Environmental criteria in a data centre tender: which ones can actually be verified at acceptance?

You have already written the environmental criteria line in your data centre specification, and you wrote it as a reference to an international document: it looked like the prudent choice. Then the bids arrive, every one of them declares compliance with figures obtained in different ways, and at acceptance there is nothing to measure — the document you referred to does not say by which method, at what load, at which point. A criterion that cannot be verified excludes nobody, and by the time you notice it on the evaluation panel it is too late to amend the tender.

Five pages written for the buyer

Recommendation ITU-T L.1304, Procurement criteria for sustainable data centres, edition 12/2020, first edition, was approved on 14 December 2020 by Study Group 5. The catalogue shows it In force, with a single component in force, and the English text is freely downloadable. Five pages of body text.

That makes it unusual: the L series normally addresses the designer or the operator, this one addresses the buyer. Clause 1: “This Recommendation aims to support public authorities in purchasing data centre related solution while taking in consideration a set of sustainable criteria”. A contracting authority that cannot find its own category in the catalogue of minimum environmental criteria will happily take this as a foothold.

The clause that tells you how to read it is empty

Clause 5, Conventions, in full: “None.” No conventions are declared, so there is no internal definition of how binding the verbs are. And the dominant verb is neither shall nor should: it is needs to, which in standards language binds nothing at all. Prefabricated solutions “need to be considered”, waste heat recovery “need be considered”: sensible advice, not obligations, and once moved into a specification they give you nothing to challenge.

The provisions written with shall — the one word the ITU-T preamble recognises as expressing a requirement — number three in the whole document. They are also the only part you can copy without rewriting it.

The single figure, and what is missing around it

The first can be checked by eye: “Data centre shall be realized by IT module with containment of hot or cold air” — IT modules with hot or cold air containment. Either the aisle is contained or it is not.

The second carries the only performance figure in the entire document: “UPS system efficiency shall be > of 96%”.

The efficiency of an uninterruptible power supply is not a single number: it varies with the load fraction and with the operating mode, which is precisely why test methods fix load points. Here there is no load point, no mode, no measurement standard — so whoever copies that line will receive the value declared at whichever operating point suits the party declaring it. The three missing lines: the load points as a percentage of rating, the mode in which the value must hold, and the test standard with its edition.

The word that makes bids impossible to compare

The third provision concedes two things in two lines: “Currently, there are no standardized reference values for equipment energy consumption. The declared energy efficient of the different equipment shall be measured in line with [ETSI EN 303 470] or [ISO/IEC 21836] for server or [ITU-T L.1310] for telecommunication equipment”.

First concession: no reference values exist, so either you write the threshold or there is none. Second: that or. For a server two alternative methods apply — ETSI EN 303 470 V1.1.1, published on 14 March 2019 and freely downloadable, and ISO/IEC 21836:2020, edition 1.0, published on 25 August 2020, catalogue status Published, which is a paid standard we have not read — with no obligation to declare which one was used. In a tender that is the worst possible defect: it does not make the bids wrong, it makes them incomparable. A tender document picks one, with version and date, and asks for the test report.

The best-written criterion points at a class that no longer exists

The most solid criterion in the document is the one on operating temperature: “Active equipment needs to be selected with an operating temperature in line with class 3.1 of [ETSI 300 019-1-3]”. A standard, a class, a range: it looks enforceable.

Except that since 13 May 2026, in edition V3.1.1 of that standard, class 3.1 no longer exists: the classes went from six to three and a data room now sits in class 3.10, with the same values under a different number, and the old numbers were deliberately not reused. A specification that today asks for class 3.1 without declaring the edition is asking for a class the edition in force does not contain: nobody can be in breach of it, because there is nothing to comply with.

This is not an isolated slip: of the twelve normative references in clause 2, five now point at superseded editions — besides ETSI EN 300 019-1-3, there are ITU-T L.1023 (edition 08/23 in force, under a different title), L.1310 (09/24), L.1410 (11/24) and ETSI TS 103 586. In a specification the reference is always written with the year, and the year is not the one printed in the Recommendation.

The document you need is in the bibliography

In the bibliography — outside the normative references — L.1304 cites exactly one item that genuinely concerns a tender: the EU green public procurement criteria for data centres, server rooms and cloud services, SWD(2020) 55 final of 11 March 2020. It came out nine months before the Recommendation, which cites it without adopting it.

That is where what is missing here can be found. Selection criteria, technical specifications, award criteria and contract performance clauses, each with its test method and its means of verification; the introduction states that they can go into tender documents “with minimal editing”. Paragraph 1.3 says why: “In this way it can be ensured that the performance claims provided by the tenderers are verifiable, repeatable, auditable and above all comparable”. And it sets out when to demand the proof: self-declaration with the bid, a test report from the highest-ranked bidder, operational measurement with penalties during contract execution.

What we do not know

What the 96 % is really worth. Without a load point, a mode and a method the figure is not verifiable, and we do not know what the drafter had in mind.
The content of the paid standards. Of ISO/IEC 21836:2020 and ISO/IEC TS 22237-1:2018, cited for the reliability classes, we report catalogue data only. That the latter was replaced by a 2021 edition comes from resellers, not from a primary catalogue.
Whether anyone uses it. We found no Italian tender documents referring to L.1304, so we cannot say whether the problem is theoretical or routine.
Revisions under way. The European product group stands at its 2020 edition and the Recommendation carries no amendment or corrigendum in the catalogue: whether either is being revised, we do not know.

The point

An environmental criterion protects you only to the extent that somebody can disprove it with a measurement. In the compliance specifications we deliver, every criterion comes with its own lines — value, method with edition and year, measurement point and condition, means of proof — and it is verified at acceptance, with the record and the documentation handed over together with the work. On the other axis, the documents that such a criterion generates — test reports, nameplate data, UPS load readings, room temperatures, commissioning measurements — today sit in an archive nobody opens again. With us they converge into a single map of the site and the network, where an AI flags the referenced edition that has since been replaced and the declared value that is drifting in service, and a team of ours steps in before the next verification. Where an AI is needed on that data, it runs inside the client perimeter, on-premises or in a dedicated cloud with data centres in Italy, together with CSIDIA, the other company in the group.

Are you writing the environmental criteria for a data centre tender, or do you have to accept a supply that declares them met? Talk to one of our engineers: the site visit is free of charge, and a criterion is written so that it holds up under challenge.