EPEAT® Implementation Plan:
Criteria for the Assessment of Ultra-Low Carbon Solar Modules
Introduction
The Global Electronics Council® (GEC) is a non-profit that stimulates the market for sustainable electronic
products and services. By deciding to prioritize the purchase of sustainable technology, institutional purchasers
help “move the needle” toward a more sustainable world. GEC also enables manufacturers to demonstrate theirefforts to address the sustainability impacts of their technology and act to evolve operational, supply chain, andprocurement priorities.
GEC is the steward of the EPEAT® ecolabel, which is used by more purchasers of electronics than any otherecolabel worldwide. EPEAT establishes criteria that address priority sustainability impacts throughout the life
cycle of electronics products, based on an evaluation of scientific evidence and international best practices.
While EPEAT Criteria are reviewed on a regular cadence to ensure they remain relevant, continue to be
impactful and incentivize leadership performance, GEC may also add new impactful criteria that are time
sensitive and address an emerging critical issue or tackle a complex topic.
In this regard, in March 2023, GEC published Criteria for Assessment of Ultra-Low Carbon Solar Modules tosupplement the existing EPEAT Criteria for the solar modules and inverters category as specified in Sustainability
Leadership Standard for Photovoltaic Modules and Photovoltaic Inverters (NSF/ANSI 457). These additional
criteria were developed based on the principle that the manufacture and procurement of low-embodied carbon
photovoltaic modules are critical for achieving net-zero emissions.
When criteria are revised or new impactful criteria added to an existing product category, EPEAT publishes aplan for implementation and the deadline for when Participating Manufacturers must come into conformancewith the revisions or new criteria.
This document contains background information and the implementation plan for Criteria for Assessment ofUltra-Low Carbon Solar Modules, including the timeframe for when solar modules already appearing in theEPEAT Registry must meet these criteria and other supporting activities for an efficient and effective transition.
The information in this document applies to all Participating Manufacturers with solar modules currently
appearing in the EPEAT Registry, potential applicant Participating Manufacturers, and all GEC-approved
Conformity Assurance Bodies. It may also be of interest to purchasers, policy makers, investors and otherstakeholders interested in the implementation of the Criteria for Assessment of Ultra-Low Carbon SolarModules.
For questions about this implementation plan, please contact us at EPEAT@GEC.org.

EPEAT Implementation Plan for ULCS Modules Criteria
Published April 23, 2024
Global Electronics Council©2024 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 1 of 6

Background
GEC Criteria Development and Revision Process
EPEAT Criteria address priority impacts throughout the life cycle of the product, based on an evaluation ofscientific research and data and international best practices. GEC’s multi-step development process includes:•Publication of State of Sustainability Research to identify science-based social and environmental
impacts across the life cycle of technology products and services, and strategies to reduce the identified
sustainability impacts. The data and analyses in State of Sustainability Research serves as the scientificbasis for the development of criteria.

•Criteria development in a balanced, voluntary consensus process that aligns with and draws from thecharacteristics of voluntary consensus defined in ISO 14024 Environmental labels and declarations –Type 1 environmental labelling – Principles and procedures, and the U.S. Federal Government’s
description of a voluntary consensus process1.

EPEAT Criteria evolve as our understanding of sustainability issues and impacts evolve. GEC reviews criteria toensure they remain relevant, continue to be impactful and incentivize leadership performance. The review
cadence – approximately every three years from the last publication – is intended to adjust criteria in a timely
manner and with the evolution of science and best practices, while providing the market sufficient time foradoption.
Within the regular review cadence, GEC may choose to initiate a limited revision to incorporate impactful new
criteria that are time sensitive and address an emerging critical issue or tackle a complex topic that would
benefit from a focused criteria development process. Limited revisions follow the same development process as
described above.
Further details on GEC’s criteria development and revision process are publicly available.
Limited Revision: New Embodied Carbon Criteria for Photovoltaic Modules
In March 2023, GEC published Criteria for Assessment of Ultra-Low Carbon Solar Modules to supplement theexisting criteria for the solar modules and inverters category as specified in Sustainability Leadership Standard
for Photovoltaic Modules and Photovoltaic Inverters (NSF/ANSI 457).
Criteria for Assessment of Ultra-Low Carbon Solar Modules were developed based on the principle that themanufacture and procurement of low-embodied carbon solar modules are critical for achieving net-zeroemissions. These criteria establish a framework, standardized methodology, and performance objectives toincentivize manufacturers and suppliers to design and manufacture low embodied carbon solar modules. Forpurchasers, these criteria provide a consensus-based definition of low-embodied carbon to aid in identifying andprocuring low embodied carbon solar modules.
1U.S. Executive Office of the President, Office of Management and Budget, OMB Circular A-119: Federal Participation in the Development
and Use of Voluntary Consensus Standards and in Conformity Assessment Activities

EPEAT Implementation Plan for ULCS Modules Criteria
Published April 23, 2024
Global Electronics Council©2024 Green Electronics Council dba Global Electronics Council. All rights reserved.

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Criteria for Assessment of Ultra-Low Carbon Solar Modules includes three criteria for photovoltaic modules:•Criterion 4.1 – Low Carbon Solar (required): Embodied carbon of the solar module shall be equal to orless than 630 kg CO2e per kWp;

•Criterion 4.2 – Ultra-Low Carbon Solar (optional): Embodied carbon of the solar module shall be equal toor less than 400 kg CO2e per kWp; and•Criterion 4.3 – Publicly Available LCI Data (optional): Primary life cycle inventory data underlying
alternative global warming potential coefficients shall be publicly available.

Upon implementation, these three criteria will be in addition to the existing EPEAT Criteria for the solar modules
and inverters category specified in NSF/ANSI 457. The existing criteria address management of substances,preferable materials use, life cycle assessment, energy efficiency and water use, end-of-life management,
packaging, and corporate responsibility.
Development of Implementation Plan
When exisiting criteria are revised or new impactful criteria added to an existing product category, EPEAT
publishes a plan for implementation including the deadline for when Participating Manufacturers must comeinto conformance with the revisions or new criteria.
To develop the implementation plan for Criteria for Assessment of UltraLow Carbon Solar Modules, GEC undertook stakeholder consultation onoptions for the implementation schedule. This included outreach toParticipating Manufacturers, GEC-approved Conformity Assurance
Bodies (CABs), purchasers, policy makers, and other EPEAT
stakeholders.

Overarching Principles
based on ISO 14024:
Credibility
Consistency
Objectivity

In addition to stakeholder feedback, GEC used overarching principles toguide development of the implementation plan for Criteria for
Assessment of Ultra-Low Carbon Solar Modules. This ensured options
were examined in a balanced manner that also aligned with theresponsibilities and requirements of EPEAT as a Type 1 ecolabel inaccordance with ISO 14024 Environmental labels and declarations –Type 1 environmental labelling – Principles and procedures.

Transparency
Leadership

To this end, GEC’s decisions were guided by a commitment to being fair, objective, and transparent. The
resulting implementation plan, as contained in this document, balances the competing needs of various
stakeholders, and ensures consistency and objectivity in the associated conformity assurance activities.
Further information on the conformity assurance process for the solar modules and inverters category, including
specific details for Criteria for Assessment of Ultra-Low Carbon Solar Modules, can be found on the EPEATRegistry.

EPEAT Implementation Plan for ULCS Modules Criteria
Published April 23, 2024
Global Electronics Council©2024 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 3 of 6

Implementation PlanImplementation Schedule
Key dates for implementation of the Criteria for the Assessment of Ultra-Low Carbon Solar Modules areidentified below.
2024
JunJulPublic Launch
ULCS Modules Criteria
in EPEAT Registry(1)

June 4, 2024

2025
Aug

Sep

Oct

Nov

Dec

Public EPEAT Registry will show solar modules(2)

Janmeeting NSF 457 Criteria and ULCS Modules Criteria.

New solar modules must meet NSF 457 and, at minimum, the required low carbon solar criterion.
Solar modules meeting optional ultra-low carbon solar criterion are designated as EPEAT Climate+.

Period in which solar modules already in the EPEAT Registry must come intoconformance with, at minimum, the required low carbon solar criterion.
June 4 – December 31, 2024

All solar modules must meet NSF 457 and,at minimum, the required low carbon solar
criterion to appear in EPEAT Registry.
January 1, 2025(3)(1)

The term “ULCS Modules Criteria” refers to Criteria for the Assessment of Ultra-Low Carbon Solar Modules and includes the three criteria
related to embodied carbon for solar modules: required criterion for low carbon solar modules (threshold of 630 kg CO2e / kWp), optional
criterion for ultra-low carbon solar modules (400 kg CO2e / kWp), and optional criterion for making LCI data publicly available.

(2)

This table only refers to solar modules because the ULCS Modules Criteria only apply to modules and not inverters. Inverters are stillrequired to only meet the NSF 457 Criteria to appear in the EPEAT Registry.

(3)

On January 1, 2025, solar modules not meeting the required low carbon solar criterion will be archived from the EPEAT Registry.

On June 4, 2024, Criteria for the Assessment of Ultra-Low Carbon Solar Modules (referred to in the table
above as ULCS Modules Criteria) will launch on the public facing EPEAT Registry. As of this date:•Solar modules meeting both the existing NSF 457 Criteria, and, at minimum, the required low carbon
solar module criterion (with a threshold of 630 kg CO2e per kWp) will appear on the public facing
EPEAT Registry and be visible to stakeholders.

•Solar modules meeting both the existing NSF 457 Criteria and the optional ultra-low carbon solar
module criterion (with a threshold of 400 kg CO2e per kWp) will be designated as EPEAT Climate+
and the companies identified as EPEAT Climate+ Champions on the EPEAT Registry.

•New solar modules that will appear in the EPEAT Registry starting on June 4, 2024 must meet boththe existing NSF 457 Criteria and, at minimum, the required low carbon solar criterion.

EPEAT Implementation Plan for ULCS Modules Criteria
Published April 23, 2024
Global Electronics Council©2024 Green Electronics Council dba Global Electronics Council. All rights reserved.

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Between June 4, 2024 and December 31, 2024:•Solar modules that appeared in the EPEAT Registry prior to June 4, 2024 have approximately sevenmonths to come into conformance with, at minimum, the required low carbon solar module
criterion. The deadline for coming into conformance is January 1, 2025.

•The public-facing Registry will identify which solar modules meet only the NSF 457 Criteria and whichsolar modules meet both the NSF 457 Criteria and, at minimum, the required low carbon solar
module criterion.

On January 1, 2025:•Solar modules meeting only the NSF 457 Criteria and not, at minimum, the required low carbon solar
module criterion will be removed from the EPEAT Registry and archived.

•The EPEAT Registry maintains a list of archived products that can be accessed by purchasers.

Supporting Resources and Training
EPEAT prepares supporting resources and training for all EPEAT criteria to help Participating Manufacturers andGEC-approved CABs further understand EPEAT Criteria requirements. These materials provide supplementary
information and further details regarding demonstration of conformance with EPEAT Criteria. The materials areaccessible to Participating Manufacturers and GEC-approved CABs on the back end of the EPEAT Registry
through their EPEAT Registry accounts.
In addition to the implementation schedule, the following are available to ensure consistency, transparency,objectivity, and efficiency for implementation of Criteria for the Assessment of Ultra-Low Carbon Solar Modules:•Conformity Requirements and Guidance Materials: These documents provide an overview of the criteria
requirements, further explain the evidence required, and illustrate examples of supporting evidence. A
separate document is available for each of the each of the three criteria in Criteria for the Assessment ofUltra-Low Carbon Solar Modules.

•Training Slides and Recordings: CAB Auditors must take the required training for Criteria for theAssessment of Ultra-Low Carbon Solar Modules and pass the associated exam. The training presentation
and recording is also available to Participating Manufacturers as an additional resource to understandthe conformity requirements.

•Recently Answered Questions: This document summarizes the questions received and responses
provided by EPEAT specifically for the Criteria for the Assessment of Ultra-Low Carbon Solar Modules.
The document is intended to make it easier for Participating Manufacturers and GEC-approved CABs tolearn about and easily access new information that may impact and/or facilitate ongoing conformity
assurance activities. The document is updated weekly on Thursdays between 1 pm and 5 pm North
American Pacific Time.

EPEAT Implementation Plan for ULCS Modules Criteria
Published April 23, 2024
Global Electronics Council©2024 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 5 of 6

EPEAT Climate+™
EPEAT Climate+ is a designation that can be earned by EPEAT registered products. EPEAT Climate+ allows
Participating Manufacturers to promote their commitment to addressing climate change and reach purchasers
and other stakeholders looking to do the same through procurement, investment, or other means.
The EPEAT Climate+ designation is reserved for products that have been verified by a GEC-approved Conformity
Assurance Body (CAB) against the requirements for EPEAT Climate+ identified below2.
First, companies and their products must prove they meet existing EPEAT criteria on climate, circularity,reduction of chemicals of concern, and responsible supply chains for their respective product categories, andhave this verified by a CAB. These criteria represent sustainability leadership and address environmental andsocial impacts across the entire product lifecycle, from the extraction of resources and manufacturing, throughproduct assembly, use, and end-of-life.
In addition to this, companies and their products must prove, and have independently verified by a CAB, thatthey meet a unique set of climate criteria based on progressive product design and corporate practices:

Computers and Displays,Imaging Equipment, Mobile
Phones, Servers, Televisions

Photovoltaic Modules•
•
•
•
•
•
•
•

Product carbon footprint disclosure and assurance
Product energy efficiency (ENERGY STAR product eligibility criteria)
External power supply energy efficiency
Battery charger system energy efficiency
Corporate GHG inventory disclosure and assurance
Corporate GHG reduction target aligned with climate science
Energy efficient upstream manufacturing processes
Manufacturer sourcing of electricity from renewable energy sources• Ultra-low embodied carbon (threshold of 400 kg CO2e per kWp)

Participating Manufacturers are not required to have their products achieve EPEAT Climate+. However, thosethat do will be recognized on the EPEAT Registry as EPEAT Climate+ Champions.
EPEAT Climate+ does not affect a product’s tier level of Bronze, Silver, or Gold. Tier levels are still based on thepercentage of available optional EPEAT criteria that apply to the product type.

2Requirements to achieve the EPEAT Climate+ designation will evolve over time and may require additional conformity assurance
activities. On November 1, 2025, the updated requirements for EPEAT Climate+ designation will become effective for the following
product categories: Computers and Displays, Imaging Equipment, Mobile Phones, Servers, and Televisions. These new requirements will
be announced in Spring 2024. (The requirements for the EPEAT Climate+ designation for Photovoltaic Modules will remain the same.)

EPEAT Implementation Plan for ULCS Modules Criteria
Published April 23, 2024
Global Electronics Council©2024 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 6 of 6