EPEAT Program
Continuous Monitoring Outcomes Report
Imaging Equipment
IE-2022-04
April 6, 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-2022-04 conducted
for the Imaging Equipment category.

2.0 Overview of Continuous Monitoring Round IE-2022-04
2.1

Investigation Activities

As per the published Round Plan, Continuous Monitoring Round IE-2022-04 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

April 6, 2023

Criteria InvestigatedContinuous Monitoring Round IE-2022-04 focused on corporate criteria with annual disclosure requirements,
to confirm that Participating Manufacturers are fulfilling annual reporting requirements for the criteria
investigated. Since one criterion is required, and one is optional, Participating Manufacturers received up to
two investigations. If a Participating Manufacturer was investigated for any of the selected criteria in another2022 Continuous Monitoring Round, the criterion was not assigned again in this Round, given the annual
disclosure requirements. The products for investigation were selected randomly using a random number
generator.
Table 1: Criteria Investigated in Round IE-2022-04
Criteria Number

Criterion Title

4.7.2.2

Public disclosure of supply chain toxics

4.9.3.1

Provision of take-back and end-of-life management for cartridges and containers

3.0 Summary of Investigations and Final Decisions on Conformity for IE-2022-04
Highlights from this Continuous Monitoring Round are:•24 investigations completed•

4 decisions of Conformance•

20 decisions of Nonconformance

Further details provided in Section 4. Of thesenonconformances, 17 were due to CAB failure to submit
an Investigation Report.

Figure 1: Final Conformity Decisions for IE-2022-04(shown as percentage of total investigations)Global Electronics Council

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4.0 Further Details on Nonconformances for IE-2022-04
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-2022-04
Criteria Number

Criterion Title

Total Nonconformances

4.9.3.1

Provision of take-back and end-of-life management for cartridges and containers

10

4.7.2.2

Public disclosure of supply chain toxics

10

Figure 2 provides a further breakdown by the underlying reason for the nonconformances.
Figure 2: Underlying Reason for Nonconformances in IE-2022-04(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). One minor error was identified in Continuous Monitoring Round IE2022-04.
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.

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One minor error was identified in Round IE-2022-04—it was a demonstrated nonconformance, which meansthat evidence definitively showed that the Criterion was not met.
4.3

Nonconformances

Seventeen nonconformances due to CAB inaction or delay were identified in Continuous Monitoring Round IE2022-04. The three other nonconformances were demonstrated nonconformances. Both required Criterion
4.7.2.2 and optional Criterion 4.9.3.1 require public disclosure of certain information. If the public disclosure
does not meet all requirements of the Criterion, then the nonconformance is a demonstrated
nonconformance. Criterion 4.7.2.2 requires disclosures for a minimum number of suppliers of specificcomponents, while Criterion 4.9.3.1 requires disclosure of the total tonnage of cartridges and containers
collected annually (in metric tons), as well as the tonnage of materials sent to the end-of-life management
methods identified in the Criterion.
Figure 3 provides a breakdown of the nonconformances found in Round IE-2022-04.
Figure 3: Reasons for Nonconformances for IE-2022-04(shown as a percentage of total nonconformances)

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”).

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The following actions were taken to restore accuracy to the EPEAT Registry as a result of Continuous
Monitoring Round IE-2022-04:•

3 investigations

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

17 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-2022-04.

6.0 Key Findings
6.1

Demonstration of Conformance with All Elements of Criterion 4.9.3.1

Required Criterion 4.9.3.1 (provision of take-back and end-of-life management for cartridges and containers)
requires Participating Manufacturers to provide a take-back service for toner and ink cartridges andcontainers. Verification requirement 2) requires manufacturers to provide evidence of this program, by
providing evidence of a business relationship with the recycler or service provider. Verification requirement 4)
requires evidence that landfill disposal and incineration are not used as part of the take-back program forregistered and formerly registered products. Evidence may include policies or procedures, business contracts,
tonnage records from provider or recycler’s downstream flowchart that show incineration and landfill are notutilized.
6.2

Disclosure per Criterion 4.7.2.2 —Public disclosure of supply chain toxics

Optional Criterion 4.7.2.2 (public disclosure of supply chain toxics) requires disclosure of the toxic release data
for at least one registered product for at least three major suppliers for three of the six following listed
parts/component suppliers: display, external power supply (EPS), unpopulated printed circuit board, lamp,
motor and integrated circuit/semiconductor. Clarification #22 identifies the requirements if the Participating
Manufacturer has less than 3 suppliers for one of the key components identified. The Criterion also requires a
copy of the previous two annual public disclosures, unless it is the first year claiming the Criterion and theParticipating Manufacturer provides the most recent annual public disclosure and the policy establishing theannual nature of the public disclosure.

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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
NumberBrother

MFC-J4335DW

Multifunction
DeviceUnited States

4.7.2.2

Public disclosure of supply chain
toxicsBrother

Brother ADS-2700W

Scanner

United States

4.9.3.1

Canon

imagePRESS C710CA

Multifunction
DeviceUnited States

4.7.2.2

Canon

GP-4000

Printer

United States

4.9.3.1

Epson

DS-575W

Scanner

United States

4.9.3.1

Fujitsu Limited

Fujitsu N7100A

Scanner

United States

4.7.2.2

HP

HP LaserJet Managed
MFP E82560dn (X3A75A)

Multifunction
DeviceCanadaHP

HP Designjet T1300 44-in
PostScript® ePrinter with
Encrypted HDD (CR652B)
Konica Minolta bizhub
C368

Printer

Konica Minolta Accurio
Press C3080

Konica Minolta

Konica Minolta

Global Electronics Council

Criterion Title

Required or
Optional

Underlying Reason for Nonconformance

Corrective Action Taken

Optional

CAB inaction or delay not attributable
to the Participating Manufacturer

Provision of take-back and end-oflife management for cartridges andcontainers
Public disclosure of supply chain
toxicsRequired

CAB inaction or delay not attributable
to the Participating Manufacturer

Optional

CAB inaction or delay not attributable
to the Participating Manufacturer

Provision of take-back and end-oflife management for cartridges andcontainers
Provision of take-back and end-oflife management for cartridges andcontainers
Public disclosure of supply chain
toxicsRequired

CAB inaction or delay not attributable
to the Participating Manufacturer

Required

CAB inaction or delay not attributable
to the Participating Manufacturer

Optional

CAB inaction or delay not attributable
to the Participating Manufacturer

4.7.2.2

Public disclosure of supply chain
toxics

Optional

CAB inaction or delay not attributable
to the Participating Manufacturer

United States

4.9.3.1

Required

CAB inaction or delay not attributable
to the Participating Manufacturer

Multifunction
DeviceUnited States

4.7.2.2

Provision of take-back and end-oflife management for cartridges andcontainers
Public disclosure of supply chain
toxics

Optional

CAB inaction or delay not attributable
to the Participating Manufacturer

Multifunction
DeviceCanada4.9.3.1

Provision of take-back and end-oflife management for cartridges andcontainers

Required

CAB inaction or delay not attributable
to the Participating Manufacturer

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

Outcomes Report – Level 1 Investigations (P41B Issue2 Rev2)

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Kyocera

KYOCERA ECOSYS
M5526cdw

Multifunction
DeviceUnited States

4.7.2.2

Public disclosure of supply chain
toxics

Optional

CAB inaction or delay not attributable
to the Participating Manufacturer

Kyocera

KYOCERA ECOSYS
P2235dw

Printer

United States

4.9.3.1

Required

CAB inaction or delay not attributable
to the Participating Manufacturer

Lexmark

Printer

United States

4.9.3.1

Required

Demonstrated nonconformance

Ricoh

Lexmark C2326,
C3426dw, CS431dw,
C3326dw
RICOH P C600

Printer

United States

4.7.2.2

Provision of take-back and end-oflife management for cartridges andcontainers
Provision of take-back and end-oflife management for cartridges andcontainers
Public disclosure of supply chain
toxics

Optional

CAB inaction or delay not attributable
to the Participating Manufacturer

Ricoh

RICOH PRO 8300S

Multifunction
DeviceUnited States

4.9.3.1

Required

CAB inaction or delay not attributable
to the Participating Manufacturer

Riso Kagaku
Corporation

RISO ComColor FW5000

Printer

United States

4.7.2.2

Provision of take-back and end-oflife management for cartridges andcontainers
Public disclosure of supply chain
toxics

Optional

CAB inaction or delay not attributable
to the Participating Manufacturer

Riso Kagaku
Corporation

RISO MF9450U

DigitalDuplicator

United States

4.9.3.1

Required

CAB inaction or delay not attributable
to the Participating Manufacturer

Toshiba

Toshiba eStudio 2518A

United States

4.7.2.2

Optional

Demonstrated nonconformance

Sharp

SHARP MX-7580N

Multifunction
DeviceProfessional
Imaging Product

United States

4.9.3.1

Provision of take-back and end-oflife management for cartridges andcontainers
Public disclosure of supply chain
toxicsProvision of take-back and end-oflife management for cartridges andcontainers

Required

CAB inaction or delay not attributable
to the Participating Manufacturer

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
Manufacturer provided evidence demonstrating
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
Manufacturer provided evidence demonstrating
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

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