Data Center Waste Compliance Checklist (US + EU)

Program and data

• ☐ Waste stream inventory per site (IT, batteries, refrigerants, generator fluids, packaging, construction, general)
• ☐ Monthly tonnes per stream from weight tickets
• ☐ Net cost and material revenue per stream
• ☐ Named owner for each stream
• ☐ Waste KPIs reported monthly (intensity per MW, diversion, net cost)
• ☐ Contracts centralized with expiry dates

IT hardware and ITAD

• ☐ Serialized asset list before every decommissioning
• ☐ Sanitization or destruction per NIST SP 800-88, method per device
• ☐ Certificate per serial number on file
• ☐ ITAD partner certified R2v3 or e-Stewards
• ☐ Data destruction partner certified NAID AAA
• ☐ Downstream destinations documented
• ☐ Revenue share on resale and metals in contract
• ☐ Reconciliation: assets out = certificates in = revenue received
• ☐ EU: WEEE treatment by authorized operators; no illegal export

UPS batteries

• ☐ Battery inventory with chemistry and replacement dates
• ☐ US: universal waste labels and accumulation dates, shipped within one year
• ☐ Lithium-ion shipped as Class 9 hazardous materials by trained staff
• ☐ Damaged batteries isolated, fire controls in place
• ☐ EU: producer take-back free of charge written into supply contracts
• ☐ Recycler certificates on file

Refrigerants

• ☐ Inventory of appliances with refrigerant type and charge
• ☐ Leak-check schedule and records per appliance
• ☐ Certified technicians only
• ☐ Recovery records for every intervention
• ☐ US: HFC leak repair rules applied to appliances of 15 lb or more
• ☐ US: check Technology Transitions limits before buying new cooling equipment
• ☐ EU: F-gas Regulation (EU) 2024/573 obligations tracked
• ☐ France: BSFF in Trackdéchets for every intervention

Generators and fluids

• ☐ Used oil, filters and oily rags segregated and labeled
• ☐ Spill kits at fuel and oil storage
• ☐ Hazardous waste quantities counted monthly (US generator status)
• ☐ France: hazardous waste on BSDD in Trackdéchets

Packaging and general waste

• ☐ Packaging zones at loading docks during deployments
• ☐ Cardboard and film baled and sold
• ☐ Pallets returned or resold
• ☐ Vendor take-back of packaging in purchase contracts
• ☐ France: 7-stream sorting in place
• ☐ Contamination checks weekly

Invoices

• ☐ Every hauling invoice checked against contract
• ☐ Lifts, rental, surcharges and fees verified
• ☐ Material revenue checked against market prices