the non-testing requirements inferred to above require manufacturers to ensure that all the other requirements are met as well. Documenting how those requirements are met will require a cross-functional team of engineers, web developers, technical publishers, and project managers to ensure that all requirements are met.

Lot 9 Timeline

From the roll out of these new product standards to the date of their enforcement is on a much tighter timeline than other similar regulatory updates. Because the process of meeting new compliance standards can take months to years, with certifying a new laboratory and putting products through the rigorous testing being a time-intensive process, it currently appears difficult to both comply with the new Lot 9 directives and do it before their current deadline of March 1, 2020.

Due to the assembly of cross-functional teams required to implement all the requirements in addition to the 80 PLUS ratings of existing power supplies in products, there is plenty of work to be done to achieve compliance and to complete all the necessary tasks and documentation by March of next year. With the multitude of possible hardware, software, web development, and change management required to put servers and data storage products into the EU, one of the best things a company can do to prepare for the changes is consult with a trusted partner that thoroughly understands regulatory requirements. The UNICOM Engineering Regulatory Compliance team provides assurance that all the manufacturing regulatory requirements are being considered and adhered to while our clients focus on their core competencies. We act as an extension of your business by monitoring requirements for countries around the world. To learn more about how the UNICOM Engineering team can assist in navigating the global regulatory process, visit our Regulatory Compliance page or contact us by email at

Category: Compliance