EPEAT Program
Continuous Monitoring Outcomes Report
Imaging Equipment
IE-2022-03
May 30, 2023

1.0 Background
EPEAT® is a comprehensive voluntary sustainability Type 1 ecolabel that helps purchasers identify sustainable
technology products and services. Central to EPEAT are conformity assurance activities that meet the technicalrigor and credibility needs of the institutional purchasers who rely upon EPEAT. The EPEAT Program ensures
the ongoing conformance of EPEAT-registered products through an ongoing surveillance process known asContinuous Monitoring. Continuous Monitoring activities occur throughout the year and test the ability ofParticipating Manufacturers to prove conformance with EPEAT Criteria on an ongoing basis.
Some Continuous Monitoring activities require that Investigations be conducted in discrete timeframes called
Rounds. The EPEAT Program develops an individual plan for each Continuous Monitoring Round, which
specifies the EPEAT Criteria to be investigated, the method of investigation that GEC-approved Conformity
Assurance Bodies (CABs) must use and the specific dates when the Investigation activities must be completed.
The EPEAT Program also selects the Participating Manufacturers and EPEAT-registered products and assigns
Investigations to CABs, which must fully participate in and are responsible for implementing Continuous
Monitoring Round activities with their Participating Manufacturer clients. Participating Manufacturers are
required to cooperate fully with their GEC-approved CAB during Round activities.
To maintain the level of transparency relied on by purchasers, the EPEAT Program publishes an Outcomes
Report at the conclusion of each Round to summarize the activities conducted and to identify the products andParticipating Manufacturers that received nonconformances and the actions taken to restore accuracy of the
EPEAT Registry.
This document summarizes the activities and results of Continuous Monitoring Round IE-2022-03 conducted
for the Imaging Equipment category.

2.0 Overview of Continuous Monitoring Round IE-2022-03
2.1

Investigation Activities

As per the published Round Plan, Continuous Monitoring Round IE-2022-03 used Level 1 Investigations(documentation review activities to determine Participating Manufacturers’ conformance with specific EPEAT
Criteria). Participating Manufacturers had a discrete time period to provide their CABs with evidence
supporting conformance with the selected EPEAT Criteria. GEC-approved CABs reviewed the documentation,
made recommendations on conformity based solely on the evidence provided by Participating Manufacturers,
and sent Investigation Reports to the EPEAT Program. The EPEAT Program made the final decisions on
conformity for the Investigations.

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2.2

May 30, 2023

Criteria InvestigatedBoth the products and Criteria for investigation in Continuous Monitoring Round IE-2022-03 were selected
randomly using a random number generator. Each Participating Manufacturer was assigned two investigations,and any manufacturers who received a nonconformance in a 2021 Continuous Monitoring Round wereassigned one additional investigation.
Table 1: Criteria Investigated in Round IE-2022-03
Criteria Number

Criterion Title

4.1.2.1

Further reduction of the use of European Union RoHS Directive hazardous substances (cadmium)4.1.3.2

Use of non-mercury containing light sources

4.1.4.1

Reduction of substances on the European Union REACH Candidate List of SVHCs

4.1.6.1

Reducing BFR/CFR/PVC content of external plastic casings

4.1.7.1

Reduce fluorinated gas emissions resulting from flat panel display manufacturing

4.2.1.2

Declaration of postconsumer recycled plastic

4.2.1.3

Minimum 5% to 10% content of postconsumer recycled plastic

4.2.2.1

Declaration of renewable/biobased plastic materials content

4.2.3.1

Declaration of product weight

4.3.1.1

Ease of disassembly of product4.3.2.1

Use of single recyclable plastic type per plastic part4.3.2.2

Restriction on materials not compatible with reuse and recycling

4.3.2.3

4.3.4.2

Manual separation and marking of plastics
Notification regarding the identification of both materials and components that have hazardous
characteristics or special handling needs
Minimum reusable/recyclable rate based requirements of European WEEE Directive

4.4.2.1

Product Upgradeability

4.4.3.1

Spare Parts

4.5.2.1

Product specific greenhouse gas emissions - life cycle assessment

4.5.3.1

Standby power level ≤ 1 W and disclosure

4.5.3.2

Auto standby capability

4.6.1.1

Provision of product take-back service

4.6.1.2

Provision of product take-back service for broader scope of products

4.6.2.1

End of life processing requirements

4.7.2.1

Public disclosure of key environmental aspects

4.7.3.1

Product life cycle assessment and public disclosure of analyses

4.8.1.2

Elimination of elemental chlorine as a bleaching agent in packaging material

4.8.2.1

Separable packaging materials

4.8.2.2

Packaging 90% compostable/recyclable

4.8.2.3

Plastics marked in packaging materials

4.8.3.1

Recovered content in select fiber-based packaging materials

4.8.4.1

Provision of take-back service for packaging
Documentation that product does not prevent the use of Non-Manufacturer Cartridges and NonManufacturer Containers
Manufacturer recycles or reuses plastic material collected through its cartridge and container take-backprogram

4.3.3.1

4.9.2.1
4.9.3.3

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3.0 Summary of Investigations and Final Decisions on Conformity for IE-2022-03
Highlights from this Continuous Monitoring Round are:•42 investigations completed•

17 decisions of Conformance•

25 decisions of Nonconformance

Further details provided in Section 4. Of these 25
nonconformances, 24 were due to CAB failure to submit an
Investigation Report.

Figure 1: Final Conformity Decisions for IE-2022-03(shown as percentage of total investigations)

4.0 Further Details on Nonconformances for IE-2022-03
Table 2 below provides a further breakdown of the nonconformances by Criterion. All nonconformances must
be categorized as either a minor error, nonconformance, or nonconformance due to CAB inaction or delay not
attributable to the Participating Manufacturer.
Table 2: Breakdown of Nonconformances by Criterion for IE-2022-03
Criteria Number

Criterion Title

Total Nonconformances

4.1.2.1

Further reduction of the use of European Union RoHS Directive hazardous
substances (cadmium)Use of non-mercury containing light sources

1

1

4.1.6.1

Reduction of substances on the European Union REACH Candidate List of
SVHCs
Reducing BFR/CFR/PVC content of external plastic casings

4.2.1.2

Declaration of postconsumer recycled plastic1

4.2.1.3

Minimum 5% to 10% content of postconsumer recycled plastic

1

4.2.3.1

Declaration of product weight1

4.1.3.2
4.1.4.1

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Table 2: Breakdown of Nonconformances by Criterion for IE-2022-03
Criteria Number

Criterion Title

Total Nonconformances

4.3.2.1

Use of single recyclable plastic type per plastic part1

4.3.2.3

Manual separation and marking of plastics

3

4.3.3.1

1

4.5.2.1

Notification regarding the identification of both materials and componentsthat have hazardous characteristics or special handling needs
Product specific greenhouse gas emissions - life cycle assessment

4.5.3.1

Standby power level ≤ 1 W and disclosure2

4.6.2.1

End of life processing requirements

1

4.7.2.1

Public disclosure of key environmental aspects

2

4.7.3.1

Product life cycle assessment and public disclosure of analyses

1

4.8.1.2

Elimination of elemental chlorine as a bleaching agent in packaging material1

4.8.2.1

Separable packaging materials

1

4.8.2.3

Plastics marked in packaging materials

1

4.8.3.1

Recovered content in select fiber-based packaging materials

1

4.8.4.1

Provision of take-back service for packaging

1

4.9.3.3

Manufacturer recycles or reuses plastic material collected through its
cartridge and container take-back program1

1

Figure 2 provides a further breakdown by the underlying reason for the nonconformances.
Figure 2: Underlying Reason for Nonconformances in IE-2022-03(shown as a percentage of total nonconformances)

4.1

Minor Errors Versus Nonconformances

All nonconformances must be categorized as either a minor error, nonconformance, or nonconformance due
to CAB inaction or delay not attributable to the Participating Manufacturer. Minor errors are non-critical or
clerical in nature and do not materially affect the validity of conformance with EPEAT Criteria. Allnonconformances that do not meet the definition of minor errors are categorized as nonconformances (unlessthey are due to CAB inaction or delay).

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No minor errors were identified in IE-2022-03, and 24 of the 25 nonconformances were due to CAB inaction ordelay not attributable to the Participating Manufacturer.
4.2

Minor Errors

For Level 1 Investigations, nonconformances may be categorized as minor errors for the following reasons:•••Minor human error in data entry (e.g., value cited for EPEAT-product registration is insignificantly
above or below the actual value).
Minor administrative errors (e.g., broken URLs, reports/certificates marginally outdated).
No documentation provided by a Participating Manufacturer where the Participating Manufacturer
indicated the product has reached end-of-life and is no longer available on the market.

No minor errors were identified in Continuous Monitoring Round IE-2022-03.
4.3

Nonconformances

25 nonconformances were identified in Continuous Monitoring Round IE-2022-03, 24 of which were due to
CAB inaction or delay not attributable to the Participating Manufacturer. One nonconformance was due toinsufficient evidence being submitted to demonstrate conformance.

5.0 Actions to Restore Conformance
Where the final conformity decision is nonconformance (including minor errors and those due to CAB inaction
or delay), Participating Manufacturers must make corrections to restore the accuracy of the EPEAT Registryduring the Corrective Action Phase. These activities may include providing additional evidence to demonstrate
conformance with the criterion or unselecting the criteria in the EPEAT Registry. Where the product was foundnonconformant and is no longer available in the marketplace, the product must be archived.
During the Corrective Action Phase, Participating Manufacturers must also develop Corrective Action Plans forother EPEAT-registered products that may be affected by the same underlying issue causing thenonconformance but were not the subject of investigation (called “similarly affected products”).
The following actions were taken to restore accuracy to the EPEAT Registry as a result of Continuous
Monitoring Round IE-2022-03:•

3 investigations

Product archived by Participating Manufacturer•

22 investigations

CAB reviewed evidence originally submitted by Participating Manufacturers,
which demonstrated conformance

Table 3 in Section 7 identifies the Participating Manufacturers and products that received nonconformances inContinuous Monitoring Round IE-2022-03.

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6.0 Key Findings
6.1

Evidence of all Elements of a Conformance Assurance System

Participating Manufacturers are reminded to review all requirements of a conformance assurance system,
including the requirements identified in Conformity Guidance Materials, and ensure all elements are
addressed.
6.2

Required Criterion 4.8.3.1 – Recovered Content in Select Fiber-Based Packaging Materials

This Criterion requires the EPEAT manufacturer to provide their own environmental packaging requirement. In
this packaging requirement, the manufacturer must state a preference for the use of postconsumer content in
the packaging they obtain. This must specifically identify post-consumer. A supplier letter, or the suppliers
packaging specification are not sufficient to address this requirement.

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7.0 Identification of Nonconformances and Corrections Made by Participating Manufacturers
In the interest of transparency, the EPEAT Program identifies the Participating Manufacturers and products that received nonconformances and the actions taken to restore accuracy of the EPEAT Registry.
Minor errors are generally clerical in nature and do not materially affect the validity of products in the EPEAT Registry. As such, these are not identified in the table below.

Table 3: Summary of Nonconformances and Corrections Made by Participating Manufacturers
Participating
Manufacturer

Product

Product TypeCountry

Criterion
NumberToshibaeStudio 389CS

United States

4.8.3.1

Brother

Brother MFC-J6530DW

United States

4.6.2.1

Brother

HL-L6400DWXMultifunction
DeviceMultifunction
DevicePrinter

United States

Canon

Canon imagePROGRAF
TX-3000

Printer

Canon

Canon

imageRUNNERADVANCE DX 4725i
DADF
PlotWave 3000

Epson

Criterion Title

Required or
Optional

Underlying Reason for Nonconformance

Corrective Action Taken

Insufficient evidence to demonstrate
conformance.
CAB inaction or delay not attributable to theParticipating Manufacturer
CAB inaction or delay not attributable to theParticipating Manufacturer

Participating Manufacturer archived the product.

Recovered content in select fiberbased packaging materials
End of life processing requirements

Required

4.1.6.1

Reducing BFR/CFR/PVC content of
external plastic casings

RequiredUnited States

4.7.3.1

Product life cycle assessment andpublic disclosure of analyses

Optional

CAB inaction or delay not attributable to theParticipating Manufacturer

Multifunction
DeviceUnited States

4.5.3.1

Standby power level ≤ 1 W anddisclosure

Required

CAB inaction or delay not attributable to theParticipating Manufacturer

Printer

United States

4.3.2.3

RequiredDS-770

Scanner

United States

4.8.1.2

Manual separation and marking ofplastics
Elimination of elemental chlorine as a
bleaching agent in packaging material

CAB inaction or delay not attributable to theParticipating Manufacturer
CAB inaction or delay not attributable to theParticipating Manufacturer

Epson

Epson DS-6500

Scanner

United States

4.8.2.3

Plastics marked in packaging materials

Required

CAB inaction or delay not attributable to theParticipating Manufacturer

Epson

ES-865

Scanner

United States

4.7.2.1

Public disclosure of key environmental
aspects

Required

CAB inaction or delay not attributable to theParticipating Manufacturer

Fujitsu
LimitedFujitsu fi-7160

Scanner

United States

4.1.4.1

Optional

CAB inaction or delay not attributable to theParticipating Manufacturer

Fujitsu
LimitedFujitsu N7100A

Scanner

United States

4.3.2.3

Reduction of substances on theEuropean Union REACH Candidate Listof SVHCs
Manual separation and marking ofplastics

Required

CAB inaction or delay not attributable to theParticipating Manufacturer

Global Electronics Council

Required

Required

Outcomes Report – Level 1 Investigations (P41B Issue2 Rev2)

Participating Manufacturer archived the product.
CAB reviewed evidence originally submitted byParticipating Manufacturers, which demonstrated
conformance
CAB reviewed evidence originally submitted byParticipating Manufacturers, which demonstrated
conformance
CAB reviewed evidence originally submitted byParticipating Manufacturers, which demonstrated
conformance
Participating Manufacturer archived the product.
CAB reviewed evidence originally submitted byParticipating Manufacturers, which demonstrated
conformance
CAB reviewed evidence originally submitted byParticipating Manufacturers, which demonstrated
conformance
CAB reviewed evidence originally submitted byParticipating Manufacturers, which demonstrated
conformance
CAB reviewed evidence originally submitted byParticipating Manufacturers, which demonstrated
conformance
CAB reviewed evidence originally submitted byParticipating Manufacturers, which demonstrated
conformance

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IE-2022-03 Outcomes ReportHP

May 30, 2023

HP Color LaserJet Pro
MFP M283fdn,
M283fdw, M283cdw
HP ENVY Inspire 7900e
seriesPrinter

Australia

4.2.1.2

Declaration of postconsumer recycledplastic

Required

CAB inaction or delay not attributable to theParticipating Manufacturer

Printer

United States

4.8.4.1

Provision of take-back service for
packaging

Optional

CAB inaction or delay not attributable to theParticipating Manufacturer

HP

HP LaserJet Managed
E60055dn (M0P33A)

PrinterIndia

4.5.3.1

Standby power level ≤ 1 W anddisclosure

Required

CAB inaction or delay not attributable to theParticipating Manufacturer

KonicaMinoltaAccurioPress C7090

Multifunction
DeviceAustralia

4.1.3.2

Use of non-mercury containing lightsources

Optional

CAB inaction or delay not attributable to theParticipating Manufacturer

KonicaMinolta

Konica Minolta Accurio
Press C3070

Multifunction
DeviceUnited States

4.5.2.1

Product specific greenhouse gas
emissions - life cycle assessment

Optional

CAB inaction or delay not attributable to theParticipating Manufacturer

KonicaMinolta

Konica Minolta bizhub
C759

Multifunction
DeviceUnited States

4.9.3.3

Optional

CAB inaction or delay not attributable to theParticipating Manufacturer

Kyocera

KYOCERA TASKalfa
6004i

Multifunction
DeviceUnited States

4.2.1.3

Manufacturer recycles or reuses plastic
material collected through its cartridgeand container take-back program
Minimum 5% to 10% content of
postconsumer recycled plastic

Optional

CAB inaction or delay not attributable to theParticipating Manufacturer

Kyocera

KYOCERA TASKalfa Pro
15000cUnited States

4.3.2.1

Use of single recyclable plastic type perplastic part

Required

CAB inaction or delay not attributable to theParticipating Manufacturer

Ricoh

LANIER IM 7000

Professional
Imaging
Product
Multifunction
DeviceUnited States

4.1.2.1

Optional

CAB inaction or delay not attributable to theParticipating Manufacturer

Ricoh

LANIER PRO 8320

Printer

United States

4.3.2.3

Further reduction of the use ofEuropean Union RoHS Directive
hazardous substances (cadmium)
Manual separation and marking ofplastics

Required

CAB inaction or delay not attributable to theParticipating Manufacturer

Ricoh

RICOH MP 2555SPG

Multifunction
DeviceUnited States

4.8.2.1

Separable packaging materials

Required

CAB inaction or delay not attributable to theParticipating Manufacturer

Sharp

SHARP MX-4051

Multifunction
DeviceUnited States

4.7.2.1

Public disclosure of key environmental
aspects

Required

CAB inaction or delay not attributable to theParticipating Manufacturer

Sharp

SHARP MX-C357F

Multifunction
DeviceUnited States

4.2.3.1

Declaration of product weight

Required

CAB inaction or delay not attributable to theParticipating Manufacturer

Sharp

SHARP MX-M4071S

Multifunction
DeviceUnited States

4.3.3.1

Notification regarding the identificationof both materials and components thathave hazardous characteristics or
special handling needs

Required

CAB inaction or delay not attributable to theParticipating Manufacturer

HP

Global Electronics Council

Outcomes Report – Level 1 Investigations (P41B Issue2 Rev2)

CAB reviewed evidence originally submitted byParticipating Manufacturers, which demonstrated
conformance
CAB reviewed evidence originally submitted byParticipating Manufacturers, which demonstrated
conformance
CAB reviewed evidence originally submitted byParticipating Manufacturers, which demonstrated
conformance
CAB reviewed evidence originally submitted byParticipating Manufacturers, which demonstrated
conformance
CAB reviewed evidence originally submitted byParticipating Manufacturers, which demonstrated
conformance
CAB reviewed evidence originally submitted byParticipating Manufacturers, which demonstrated
conformance
CAB reviewed evidence originally submitted byParticipating Manufacturers, which demonstrated
conformance
CAB reviewed evidence originally submitted byParticipating Manufacturers, which demonstrated
conformance
CAB reviewed evidence originally submitted byParticipating Manufacturers, which demonstrated
conformance
CAB reviewed evidence originally submitted byParticipating Manufacturers, which demonstrated
conformance
CAB reviewed evidence originally submitted byParticipating Manufacturers, which demonstrated
conformance
CAB reviewed evidence originally submitted byParticipating Manufacturers, which demonstrated
conformance
CAB reviewed evidence originally submitted byParticipating Manufacturers, which demonstrated
conformance
CAB reviewed evidence originally submitted byParticipating Manufacturers, which demonstrated
conformance

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Document Control and Change History
Issue
1

Revision0

Owner
EPEAT Conformity
Assurance Manager
EPEAT Conformity
Assurance Manager
Senior Manager,
Ecolabels andResources

1

1

2

0

2

1

Senior Manager,
Ecolabels andResources2

2

Senior Manager,
Ecolabels andResources

Global Electronics Council

ApproverDirector, EPEAT
ProgramDirector, EPEAT
Program
Senior Director,
Ecolabels andManufacturer
Resources
Vice President,
Ecolabels andManufacturer
Resources
Vice President,
Ecolabels andManufacturer
Resources

Description
Initial release

Approval Date

Effective Date2018 Dec 112018 Dec 11

Reformatting of document. Addition ofstandardized text.

2021 Mar 25

2021 Mar 30

Updated terminology fornonconformances to include“nonconformances” and “minor errors”,
in alignment with revisions to P66.
Updated to reflect new nonconformance
category for CAB inaction or delay

2022 Sep 152022 Sep 30

2023 Mar 92023 Mar 13

Outcomes Report – Level 1 Investigations (P41B Issue2 Rev2)

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