EPEAT Program
Continuous Monitoring Outcomes Report
Computers and Displays
IE-2021-03
June 3, 2022

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 calledRounds. 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 arerequired 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 IE-2021-03 conducted
for the Computers and Displays category.

2.0 Overview of Continuous Monitoring Round IE-2021-03
2.1Investigation Activities

As per the published Round Plan, Continuous Monitoring Round IE-2021-03 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

June 3, 2022

Criteria InvestigatedContinuous Monitoring Round IE-2021-03 was a Targeted Round focused on three Criteria related torepairability and extension of product life. Manufacturers were assigned one investigation per criteria (if they
had selected the criteria), and the products were selected randomly using a random number generator. Since
two of the selected Criteria are Optional and one is Required, Participating Manufacturers received up to 3
investigations. Participating Manufacturers that received a Major Nonconformance in any 2020 Continuous
Monitoring Round for Imaging Equipment were then also assigned one additional investigation in this Round.
The additional investigation assigned was an extra investigation for one of the three targeted Criteria.
Table 1: Criteria Investigated in Round IE-2021-03
Criteria NumberCriterion Title

4.3.1.2

Ease of disassembly of consumer products

4.4.2.1

Product upgradeability

4.4.3.1

Spare parts

3.0 Summary of Investigations and Final Decisions on Conformity for IE-2021-03
Highlights from this Continuous Monitoring Round are:•47 investigations completed•

40 decisions of Conformance•

7 decisions of Nonconformance

Further details provided in Section 4•

2 investigations cancelled[Cancelled due to CAB administrative challenges]

Figure 1: Final Conformity Decisions for IE-2021-03(shown as percentage of total investigations)Global Electronics CouncilOutcomes Report – Level 1 Investigations (P41B Issue2 Rev0)

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4.0 Further Details on Nonconformances for IE-2021-03
Figure 2 below provides a further breakdown of the nonconformances by Criterion.
Figure 2: Breakdown of Nonconformances by Criterion for IE-2021-03(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 IE-2021-03(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 IE-2021-03(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.

Four of the Minor Nonconformances were due to the fact that no documentation was provided, while one
Minor Nonconformance was a demonstrated nonconformance.
4.3

Major Nonconformances

Major Nonconformances may be due to a demonstrated nonconformance, insufficient evidence provided todemonstrate conformance, or because no documentation was provided. Two of the seven nonconformances
found in this Round were Major Nonconformances and both Major Nonconformances were for Criterion
4.3.1.2—Ease of disassembly of consumer products. One of the Major Nonconformances was due toinsufficient evidence, while the other was due to no documentation provided.
During Continuous Monitoring Rounds, Participating Manufacturers are responsible for compilingdocumentation and submitting it to their CAB in an organized and timely manner. Evidence must be submitted
before the end of the Investigation Phase. If a Participating Manufacturer does not provide documentation
during the Investigation Period, this will always result in a Major Nonconformance due to no documentation
provided, unless the product is end-of-life and no longer available on the market.
Criterion 4.3.1.2 has multiple elements against which conformance must be demonstrated. Criterion 4.3.1.2
requires a description of the disassembly process or letters from recyclers to demonstrate that Criterion
elements are met. All Criterion elements must be addressed, including all of the following:

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Ensuring ease of access to (a) materials with special handling needs that should be removed before
mechanical processing; (b) material, components and subassemblies that are able to be reused; and (c)components and subassemblies that may need removal for repair or replacement.
Ensuring external enclosures, chassis, and electronic subassemblies shall be removable by one personwith commonly available tools or by hand, including:o The use of common fasteners for joining components, subassemblies, chassis, and enclosures,(with an exception for special fasteners needed for safety and anti-theft reasons),o Disassembly for recycling purposes can be done exclusively with commonly available tools orby hand,o Adequate points of access for ease of dismantling of enclosures, chassis, and electronic
subassemblies.
o Non-separable connections (e.g., glued, welded) between different materials are avoided
unless they are technically or legally required or utilized for safety purposes or in an anti-theftapplication.
Electrical and communication wiring and cables that connect to external devices or sources of power
or data shall be removable without tools from all products unless they are technically required.

In addition, if there are any exemptions due to safety requirements, the Participating Manufacturer mustjustify the exemptions per the referenced safety standards in the 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 orunselecting 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 IE-2021-03:•1 investigation

Additional data provided by Participating Manufacturer, bringing the productinto conformance with the Criterion•1 investigation

Participating Manufacturer corrected information in the EPEAT Registry•

1 investigation

Criterion unselected by Participating Manufacturer•1 investigation

Product archived by Participating Manufacturer•

3 investigations

Corrective Action not submitted to EPEAT Program by deadline. EPEAT Program
undertook necessary follow up with CAB after deadline.

Table 2 in Section 7 identifies the Participating Manufacturers and products that received Major
Nonconformances in Continuous Monitoring Round IE-2021-03.
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6.0 Key Findings
6.1

Conformity Against All Elements of Criterion 4.3.1.2

Criterion 4.3.1.2 has multiple elements against which conformance must be demonstrated. Criterion 4.3.1.2
requires a description of the disassembly process or letters from recyclers to demonstrate that all Criterion
elements are met. Participating Manufacturers are encouraged to ensure their products meet all requirementsof the criterion and that they have supporting evidence for all criterion elements.
6.2

Definition of Spare Parts versus Consumables

Criterion 4.4.3.1 requires Participating Manufacturers to declare if spare parts are available, and if available,
the length of time that spare parts are available after the end of production.
Spare parts are defined as: A component of a product that is kept in reserve for possible use to replace asimilar or identical component in the product.
The definition of consumables confirms that spare parts and consumables are different:
Consumable: A product integral to the functioning of the imaging equipment product with the intent,
when depleted or worn, to be replaced or replenished by the user during the normal usage and life spanof the imaging equipment product. NOTE—Consumables may include: toner, toner containers, toner
bottles, toner cartridges, waste toner cartridges, ink cartridges, ink heads, ink sticks, ribbon ink,
thermal paper, copy paper, imaging units, transfer belts, transfer roller, fusers, drum maintenance
units, and other associated items. Items not intended to be replaced or replenished by the user would
not be considered consumable supplies, but rather “spare parts.”
Therefore, Participating Manufacturers are reminded to ensure that spare parts, not consumables, areavailable, if the Participating Manufacturer declares that spare parts are available for Criterion 4.3.1.1.
6.3

Ensure Registry Selections are Correct

If spare parts are available, Criterion 4.4.3.1 requires Participating Manufacturers to declare the length of timespare parts are available after the end of production. Participating Manufacturers are encouraged to review
Registry declarations to ensure they are accurate.

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

ProductProduct TypeCountryCriterion
NumberEpson

DS-30000

Scanner

United States

4.3.1.2

HPHP Laser MFD 432fdn

Multifunction
DeviceIndia

4.3.1.2

Global Electronics Council

Criterion Title

Ease of disassembly ofconsumer products
Ease of disassembly ofconsumer products

Required or
Optional

Underlying Reason for Nonconformance

Corrective Action Taken

Optional

No documentation provided

Optional

Insufficient evidence to demonstrate
conformance

Manufacturer unselected theCriterionCorrective Action not submitted by
CAB before deadline. EPEAT Program
undertook necessary follow-up.

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Document Control and Change History
Issue
1Revision
01

1

20

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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