Summary As proposed, when designating data centre acceleration zones Member States must consider a preference for reusing brownfield sites over greenfield sites. Article 10(1)(g) lists this preference as one of the aspects to weigh, alongside sustainability and climate-resilience under Article 10(1)(h). It is a factor to consider, not an absolute ban on greenfield development. The aim is to minimise environmental impact and reuse existing land while accelerating compute capacity across the Union.

Detail

CADA introduces a harmonised framework to address the EU's shortage of computing capacity and its reliance on third-country cloud providers. A central pillar is the data centre acceleration zone — a designated area where deployment, expansion, and modernisation of data centres are facilitated through streamlined permitting and administrative processes.

When Member States designate these zones, they are not free to choose locations arbitrarily. Article 10(1) sets out specific aspects they must consider so that rapid expansion aligns with the Union's environmental and sustainability goals.

The brownfield preference in Article 10

Article 10, "Designation of data centre acceleration zones," requires each Member State, where data centre capacity is being deployed in its territory, to designate at least one acceleration zone (within six months of entry into force). When doing so, Member States "shall consider" a list of aspects.

Article 10(1)(g) lists, among them:

"(g) the preference for reusing brownfield sites over using greenfield sites;"

This signals a clear intent to prioritise redeveloping previously used land over developing virgin agricultural or natural land — though, as proposed, it is a factor Member States must weigh at the zone-designation stage, not an outright prohibition on greenfield projects.

Sustainability and environmental rationale

The brownfield preference is tied to CADA's broader sustainability objectives. Article 10(1)(h) requires consideration of:

"(h) the ability of the site or area to function sustainably, particularly as regards preventing or minimising environmental impacts and supporting the reduction of carbon emissions and its climate resilience."

Brownfield redevelopment typically avoids the loss of agricultural land, habitats, and carbon sinks, and such sites often already have some connectivity (road access, possibly grid links), reducing the footprint of new construction.

This aligns with Article 11, under which, when setting sustainability requirements for data centres in acceleration zones, Member States shall use the key performance indicators specified in Delegated Regulation (EU) 2024/1364 (Annex II, points (a) to (n)), adopted pursuant to Directive (EU) 2023/1791.

Integration with spatial planning

Zone designation must connect to planning. Article 10(3) provides that national, regional, and local authorities responsible for spatial and development plans shall consider including provisions for the development of data centre projects in acceleration zones and the necessary infrastructure, and that Member States shall ensure relevant spatial planning data are available to operators. Where such plans require strategic environmental and habitats assessments, those assessments are to be combined.

CADA also recognises that data centres are major energy consumers. Article 10(2) provides that Member States shall, where appropriate, conduct (and review at least every three years) a comprehensive analysis of the energy needs of current and future acceleration zones, and ensure that transmission and distribution system operators' network development plans take due account of it. Brownfield sites near population and industrial centres may offer advantages in grid proximity and waste-heat reuse, reinforcing the sustainability rationale.

Facilitated permitting

Once a zone is designated, projects within it benefit from facilitated administrative and permit-granting processes under Article 13. Under Article 13(1), data centre projects deployed in acceleration zones "shall be considered as strategic projects within the meaning of Article 14 of [the] Regulation [on speeding-up environmental assessments]" and benefit from the toolbox in that Regulation's Annex — accelerating environmental assessments while maintaining protection of human health and the environment. Brownfield redevelopment can sometimes streamline these assessments, supporting CADA's wider objective of tripling EU data centre capacity within the next five to seven years.

What this means for you

For public-sector procurement officers and regional planners, the brownfield preference has practical implications:

  1. Site selection. When identifying candidate locations, prioritise industrial estates, former manufacturing sites, and other developed land. Greenfield should be considered where suitable brownfield options are lacking, with the sustainability impact assessed against Article 10(1)(h).
  2. Stakeholder engagement. Involve environmental agencies and planners early. Showing alignment with the brownfield preference strengthens the case for designation and smoother integration into development plans.
  3. Infrastructure planning. Brownfield sites may need power and connectivity upgrades; ensure your Article 10(2) energy-needs analysis accounts for the cost and timeline.
  4. Procurement. Reflect brownfield realities (soil remediation, legacy-infrastructure removal) in tender documents to attract qualified contractors.

Common misconceptions

  • "Brownfield preference is mandatory for every project." Article 10(1)(g) requires Member States to consider the preference when designating a zone. It is a factor, not an absolute ban on greenfield data centres — though disregarding it without strong justification would sit poorly with CADA's sustainability goals.
  • "Greenfield sites are always better for connectivity." Greenfield may offer more space, but brownfield sites often benefit from existing road networks and urban proximity, aiding grid connection and workforce access.
  • "CADA ignores environmental concerns for speed." CADA streamlines permitting but does not lower environmental standards; the brownfield preference is one mechanism to keep rapid deployment sustainable.

Related

This is general information about a draft EU regulation, not legal advice.