Fortum's views on the EU data center rating scheme

Fortum broadly supports the Commission's objective of enhancing transparency in the environmental footprint of data centres operating in the Union. A credible and comparable rating scheme can meaningfully inform decision-making by customers, policymakers and investors, and contribute to the sector's sustainability transition.

At the same time, we have identified several provisions that risk undermining the effectiveness and credibility of the scheme as currently drafted, and where targeted adjustments would improve outcomes without departing from the Regulation's core objectives.

In particular, we consider that the scheme would benefit from targeted revisions that:

• replace the 15-minute guarantee of origin (GOO) matching requirement with granularity aligned to what national registries can actually deliver, avoiding a permanent asymmetry driven by Member State administrative choices rather than data centre procurement decisions
• reconsider the 10-year asset commissioning rule for GOOs, which penalises markets such as Finland, Sweden and Norway where mature hydroelectric and nuclear assets provide clean, surplus baseload electricity, and where the additionality rationale underlying the rule does not reflect physical electricity system reality
• ensure that firm low-carbon generation, including nuclear power, is appropriately recognised in the forthcoming review of the energy indicator, given that data centres require 24/7 dispatchable electricity supply that variable renewables alone cannot reliably provide
• condition the "waste heat reuse ready" obligation on the proximity of viable heat demand, rather than requiring identical infrastructure regardless of whether a district heating network or heat consumer exists within a feasible distance
• strengthen the waste heat indicator by distinguishing between infrastructure readiness and actual operational delivery, allowing policymakers, customers and investors to identify facilities that are actively supplying heat rather than merely equipped to do so.

Projects such as the Fortum–Microsoft district heating partnership in the Helsinki metropolitan area demonstrate that waste heat reuse from data centres can deliver genuine environmental value at scale. The scheme should be designed to incentivise and reward that outcome, not to produce binary labels that treat committed delivery and prospective potential as equivalent.

Our more detailed views, including specific proposed amendments, can be found in the attached position paper.