ALE Environmental Policy

This Policy will outline the commitment of Alcatel-Lucent Enterprise to protecting the environment and operate its business in a manner that reduces the impact on the environment by:

• the development of energy-conscious designs
• compliance with environmental laws and regulations and other obligations
• the conscious lifecycle management of our products and solutions, with proper recycling and disposal of products and consideration for the use of environmental packaging
• collaboration and direction towards suppliers: requiring delivery and evidence of environmental regulations compliant components and systems
• manufacturing partners that have the same objectives and compliance in terms of environmental legislations and obligations in their manufacturing environment
• documentation and declarations of compliance of our products and solutions

Strategy

ALE’s Quality Management System (and Operating model) has developed an internal strategy and associated process and procedures to ensure compliance with the many factors of the environmental aspects and involved parties. We are committed to comply with all applicable environmental requirements and to adopt management systems that enhance our environmental adherence and performance.

As part of Continual Improvement efforts, this framework is reviewed regularly to keep up to date with ever-changing laws and regulations, and if required, we will update the corresponding process, procedures and associated declarations of conformity.

The development of energy-conscious product and solution designs

ALE is committed to design and develop products that are energy conscious during usage.

ALE products (predominantly applicable to switches) are designed to minimize power consumed during operation and to provide high-efficiency solutions with regards to power consumption. The products are designed to conform to requirements defined by 80 PLUS® and ENERGY STAR®. Key elements in the design and operation of ALE products include:

• Power supplies in ALE products have a guideline to be designed to exceed the criteria defined by the 80 PLUS® power supply certification.  Power supplies meeting the 80 PLUS® requirements deliver over 80% power efficiency.  For most ALE products the power supplies conform to the 80 PLUS® Silver requirements with 85%+ efficiency and some conform the 80 PLUS® Gold requirements with 87%+ efficiency.
• ALE products typically support the IEEE 802.3az Energy Efficient Ethernet (EEE) standard.  EEE reduces the power consumption associated with Ethernet links during periods of low data activity. The goal is to reduce energy consumption by 50%.
• Dynamic Power over Ethernet (POE) allocation ensures that POE usage in the only consumes the power required by the powered devices.  This functionality allows for maximum efficiency in power consumption by the products.  
• When possible products (mainly switch products) have implemented Adaptive Active Cooling which allows fan speed to vary based on temperature inside the product and reduces energy consumed.

Compliance with environmental laws and regulations and other obligation

ALE keeps abreast of all the legislative and regulatory changes that apply to our products and solutions. In particular we developed special processes and procedures to deal with ROHS (Restrictions of Hazardous Substances) and REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) and we capture the relevant information from our supplier documentation and certification in our Product Life Management (PLM) system to document compliance with the various requirements that enables us to generate the various declarations of conformity.

Relevant regulations: 

• EU RoHS Recast (Directive 2011/65/EU) 
• EU RoHS Recast Amendment 2015/863 regarding phthalates
• EU REACH Regulation (EC No 1907/2006)

The conscious lifecycle management of our products and solutions

ALE has a dedicated Business Lifecycle (BLC) process that guides the development of products from requirements throught the development cycle, transition to manufacturing, sales, product shipment and to the end of life and end of support as the final phase. 

Packaging materials used during shipment of the products also has to comply with the relevant regulations:

• EU Packaging Directive (94/62/EC)
• US Toxics in Packaging Restrictions (Consolidation of state level regulations)

Once the products are decommissioned, we also ensure proper disposal and recycling compliant with Directive 2012/19/EU on Waste Electrical and Electronic Equipment (WEEE) and provide a take-back option.

Collaboration and direction towards suppliers

To ensure that procurement or sourcing of components or systems complies with the regulations (and as part of the Environmental Strategy), ALE has created a specification directed to its suppliers to require compliant materials and corresponding declarations.

Alcatel-Lucent Enterprise’s Restricted Materials Specification provides details of the

• Applicable legislations governing restricted materials
• Applicable materials restrictions
• Applicable material disclosure requirements

for components and materials supplied to Alcatel-Lucent Enterprise. These requirements and restrictions are mandatory for components and materials supplied to Alcatel-Lucent Enterprise for use or integration in Alcatel-Lucent Enterprise’s products and solutions.  

Manufacturing partners 

Our manufacturing partners are expected to observe the same behavior towards environmental practices and regulations. We do expect that they possess an ISO14001 certification (specifies the requirements of an environmental management system). 

Documentation and declarations

ALE provides documentation related to ROHS and REACH compliance in the form of ECO (Environmental Declarations) in accordance to the ECMA TR / 70 or 370 model and a REACH statement listing which version of compliance and the Substances of Very High Concern (SVHCs) or any other declarations as requested.

Upon request we also deliver the EU declaration of conformity.