Hírek Our Feedback to EC 18 September 2022

Have your say - Sustainable mobiles & labelling

You can also get involved in forming EU laws. The European Commission would like to hear your views on laws and policies currently in development. They offer a platform "Have your say" with the list of all new EU initiatives open for public consultation. You need to register to write your feedback.

https://ec.europa.eu/info/law/better-regulation/have-your-say

There are always 5 stages of each EU initiative, each stage is open for public consultation for a specific time frame:

  1. In preparation

  2. Call for evidence

  3. Public consultation

  4. Draft act

  5. Commission adoption

Designing mobile phones and tablets to be sustainable – ecodesign

About this initiative: It aims to ensure that:
- mobile phones and tablets are designed to be energy efficient and durable
- consumers can easily repair, upgrade and maintain them
- it is possible to reuse and recycle the devices.

Feedback period: for stage 4 it is 31 August 2022 - 28 September 2022

Link: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12797-Designing-mobile-phones-and-tablets-to-be-sustainable-ecodesign_en

Energy labelling of mobile phones and tablets – informing consumers about environmental impact

About this initiative: EU energy labels provide a clear and simple indication of the energy efficiency of products at the point of purchase.

Feedback period: for stage 4 it is 31 August 2022 - 28 September 2022

Link: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12798-Energy-labelling-of-mobile-phones-and-tablets-informing-consumers-about-environmental-impact_en

Feedback 1 from Europeans for Safe Connections

We "Europeans for Safe Connections" welcome the initiative to protect the environment, reduce the waste and obsolescence of personal devices and save energy. Unfortunately, the 5G deployment and IoT’s usage will have a huge negative impact. We suggest:

- All devices with wireless features must pass all procedures defined in Directive 2014/53/EU before being placed on the market but also those already on the market. Any device undergoing repair, part replacement or firmware upgrade must be re-certified on RF peak values of each antenna and also the sum of all peak values. This will ensure energy efficiency and user will be informed on the exposure.

- Promote design of devices with replaceable components (e.g. battery, display, etc.), sharing parts across various models and with other vendors. Parts and software support should be provided for longer time.

- Wireless functions must be set to "Disabled" by default and stay disconnected until intentionally turned on. Airplane mode must not be overridden by any apps. The phone is communicating with the base stations even when user is not using it, this applies also to Wi-Fi, BT, mobile data. This makes up the largest part of the energy consumption and the wireless devices require very frequent charging.

- In order to ensure minimal power consumption (and minimise RF exposure), manufacturers should develop antennas with significantly improved overall sensitivity for signal reception and with the lowest possible radiation power levels.

- In order to improve battery management (and minimise RF exposure), function of prioritising the lowest radiation power wireless antenna should be implemented and the frequency of synchronisation with the base stations (or access points) should be reduced as much as possible, even to zero if not used by user.

- A safety mechanism should be integrated into the device to alert the consumer to a worsening signal quality. This should include displaying an alert, selecting the antenna with the lowest power, reducing the number of queries to access points or base stations, warning before making a call or before using wireless data transmissions. The alert thresholds could be adjusted differently for children, EHS and pregnant women.

In our ECI, among 23 proposals there are:

- Proposal 12: Reduce the massive electricity consumption caused by digital communication technology, e.g. by prioritizing wired solutions and low energy solutions in the action plan for the European Green Deal

- Proposal 13: Include "Waste from Electrical and Electronical Equipment" (WEEE), other waste products, and the environmental impacts of mining for rare earth minerals and metals used in electronical equipment in the “Zero pollution action plan”.

- Proposal 14: Update Ecodesign Directive from 2009 setting tight limits to resource and energy waste of all connected devices including antennas and satellites.

www.signstop5g.eu/en/solutions/protection-of-our-environment

Best regards
Kamil Bartošák, Petra Bertová, Giorgio Cinciripini
on behalf of the Europeans for Safe Connections
This feedback was sent from a wired internet connection
- No use of harmful radiation
- Less electricity consumption
- Increased data security

https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12797-Designing-mobile-phones-and-tablets-to-be-sustainable-ecodesign/F3342153_en

Feedback 2 from Europeans for Safe Connections

We "Europeans for Safe Connections" welcome this initiative, because the proposed labelling will inform the potential customer and, at the end, will reduce the energy consumption required by smartphone and tablets.

But, this proposed regulation will be hindered by the deployment of 5G and Internet of Things that is moving in the opposite direction: increase of energy request for high speed wireless data transmission, servers, devices’ use!

We suggest a pair of information on wireless devices:

- how long will the battery last with all wireless functions ON
- how long will the battery last with all wireless functions OFF

We suggest a label indicating whether the device contains parts of conflict minerals.

We suggest a label indicating how many water was used to produce this device and how many water is assumed to be produced to recycle this device.

In addition to energy labels, we suggest to add labeling related to radiofrequency electromagnetic fields (RF EMF):

- Introduce clear labelling indicating the presence of RF EMF, the transmitting power or the specific absorption rate (SAR) of the device and any health risks connected with its use. Due to negligence by vendors and regulators, devices exceeding the permitted exposure levels entered the market and posed a health danger to the consumers, without informing them (Art. 169 TFEU).
It is crucial to set SAR exposure measurements at a distance of 0mm between the device with wireless capabilities and the head, and also between the device and the body according to Formal Objection against EN 50566:2017 from ANSES France:
ec.europa.eu/docsroom/documents/43448/attachments/2/translations/en/renditions/native

- Instruct manufacturers to print safe usage procedures on devices and not only inside manuals.

- Apply warnings ("labelling") on device packaging with regard to their harmful effects. Similar regulatory approaches are known, for example, from European food law. Jurisdiction can be affirmed on the basis of Art. 114 TFEU.

- Integrate a meter into the device to measure and log exposure including peak values for all frequencies operated on the device during active mode and passive standby mode.

Best regards
Kamil Bartošák, Petra Bertová, Giorgio Cinciripini
on behalf of the Europeans for Safe Connections

This feedback was sent from a wired internet connection
- No use of harmful radiation
- Less electricity consumption
- Increased data security

https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12798-Energy-labelling-of-mobile-phones-and-tablets-informing-consumers-about-environmental-impact/F3342170_en

labelling
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