Tim BannonProduct Manager, EMEA

RoHS & WEEECompliance Programme

Update

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Agenda

VeriFone Environmental Compliance Programme

RoHS

Part Numbers

Product Release

“Put on market”

WEEE

Timeline Summary

Current activities

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VeriFone Environmental Compliance Programme

As a trusted global leader in the secure electronic payment industry, VeriFone is committed to address the RoHS Directive as part of its corporate Environment Compliance Programme (ECP)

Under the ECP, VeriFone has been actively working with industrial partners, suppliers and service providers to comply with all applicable substance legislation worldwide

The use of environmentally friendly substances will not affect VeriFone’s commitment to delivering high quality products. We will continue to work diligently with our customers to ensure a smooth transition to RoHS compliant products

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RoHS (Restriction of the use of certain Hazardous Substances)

EU directive effective 1 July 2006 – adopted as law in EU member states

Defines the prohibited substances (lead, mercury, cadmium, hexavalent chromium, PBBs, PBDEs) in terms of maximum concentration value

All product imported and deployed into the EU from 1 July 2006 must be RoHS compliant

SC5000, PP100SE, Vx510, Vx610, Vx570, Vx670, MX870 product families will be RoHS compliant

RoHS product will begin shipping to ALL of EMEA from1 July 2006

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RoHS Part Numbers

RoHS compliant part numbers end in an alpha characters:

Vx510, M251-xxx-xx-xx(a)Vx570, M257-xxx-xx-xx(a)Vx610, M256-xxx-xx-xx(a)Vx670, M267-xxx-xx-xx(a)SC 5000, M108-xxx-xx-R or M108-xxx-xx-RxxPP1000SE, P003-xxx-xx-R or P003-xxx-xx-RxxMx870, M090-xxx-xx-R

Accessories xxxxx-xx-R

Terminals

Consumer Facing

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RoHS Part Numbers continued

Items NOT requiring RoHS Part Numbers Intangible items such as firmware, services, on-line

manuals etc Plastic Parts Paper products such as Certs and Regs, Quick install

guides, labels, boxes

Spares Spare parts are not required to be RoHS compliant Most product lines will move to RoHS spares which will be

backward compatible to non RoHS variants

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RoHS Product

RoHS product does NOT require different OS or software

Currently sent out limited units for functional testing• SC 5000, PP1000SE and Vx610 GPRS sleds sent out on 2 May• 610 WiFi sleds/terminals, 510 and 570 terminals to be sent out around

25 May)

Target is to begin shipping RoHS compliant product for deliveries scheduled after 1 Jul 2006

VeriFone can only ship Non-ROHS compliant product to non EU countries

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“Put on market”

Non-RoHS goods can be resold in EU countries after 1 Jul 2006 if the goods have been “put on the market” before 1 Jul 2006

The Guide to the implementation of directives based on the New Approach and the Global Approach defines “put on the market” as follows: • Ownership – Must of exchanged between VF and another legal entity • Delivery - Goods have been physically delivered and cleared EU

customs• Packaging - Goods are packaged in their final working condition

without requiring further measures (e.g. OS has already been loaded)• Shipping - Goods must be shipped with the intent of being sold into

that country. “In-transit” goods are not considered to be “put on the market”

• “The market” can be considered to be the EU market or the local market. This varies by the domestic laws.

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“Put on market” is defined as…

Austria

Belgium

Cyprus

Czech Republic

Denmark

Estonia

Finland

France

Germany

Greece

Hungary

Ireland

Italy

Latvia

Lithuania

Luxembourg

Malta

Poland

Portugal

Slovakia

Slovenia

Spain

Sweden

The Netherlands

United Kingdom

BLUE EU market

GREEN Local market

LIGHT BLUE Not yet defined so use EU market

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Importing Non-RoHS Product Implications

Non ROHS goods are imported into an EU country and “put on market” before 1 Jul 2006

VIP wants to export goods to Country Y

Country Y’s interpretation of “the market” must be the EU market for the goods to be imported

From confidential sources we have learned that the European Commission has taken the issue of whether the relevant "market" is the EU market versus the local market seriously by issuing warning letters to certain Member States.

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EU Member State

RoHS Domestic legislation

in force by Jul 1-

06 RoHS Violation Max

Penalty

RoHS Violation

Max prison

sentence EU Member State

RoHS Domestic legislation in force by

Jul 1-06 RoHS Violation Max

Penalty

RoHS Violation

Max prison

sentence

UK Unlimited Ireland Not specified

Austria € 7,270 Italy € 100,000

Belgium € 10,000,000 8 yrs Latvia Not specified

Cyprus $42,530 3 yrs Lithuania In

Progress 10,000 LTL

Czech € 35,000 Luxembourg € 125,000 ½ yr

Denmark Not specified 2 yrs Malta N/A Not specified

Estonia € 1,597,780 2 yrs Netherlands € 45,000 2 yrs

Finland € 850,000 Poland Not specified

France In

Progress € 7,500 Portugal € 44,800

Germany € 50,000 Slovakia Not specified

Greece Not available Slovenia € 83,529

Hungary $1,750 Spain € 1,200,000

Sweden Not specified 6yrs

RoHS readiness, max fine & prison sentence

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WEEE Directive

Waste Electrical & Electronic Equipment (WEEE)

EU directive effective 13th August 2005 – adopted as law in EU member states

Requires that the importer (producer) of the product “put on market” after 13 Aug 2005 registers for WEEE and provides for take-back and destruction at end of life

Producers are responsible (by individual financial guarantee) for financing waste management costs for “new” products “put on market”

Noncompliance with WEEE may result in penalties beginning from August, 2005

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WEEE registry, max- fine & prison sentence

EU Member State

Deadline for WEEE

registration

Fine for failing WEEE

registration

Prison sentence for failing WEEE

registration EU Member State

Deadline for WEEE

registration

Fine for failing WEEE

registration

Prison sentence for failing WEEE

registration

UK N/A N/A Ireland Jul 20, 2005 Forthcoming

Austria 1-m before

placing EEE € 2,910 Italy 90-d prior

placing EEE € 100,000

Belgium Aug 1, 2005 N/A Latvia 1-mo prior

placing EEE $603

Cyprus Oct 31, 2005 $42,530 3 yrs Lithuania Mar 31, 2006 5,000 LTL

Czech Oct 12, 2005 € 35,000 Luxembourg Apr 1, 2006 € 125,000 6 months

Denmark Jan 1, 2006 Forthcoming Malta N/A N/A

Estonia No registration

required Forthcoming Netherlands 13-wk prior placing EEE € 45,000 2 yrs

Finland May 15, 2005 Forthcoming Poland Oct 1, 2006 € 1,281

France Dec 1, 2006 € 2,250 Portugal Aug 13, 2005 Forthcoming

Germany Nov 23, 2005 € 50,000 Slovakia 1-mo prior to placing EEE $16,000

Greece N/A N/A Slovenia Dec 31, 2005 € 375,852

Hungary Dec 31, 2004 Forthcoming Spain Jan 31, 2006 Forthcoming

Sweden April 1, 06 N/A

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WEEE - Summary

Waste mgmt costs shared by all producers for “historical” products on the market

WEEE Registration laws require VIPs to register for WEEE, including a WEEE take-back program

Where VeriFone is registered as a legal company such as UK, France and Poland, VeriFone will be responsible for the WEEE take-back

Failure to register may result in (but not limited to) • Maximum fine• Prison sentence• Confiscation• Closure of premises• Revocation of trade licenses

Our legal consultants have advised us that the Scandinavian countries and especially The Netherlands are very stringent

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VeriFone’s Environmental Leadership

http://www.verifone.com/industry/environmental/index.html

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Current Activities

Part Numbers – Only RoHS product can be ordered after 1 July. Speak with your Sales Manager / Sales Support Consultant if you require help with RoHS part numbers.

Functional testing feedback

610 WiFi sleds, 610 terminals, 510 and 570 terminals due to be sent out around 25 May for functional testing

Send out information update• Updated position statement• Certification marketing / operations information sheet• Update RoHS product spares lists

Distribute WEEE letter for signature

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RoHS / WEEE Timeline

WEEE

Pre Aug 2005

Waste mgmt costs shared by all producers for “historical” products on the market

WEEE

Producer has responsibility to finance recycling of marked products

13 Aug 2005

WEEE

Collection, treatment and financial system must be in place

Sep 2005

RoHS

All products sold in EU must be RoHS compliant

1 July 2006

WEEE

1st collection and treatment targets attained

31 Dec 2006

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Closing

Laws are “self-policing” but if a product is challenged we must be able to show due diligence was followed in our processes

Failure to comply with RoHS and/or WEEE may result in significant penalties

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Questions

Thank you

Any Questions

Tim Bannontim_bannon@verifone.com