Espoo, Finland-headquartered Nokia is officially opposing Apple’s requirement for an emerging mobile industry standard basically calling for a miniaturized SIM module roughly a third smaller than the Micro SIM used with the iPhone 4/4S. A proposal put forth by Motorola, RIM and Nokia has some technical advantages over the Apple-backed nano SIM that requires a “drawer” to protect it.

As a result, cell phones would need to be re-engineered with this in mind. Nokia says its variant of the Nano SIM doesn’t require a tray and is even smaller than Apple’s. Both camps have tabled proposals to the European Telecommunications Standards Institute (ETSI). With 92 votes, Nokia is the largest ETSI voting body, so no wonder Apple has filed multiple membership applications in order to increase its voting power.

Nokia has explained its stance in a lengthy statement issued to The Verge just this morning…

Here’s Nokia’s statement to The Verge in its entirety, included here for the sake of discussion.

Apple’s proposal does not meet all of the pre-agreed requirements for ETSI’s planned 4FF standard (the so-called nano SIM). The proposal from Nokia, RIM and Motorola does.

Nokia believes that our proposal has features which would make it easier for consumers to insert and remove the SIM without damage. Additionally, our proposed SIM has different dimensions from a micro SIM, one of ETSI’s requirements, which would avoid it getting stuck if inserted by mistake into a phone with a micro SIM slot. Apple’s proposed card is the same length as the width of current micro SIMs and so would risk jamming, leading to card and product damage.

We also feel that our proposal allows for more design options for the type of card reader, i.e. how the SIM is inserted into the device, to allow for a wider range of device form factors. Requiring a tray or SIM carrier would reduce design options and increase manufacturing cost, perhaps not significant for high end smartphones but it would be for lower cost devices.

The combination of our proposed card and the associated mechanics are smaller than those for a current micro SIM, allowing further miniaturization in devices. Though Apple’s proposed card is smaller than current micro SIMs, when combined with the associated mechanics needed in the phone, we don’t believe it represents a significant reduction in size. We believe that in practice it would mean it was just different from micro SIM, rather than smaller, which could be a barrier to broad adoption as an alternative to micro SIM, potentially leading to fragmentation.

In summary, Nokia believes that our proposed nano SIM would be easier for consumers to handle, enable a wider range of device designs and offer a true difference from the existing options with micro SIM. We look forward to continuing the discussions in more detail with our counterparts in ETSI.

Apple thinks smaller is better so last summer the company submitted a new requirement to the European Telecoms Standards Body for a shrunk-down version of the already tiny Micro SIM card. Soon thereafter, AT&T followed suit. The smaller the SIM card, the more space there is for other components in ultra-thin mobile devices.

It’s widely accepted that Apple is pushing for its own Nano SIM variant as it contains technical advantages likely benefiting the design of an upcoming sixth-generation iPhone, rumored to be a major redesign.