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France’s ecodesign framework for digital services

While regulators engage more with sustainability, delivering Europe’s twin green and digital transitions will demand more work to understand the environmental impacts of technology

French regulators finalised their framework for sustainable design in digital services

On 17 May 2024, Arcep and Arcom published their non-binding policy framework for the ecodesign of digital services. Created in consultation with ADEME, the French National Agency for the Environment and Energy, the framework responds to a direction issued by the Government through the Reducing the Environmental Footprint of the Digital Sector Act (REEN Act 2021). The framework presents 78 criteria that must be met during the design process for digital services, including websites, streaming platforms, apps and AI tools. In determining these criteria and urging changes from industry, the regulators cite Arcep and ADEME’s estimation that the carbon footprint of communications markets could triple between 2020-2050 without meaningful action. Given Arcep’s globally leading role in advancing sustainability in communications markets, the regulator debuted the framework with a promise to promote its recommendations before the EC and governments around the world.

The non-binding policies are based around four primary goals to influence design throughout all stages of the life cycle of digital services

The framework was drafted with four central goals that carry implications across a service’s lifespan:

  1. Extend the lifespan of devices by ensuring service compatibility with older models and limiting incentives for new purchases;

  2. Promote environmental considerations in online attention economies, or designs which keep users online longer, by limiting features such as push notifications and automatic video playback;

  3. Limit the resources consumed over a service’s lifespan by optimising data traffic and limiting digital infrastructure use; and

  4. Increase transparency on environmental footprints and encourage users to be aware of the impacts of their digital consumption.

Within these goals, specific criteria are organised by priority and the difficulty to achieve them, and are intended to offer digital service providers the opportunity to evaluate the sustainability of their products while monitoring progress towards reducing their environmental impacts. Some of the criteria, especially those related to transparency, coordinate with the French Government’s prior effort to develop a sustainability index to label electronic devices, including smartphones and laptops.

European regulators are working to understand the positive and negative environmental impacts of ICT, despite limited remits

The ecodesign framework comes at a time of increasing global anxiety about the energy consumption that powers both hardware and software based communications markets. Academic research into the energy consumption of power intensive systems such as AI and blockchain as well as infrastructure like data centres suggest that ICT will account for a large and growing proportion of global energy consumption in the coming years. However, innovations in connectivity and the internet of things (IoT) also pose the potential of improved efficiency and reduced emissions across a range of industries, including transportation and agriculture, as detailed by the Malta Communications Authority. Though most European regulators lack jurisdiction to include sustainability in their remit directly, a number of agencies have begun work programmes on voluntary environmental monitoring and the relationships between sustainability and network resilience. Given the EC’s priority on managing the twin green and digital transitions, the work of managing the cost-benefit analysis of technological adoption as it relates to sustainability is likely to only grow in importance and complexity.