H. GROENEBOER 1 Lucent Technologies Proprietary ETSI/OCG22(04)16 ETSI OCG meeting February ECO ENVIRONMENTAL PRODUCT STANDARDS (ETSI EE-EEPS) H. Groeneboer Supply Chain Networks Director Environmental Affairs Management

H. GROENEBOER 2 Lucent Technologies Proprietary ETSI/OCG22(04)16 CONTENT ETSI EE - EEPS group CENELEC ETSI interest Standard under development (example ) Considerations for ETSI (for discussion)

H. GROENEBOER 3 Lucent Technologies Proprietary ETSI/OCG22(04)16 ETSI TC EE Eco Env. Product Standards Inclusion in EE TOR Observation of European legislation and judging impact on telecommunication infrastructure equipment. Maintain a liaison with CEN/CENELEC on development of Eco-environment related product standards Modus operandus Established in Convenor H. Groeneboer Per correspondence via ETSI list-server Liason/ observer CENELEC work (BTWG 85-3)

H. GROENEBOER 4 Lucent Technologies Proprietary ETSI/OCG22(04)16 CENELEC BTWG 85-3 Environmental activity - ETSI interest Environmental advice to Technical board and technical committees Generates proposals for new tools (e.g. Environmental data base) Established BTTF in response to mandate M/336 (WEEE: ‘marking’) EC consultation on Integration of Env. aspects into standardisation. (Contribution ETSI by EEPS) Eco- design for Energy Using Products (EuP) will be considered on implications for CENELEC Integrated Product Policy (EC publication)

H. GROENEBOER 5 Lucent Technologies Proprietary ETSI/OCG22(04)16 Current view on ETSI interest Standards on metrics setting for environmental performance of equipment Protect telecomm interest in development of horizontal Eco Env. Product Standards, i.r.t. to the specifics of this industry as system integrators and the international nature of the business. Protect telecom interest in specific interpretations of the directives and the impact on the to be developed standards.

H. GROENEBOER 6 Lucent Technologies Proprietary ETSI/OCG22(04)16 CENELEC BTTF example EC Marking Mandate M/336 (12 June 2003) to CEN/ CENELE/ ETSI To produce standards that satisfy the marking requirements of Art 11(2) of the WEEE Directive. Must cover all EEE listed in Annex I Particular regard for small or very large EEE Account should be taken of existing marks or work in preparation by MS Standard for a mark should be completed by end 2004 Use of “smart tracker chips” should be examined

H. GROENEBOER 7 Lucent Technologies Proprietary ETSI/OCG22(04)16 CENELEC BTTF Convenor: Mr Rene Nielsen (Denmark) Meeting schedule: Kick off meeting January 19, 2004 February 5th and 6th, 26th and 27th April 1st and 2nd, 21st and 22nd Intention to have final draft by 1st May Decision D117/118: Decision process under Unique Acceptance Procedure UAP Does not allow the expression of technical comments during voting

H. GROENEBOER 8 Lucent Technologies Proprietary ETSI/OCG22(04)16 WEEE and RoHS concerns Specific concerns for Telecommunication industry due to unclear definitions in the directives, impacting ‘Marking’ standard Identification of Producer - Telecom suppliers and operators as system integrators might become unintentionally the ‘producer’ under the law. Placed on the market - For RoHS to interpreted at Community level. (non binding opinion of Commission to EICTA) - For WEEE it is related to individual MS. (As WEEE and RoHS are being transposed jointly at many MS’s, it could lead to contradictory and conflicting interpretations) Note: Re-labelling when products are transferred from one MS to another is not in conformity with EC Treaty rules.

H. GROENEBOER 9 Lucent Technologies Proprietary ETSI/OCG22(04)16 WEEE Directive Responsibility for Producers- not only financing: Recovery. Recycling targets (Art. 7) Financing (Arts. 8 and 9) Collection (Art. 5) Treatment (Art. 6) Design (Art. 4) and all RoHS Information for users and Marking (Art. 10) Information for treatment facilities (Art. 11) Registration and reporting (Art 12) Identification of producer with a mark (Art. 11.2)

H. GROENEBOER 10 Lucent Technologies Proprietary ETSI/OCG22(04)16 CONCLUSION: The development of a ‘simple’ mark might have unexpected impacts for the telecommunication industry

H. GROENEBOER 11 Lucent Technologies Proprietary ETSI/OCG22(04)16 Considerations for an active ETSI INVOLVEMENT Need for attention in ETSI (beyond observer role) to address issues and work position statements while leaving CENELEC in the ‘driver’ seat. Work with CENELEC on common issues and interpretations of legislation up to EC level when developing standards. Need for active participation in EEPS from ETSI members. Flexible process to facilitate change from observer to active participant. Mandate for ETSI representative to work in CENELEC on behalf of ETSI members. Act and inform later, due to time constraints. Develop an information site with links to active groups in Europe. (CENELEC, EICTA, Orgalime, etc.)

H. GROENEBOER 12 Lucent Technologies Proprietary ETSI/OCG22(04)16 Back up information

H. GROENEBOER 13 Lucent Technologies Proprietary ETSI/OCG22(04)16 WEEE and RoHS definitions ‘Producer’ means any person who, irrespective of the selling technique used, including by means of distance communication: (I) manufactures and sells EEE under his own brand, (ii) resells under his own brand equipment produced by other suppliers, a reseller not being regarded as the ‘producer’ if the brand of the producer appears on the equipment, as provided for subpoint (I), or (iii) Imports or exports EEE on a professional basis into a member state