EPEAT Program
Continuous Monitoring Outcomes Report
Computers and Displays
CD-2020-02
July 8, 2021

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 major nonconformances and the actions taken to restore accuracyof the EPEAT Registry.
This document summarizes the activities and results of Continuous Monitoring Round CD-2020-02 conducted
for the Computers and Displays category.

2.0 Overview of Continuous Monitoring Round CD-2020-02
2.1

Investigation Activities

As per the published Round Plan, Continuous Monitoring Round CD-2020-02 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

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Criteria InvestigatedCriteria were selected for Continuous Monitoring Round CD-2020-02 based on the positive sustainability
impact the Criteria will have when adopted, and the potential to drive change in the sector. Each Participating
Manufacturer selecting the Criteria was assigned investigations and products were chosen randomly. Any
Participating Manufacturer that received a Major Nonconformance during 2019 Continuous Monitoring
activities in the Imaging Equipment category received an additional Investigation in this Round.
Table 1: Criteria Investigated in Round CD-2020-02
Criteria Number

Criterion Title
Minimum post-consumer recycled plastic, ITE-derived post-consumer recycled plastic or bio-based plastic
content
Socially responsible supplier manufacturing: Labor

4.2.1.1
4.10.1.1

3.0 Summary of Investigations and Final Decisions on Conformity for CD-2020-02
Highlights from this Continuous Monitoring Round are:•61 investigations completed•

42 decisions of Conformance•

19 decisions of Nonconformance

Further details provided in Section 4•

3 investigations cancelled

Cancelled due to administrative issue.

Figure 1: Final Conformity Decisions for CD-2020-02(shown as percentage of total investigations)Global Electronics Council

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4.0 Further Details on Nonconformances for CD-2020-02
Figure 2 below provides a further breakdown of the nonconformances by Criterion.
Figure 2: Breakdown of Nonconformances by Criterion for CD-2020-02(shown as a percentage of total nonconformances)

Figure 3 provides a further breakdown by the underlying reason for the nonconformances.

Figure 3: Underlying Reason for Nonconformances in CD-2020-02(shown as a percentage of total nonconformances)

4.1

Major Versus Minor Nonconformances

All nonconformances must be categorized as either major or minor. Minor nonconformances are non-criticalor clerical in nature and do not materially affect the validity of conformance with EPEAT Criteria. Allnonconformances that do not meet the definition of minor are categorized as major.

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Figure 4: Major versus Minor Nonconformances for CD-2020-02(shown as a percentage of total nonconformances)

4.2

Minor Nonconformances

For Level 1 Investigations, nonconformances may be categorized as minor 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.

Table 2 provides a breakdown of the minor nonconformances found in Round CD-2020-02.
Table 2: Reasons for Minor Nonconformances for CD-2020-02

4.3

Criteria
Number
4.2.1.1

Number of Minor
Nonconformances3

4.10.1.10

Reason for Nonconformances
All 3 minor nonconformances were due to a demonstrated nonconformance
N/A

Major Nonconformances

Major nonconformances may be found due to a demonstrated nonconformance, insufficient evidence
provided to demonstrate conformance, or because no documentation was provided. Major nonconformanceswere found for both Criteria investigated in this Round.
Criterion 4.2.1.1 requires the product to contain a minimum of 2% of any combination of postconsumer
recycled plastic, ITE-derived post-consumer recycled plastic, or bio-based plastic, measured as a percentage of
total amount of plastic (by weight) in the product. The verification requirements specifically require supplierletter(s) and a list of parts excluded from the calculation and the reason for their exclusion to support thecalculation of content in the product.
There were eight major nonconformances for Criterion 4.2.1.1. Five of these nonconformances were because a
supplier letter was not provided to support the content calculation and one nonconformance was because the

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supplier letter did not confirm post-consumer recycled content in the plastic. One nonconformance was due toevidence not provided to support a N/A selection for 4.2.1.1 on the EPEAT Registry. For one investigation, theCAB could not link the evidence to the EPEAT-registered product. Lastly, three investigations were
nonconformant because evidence did not support a minimum of 2% postconsumer recycled plastic, ITEderived post-consumer recycled plastic, or bio-based plastic content in the product.
Criterion 4.10.1.1 has multiple criterion elements that must be met to demonstrate conformance. The criterion
requires Participating Manufacturers to have publicly available supplier requirements that include all labor
provisions identified in the criterion. These requirements must be incorporated into agreements with directly
contracted suppliers and require those suppliers to apply the labor provisions to their own directly contracted
suppliers. The Participating Manufacturer must conduct a prioritization assessment to determine which
supplier facilities are in scope. The prioritization assessment must be conducted annually using one of themethods identified in the criterion and assess a minimum percentage of directly contracted suppliers (either
80% or 95% for 1 or 2 optional points, respectively). In addition, all manufacturer-owned or -leased facilities
that produce and assemble the products and the materials, components and parts contained in the products
declared to conform to EPEAT Computers and Displays are in scope. All facilities in scope must then be RBA
VAP recognized or included in an audit program that meets all criterion requirements (audited a minimum of
every two years by qualified auditors). Lastly, the Participating Manufacturer must make an annual public
disclosure of a summary of the audit results including information on nonconformities, repeat nonconformities
and corrective actions by labor provision and geographic area.
There were 5 major nonconformances for Criterion 4.10.1.1. One nonconformance was due to no evidence
being provided. The remainder of nonconformances were due to various elements of the criterion not being
addressed. One nonconformance was due to insufficient evidence demonstrating the supplier audit program
required audits to be conducted a minimum of every two years. One nonconformance was because supplierrequirements were not incorporated into agreements with all directly contracted suppliers and because it was
not clear which prioritization method was used. Two nonconformances were due to a number of criterion
elements not being addressed, including not ensuring supplier requirements addressed the supplier’s next-tiersuppliers, not providing the prioritization assessment, not ensuring qualifications of auditors and topics
audited in the supplier audit program and inadequate disclosure of audit results.
For Criterion 4.10.1.1, the EPEAT Program understands that RBA has identified the ongoing COVID-19
pandemic as an issue for scheduling audits and this may have caused some assessments to be postponed. RBA
has indicated that the expiration date on a current VAP or SVAP is still valid, but are offering flexibility if a
facility needs to reschedule.
Figure 5 provides a breakdown of the major nonconformances found in Round CD-2020-02.

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Figure 5: Reasons for Major Nonconformances for CD-2020-02 By Criterion

5.0 Actions to Restore Conformance
Where the final conformity decision is nonconformance (whether major or minor), Participating Manufacturers
must make corrections to restore the accuracy of the EPEAT Registry during 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 found nonconformant 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 CD-2020-02:•

14 investigations

Additional data provided by Participating Manufacturers, bringing the products
into conformance with the Criterion•

2 investigations

Participating Manufacturer exited the EPEAT Program•

1 investigation

Product archived by Participating Manufacturer•

2 investigations

Products archived by the CAB or by the EPEAT Program

Table 3 in Section 7 identifies the Participating Manufacturers and products that received major
nonconformances in Continuous Monitoring Round CD-2020-02.

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6.0 Key Findings
6.1

Providing Necessary Evidence to Support Calculation for Criterion 4.2.1.1

The calculation of postconsumer recycled plastic, ITE-derived post-consumer recycled plastic, or bio-based
plastic content, supplier letters to support this calculation and a list of parts excluded from the calculationmust all be provided.
The Participating Manufacturer must identify all excluded parts and their reason for exclusion based on thelisted acceptable exclusions in the criterion text. The intent is to have all plastics accounted for either in thecalculation of recycled content or in the exemptions list. All Investigation Reports should include verification
requirement c) and clearly identify what evidence was provided. During this Round, the EPEAT Program foundthat some Participating Manufacturers forgot to include all exempted parts in the list provided and although
this evidence was accepted for this Round, incomplete lists may result in a nonconformance in the future.
The EPEAT Program also identified a training opportunity to train CABs and Participating Manufacturers on
how to incorporate fillers into EPEAT’s Annex 1 template for calculating recycled or bio-based content.
6.2

Conformity Against All Elements of Criterion 4.10.1.1

Manufacturers are reminded to review all criterion elements for Criterion 4.10.1.1. Participating
Manufacturers are reminded to ensure that they have all of the following:
•

•

•
•

Publicly available supplier requirements that include all labor provisions identified in the criterion, areincorporated into agreements with directly contracted suppliers and require those suppliers to apply
the labor provisions to their own directly contracted suppliers.
Annual prioritization assessment to determine which supplier facilities are in scope. The prioritizationassessment must be conducted using one of the methods identified in the criterion and assess aminimum percentage of directly contracted suppliers (either 80% or 95% for 1 or 2 optional points
respectively).
Evidence that all manufacturer and supplier facilities in scope are RBA VAP recognized or included in
an audit program that meets all criterion requirements.
Annual public disclosure of a summary of the audit results which includes all information identified in
the criterion.

Participating Manufacturers are encouraged to work with their CABs if they have questions.

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7.0 Identification of Major Nonconformances and Corrections Made by Participating Manufacturers
In the interest of transparency, the EPEAT Program identifies the Participating Manufacturers and products that received major nonconformances and the actions taken to restore accuracy of the EPEAT
Registry. Minor nonconformances 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 Major Nonconformances and Corrections Made by Participating Manufacturers
Participating
Manufacturer

Product

Product TypeCountry

Criterion
NumberCriterion Title

Required or
Optional

ASUSTeK
Computer Inc.

N/A: Corporate
Criterion

N/A: Corporate
Criterion

N/A: Corporate
Criterion

4.10.1.1

Socially responsible supplier manufacturing: LaborASUSTeK
Computer Inc.

VP348QGL

MonitorPortugal

4.2.1.1

BenQ

BL2381T, BL2381TE(BL2381T-T)

MonitorUnited States

4.2.1.1

BenQ

PD2700U, PD2700UE(PD2700U-B)

MonitorUnited States

4.2.1.1

Ciara Tech

Horizon 8275-A

Desktop

Canada4.2.1.1

Comercializadora
Milenio S.A. de
C.V.
LenovoMitsui MLT003

Notebook

Mexico4.2.1.1

ThinkPad T15p Gen 1

Notebook

Canada4.2.1.1

Microsoft

N/A: Corporate
Criterion

N/A: Corporate
Criterion

N/A: Corporate
Criterion

4.10.1.1

Positivo
Tecnologia S.A.

MASTER N2140

Notebook

Brazil

4.2.1.1

Samsung

Samsung QM43R

Signage Display

Sweden4.2.1.1

Global Electronics Council

Underlying Reason for Nonconformance

Corrective Action Taken

Optional

Insufficient evidence to demonstrate
conformance

Minimum post-consumer recycled plastic, ITEderived post-consumer recycled plastic or biobased plastic content
Minimum post-consumer recycled plastic, ITEderived post-consumer recycled plastic or biobased plastic content
Minimum post-consumer recycled plastic, ITEderived post-consumer recycled plastic or biobased plastic content
Minimum post-consumer recycled plastic, ITEderived post-consumer recycled plastic or biobased plastic content
Minimum post-consumer recycled plastic, ITEderived post-consumer recycled plastic or biobased plastic content
Minimum post-consumer recycled plastic, ITEderived post-consumer recycled plastic or biobased plastic content
Socially responsible supplier manufacturing: Labor

RequiredInsufficient evidence to demonstrate
conformance

RequiredInsufficient evidence to demonstrate
conformance

RequiredInsufficient evidence to demonstrate
conformance

Required

Demonstrated nonconformance

RequiredInsufficient evidence to demonstrate
conformance

Required

Demonstrated nonconformance

Optional

Insufficient evidence to demonstrate
conformance

Minimum post-consumer recycled plastic, ITEderived post-consumer recycled plastic or biobased plastic content
Minimum post-consumer recycled plastic, ITEderived post-consumer recycled plastic or biobased plastic content

RequiredInsufficient evidence to demonstrate
conformance

RequiredInsufficient evidence to demonstrate
conformance

Participating Manufacturer provided
additional evidence demonstrating
conformance.
Participating Manufacturer provided
additional evidence demonstrating
conformance.
Participating Manufacturer provided
additional evidence demonstrating
conformance.
Participating Manufacturer provided
additional evidence demonstrating
conformance.
Participating Manufacturer provided
additional evidence demonstrating
conformance.
Manufacturer exited the EPEAT
Program and the products werearchived.
Participating Manufacturer provided
additional evidence demonstrating
conformance.
Participating Manufacturer provided
additional evidence demonstrating
conformance.
Participating Manufacturer provided
additional evidence demonstrating
conformance.
Participating Manufacturer provided
additional evidence demonstrating
conformance.

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

Criterion
NumberCriterion Title

Required or
Optional

Underlying Reason for Nonconformance

Corrective Action Taken

N/A: Corporate
Criterion

4.10.1.1

Socially responsible supplier manufacturing: Labor

Optional

Demonstrated nonconformance

N/A: Corporate
Criterion
Desktop

N/A: Corporate
Criterion
Spain

4.10.1.1

Socially responsible supplier manufacturing: Labor

Optional

4.2.1.1

Required

N/A: Corporate
Criterion

N/A: Corporate
Criterion

N/A: Corporate
Criterion

4.10.1.1

Minimum post-consumer recycled plastic, ITEderived post-consumer recycled plastic or biobased plastic content
Socially responsible supplier manufacturing: Labor

Insufficient evidence to demonstrate
conformance
Demonstrated nonconformance

Participating Manufacturer provided
additional evidence demonstrating
conformance.
Product archived by CAB.

Optional

Insufficient evidence to demonstrate
conformance

ViewSonic

ViewSonic / VS16453/ TD2230

MonitorCanada4.2.1.1

RequiredInsufficient evidence to demonstrate
conformance

Zebra
Technologies

Zebra L10 Rugged
Tablets (XPAD,XSLATE, XBOOK)

Tablet / Slate

United States

4.2.1.1

Minimum post-consumer recycled plastic, ITEderived post-consumer recycled plastic or biobased plastic content
Minimum post-consumer recycled plastic, ITEderived post-consumer recycled plastic or biobased plastic content

RequiredInsufficient evidence to demonstrate
conformance

Product

Product TypeCountry

Teknoservice S.L.

N/A: Corporate
Criterion

N/A: Corporate
Criterion

TICNOVA QUALITYTEAM
TICNOVA QUALITY
TEAM

N/A: Corporate
Criterion
Ticnova DLC E70 SFF

ViewSonic

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Product archived by CAB.

Participating Manufacturer provided
additional evidence demonstrating
conformance.
Participating Manufacturer provided
additional evidence demonstrating
conformance.
Participating Manufacturer provided
additional evidence demonstrating
conformance.

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Document Control and Change History
Issue
1

Revision
0

1

1

2

0

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

Global Electronics Council

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

Description
Initial release

Reformatting of document. Addition ofstandardized text.

Outcomes Report – Level 1 Investigations (P41B Issue2 Rev0)

Approval Date

Effective Date2018 Dec 112018 Dec 112021 Mar 25

2021 Mar 30

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