EPEAT®
PolicyManualThis document identifies the policies that govern and support EPEAT programmatic activities. As such,it applies to all manufacturers or brands that have active EPEAT-registered products or are in theprocess of confirming that their products conform with EPEAT Criteria (Participating Manufacturers)
and to all Conformity Assurance Bodies approved to provide EPEAT conformity assurance services(GEC-approved CABs).
A companion document, EPEAT Conformity Assurance Implementation Manual (P66), defines the
specific requirements and expectations of Participating Manufacturers and GEC-approved CABs when
implementing EPEAT policies. Participating Manufacturers and GEC-approved CABs must operate inaccordance with both Manuals as of their effective date to fulfill EPEAT Program requirements.
The EPEAT Program reviews the EPEAT Policy Manual (P65) and EPEAT Conformity Assurance
Implementation Manual (P66) on an annual basis to determine if revisions are required.
The latest revisions to this document were published on February 15, 2024. These revisions, unlessotherwise noted, are effective as of July 1, 2024.
Please direct any questions on this document to EPEAT@GEC.org .

Published February 15, 2024 and Effective July 1, 2024

Contents
1.0

Introduction ................................................................................................................ 3

2.0

EPEAT Governance ...................................................................................................... 4Contents

Authority............................................................................................................................... 4
Role of GEC ........................................................................................................................... 4
Program Transparency ......................................................................................................... 4
Confidentiality ...................................................................................................................... 4
Type 1 Ecolabel ..................................................................................................................... 5

3.0

EPEAT-Registered Products.......................................................................................... 6

4.0

EPEAT Criteria ............................................................................................................. 7
Overview............................................................................................................................... 7
Criteria Development, Revision and Adoption ..................................................................... 8
4.2.1 Selection of Product Categories ............................................................................... 8
4.2.2 Criteria Development Process .................................................................................. 8
4.2.3 Criteria Revisions .................................................................................................... 10
4.2.4 Adopting Criteria for Use in the EPEAT Program ................................................... 11

5.0

EPEAT Conformity Assurance System ......................................................................... 12
Overview............................................................................................................................. 12
Documentation Review ...................................................................................................... 12
Continuous Monitoring ...................................................................................................... 13
Nonconformances Identified Outside of Continuous Monitoring ..................................... 14
Rebranding of EPEAT-Registered Products ........................................................................ 14
EPEAT Technical Guidance and Authority .......................................................................... 14
5.6.1 Clarifications ........................................................................................................... 15
5.6.2 Conformity Requirements and Guidance Materials............................................... 15
5.6.3 Calibration Meetings .............................................................................................. 16
5.6.4 Conformity Guidance Group .................................................................................. 16

6.0

Requirements of Conformity Assurance Bodies .......................................................... 17
CAB Eligibility Requirements .............................................................................................. 17
Approval ............................................................................................................................. 17
Qualified Auditor Proficiency and Training Requirements ................................................. 18
Additional Oversight and Support ...................................................................................... 18
6.4.1 CAB Mentored Work Phase .................................................................................... 18
6.4.2 Annual EPEAT Audit of CAB .................................................................................... 19
6.4.3 Performance Metrics .............................................................................................. 19
6.4.4 Annual CAB Summit................................................................................................ 20
Suspension or Termination................................................................................................. 20

Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 1

Published February 15, 2024 and Effective July 1, 2024

7.0

Requirements of Participating Manufacturers ........................................................... 22
Initial Requirements ........................................................................................................... 22
Ongoing Requirements ....................................................................................................... 22
Changing CABs .................................................................................................................... 23
Termination ........................................................................................................................ 23

8.0Managing Impartiality and Conflicts of Interest ......................................................... 24
Recognized Potential Conflicts of Interest ......................................................................... 24
GEC CAB and Independence ............................................................................................... 25

9.0

Complaints and Appeals ............................................................................................ 26
Complaints .......................................................................................................................... 26
Appeals ............................................................................................................................... 27

10.0 Use of the EPEAT Name and Mark ............................................................................. 28
11.0 Other EPEAT Activities ............................................................................................... 29
12.0 Force Majeure Events ................................................................................................ 30

Contents

13.0 Revisions and Effective Date ...................................................................................... 31
14.0 Supplementary Information ...................................................................................... 32
Acronyms ............................................................................................................................ 32
References .......................................................................................................................... 32
Definitions .......................................................................................................................... 32
Document Change History.................................................................................................. 38

Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 2

Published February 15, 2024 and Effective July 1, 2024

1.0 Introduction
EPEAT® is a comprehensive voluntary sustainability Type 1 ecolabel that helps purchasers identify moresustainable technology products and services. Central to EPEAT are conformity assurance activities thatmeet the technical rigor and credibility needs of the institutional purchasers who rely upon it. The EPEAT
Program is owned and operated by the Global Electronics Council (GEC), a mission driven non-profit
working to create a world of only sustainable technology products and services.
EPEAT Criteria are developed in a multi-stakeholder, voluntary, consensus-based process and addressenvironmental and social impacts across the entire product lifecycle, from extraction of resources andmanufacturing, through to assembly, use, and end of life.

Introduction

EPEAT Criteria are designed to address both attributes of the product and corporate activities of the
Manufacturer and are identified as either Required or Optional. Required Criteria must be met for a
product to become EPEAT-registered. Optional Criteria represent a Participating Manufacturer’scommitment to innovation in environmental and social performance. Depending on the number of
Optional Criteria met, a product may achieve an EPEAT rating of Bronze, Silver, or Gold.
Participation in the EPEAT Program is voluntary, and open to any manufacturer or brand owner of
products in a product category for which EPEAT Criteria exist. Products that meet EPEAT Criteria are
identified in the public facing website called the EPEAT Registry. Before becoming EPEAT-registered, an
independent GEC-approved Conformity Assurance Body (CAB) must confirm the product’s conformancewith EPEAT Criteria. To ensure consistent and objective assessment of products, the EPEAT Program
maintains a Conformity Assurance System, which identifies the rules for conformity assurance activities
and provides oversight and ongoing approval of all CABs.
This document identifies the policies that govern and support EPEAT programmatic activities. As such, allmanufacturers or brands that have active EPEAT-registered products or are in the process of confirmingthat their products conform with EPEAT Criteria (Participating Manufacturers), and all CABs approved toprovide EPEAT conformity assurance services (GEC-approved CABs), are required to fulfill all applicablerequirements in this document. A companion document, EPEAT Conformity Assurance Implementation
Manual (P66), defines the specific requirements and expectations of Participating Manufacturers and
CABs when implementing EPEAT policies. The EPEAT Program reviews both this Policy Manual and the
EPEAT Conformity Assurance Implementation Manual (P66) on an annual basis to determine if revisions
are required.

Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 3

Published February 15, 2024 and Effective July 1, 2024

2.0 EPEAT Governance
Authority

EPEAT Governance

The EPEAT Program was initially developed by a broad group of diverse stakeholders representing
product manufacturers, component suppliers, environmental advocacy organizations, government
representatives, large purchasers of electronics, retailers, electronic recyclers, academic researchers,
and others. The EPEAT Program is owned, managed by, and operates under the authority of GEC. GEC isa nonprofit organization that serves the public interest by making the EPEAT Program available to theglobal public. GEC is overseen by a fiduciary board of directors. EPEAT Program staff are employees of
GEC.
Because the activities of GEC impact the interests of many stakeholders, GEC maintains an Advisory
Council that is comprised of a balanced representation of different stakeholder perspectives, to provide
advice and guidance to both GEC and the EPEAT Program. The Advisory Council does not influence
conformity assurance activities and has no fiduciary responsibility. As such, it does not influence EPEAT
Participating Manufacturer or CAB participation fees.

Role of GEC
GEC is owner of the EPEAT Trademarks and manager of the EPEAT Program.

Program Transparency
GEC is committed to transparency in its administration of the EPEAT Program and ensures that EPEAT
Program documents are freely available to stakeholders. Information is made available to interested
parties regarding the following aspects of the EPEAT Program: the selection of product categories; theselection, development, and revision of EPEAT Criteria; EPEAT Criteria including the identification of
methods used for product evaluation; and conformity assurance requirements and processes.
The activities of the Global Electronics Council are funded through a mix of trademark fees from ourecolabels, fees from CABs to support their training and auditing, in-kind support from partnerorganizations and grants/research funding. To this end, the Global Electronics Council makes annual
financial statements publicly available on the GEC website.

Confidentiality
As the owner of the EPEAT Trademarks and manager of the EPEAT Program, GEC has a robust
framework of internal policies and procedures in place to prevent the disclosure of any confidential
information in its possession. Participating Manufacturers provide the EPEAT Program with proprietary,commercially sensitive data. GEC ensures that all levels of the organization are in full compliance withapplicable laws to safeguard the confidentiality of this information.
All GEC personnel, including consultants and subcontractors, are contractually bound to keep all
information they have access to during their support of GEC activities confidential. GEC has contractual

Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 4

Published February 15, 2024 and Effective July 1, 2024

requirements on confidentiality in place with Participating Manufacturers [GEC EPEAT License andParticipating Manufacturer Agreement (P26)] and GEC-approved CABs [GEC Conformity Assurance Body
Agreement (P33)].

EPEAT Governance

Type 1 Ecolabel
The EPEAT Program is recognized by ANAB (ANSI National Accreditation Board) as a Type 1 ecolabel
defined by ISO 14024 Environmental labels and declarations – Type 1 environmental labelling –Principles and procedures. Key elements of Type 1 ecolabels include: development of criteria in avoluntary process that facilitates full participation of interested parties and makes reasonable efforts toachieve consensus throughout the process; inclusion of criteria that address impacts across the entire
lifecycle of the product or service; and independent validation of conformance to the criteria. GEC
follows both ISO 14020 Environmental labels and declarations – General principles and ISO 14024
Environmental labels and declarations – Type 1 environmental labelling – Principles and procedures
when managing all aspects of the EPEAT Program. GEC also goes beyond the requirements of ISO 14020
and ISO 14024 by using a balanced voluntary consensus process, including a consensus body (TechnicalCommittee), for the development and revision of Criteria.
GEC collaborates with a diverse range of stakeholders including technology product manufacturers andservice providers, retailers, large purchasers of technology products and services, CABs, scientificexperts, sustainability advocacy organizations, policy makers, and criteria development organizations toensure that the EPEAT Program remains a credible Type 1 ecolabel.

Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 5

Published February 15, 2024 and Effective July 1, 2024

3.0 EPEAT-Registered Products

EPEAT-Registered Products

EPEAT-registered products are identified by tier as EPEAT Bronze, EPEAT Silver, or EPEAT Gold. All
products must meet all Required EPEAT Criteria, and the tiers differentiate products by the percentage
of Optional EPEAT Criteria the products meet (see Section 4.1 for further details). GEC maintains theonline EPEAT Registry as a free resource where EPEAT-registered products can be found(https://epeat.net/). A product is considered “EPEAT-registered” only after a GEC-approved CAB has
confirmed conformance of all Required EPEAT Criteria and the Optional EPEAT Criteria selected for the
product and the EPEAT Program has performed a final review.
An EPEAT-registered product is a specific marketing model and includes all possible configurations orvariations that could be offered in that specific marketing model. This typically includes peripherals or
external components integral to a product’s operation; however, specific definitions of “product” areprovided in EPEAT Criteria for each product category.
Where applicable, Participating Manufacturers must identify those exceptional configurations of an
EPEAT-registered product that do not meet specific EPEAT Criteria. This information is provided toenable clear identification of which configurations qualify as EPEAT-registered.

Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 6

Published February 15, 2024 and Effective July 1, 2024

4.0 EPEAT Criteria
EPEAT Criteria address environmental and social impacts across the entire product lifecycle, fromextraction of resources and manufacturing, through to assembly, use, and end of life. Criteria are also
developed to reflect and address product function characteristics such as performance, lifetime,
durability, repairability, and upgradeability. EPEAT Criteria are based on the best science available at thetime of development and are revised as needed to maintain relevance. Relevant local, regional, andglobal environmental issues, available technologies, and best practices are taken into consideration
during the development of Criteria. Additionally, Criteria are designed to address impacts instead ofparticular processes or production methods wherever possible, and the Criteria do not create obstacles
to international trade. All EPEAT Criteria, whether new or revised, are publicly available at no cost andpublished on the EPEAT Registry after being adopted for use by the EPEAT Program.

EPEAT Criteria

GEC may collaborate with a criteria development organization to develop environmental and social
criteria, which can then be adopted by the EPEAT Program. Products are only considered EPEATregistered if they meet the Criteria that have been adopted by the EPEAT Program.
GEC’s criteria development and revision processes are described in GEC Criteria Development Process(P74), which is publicly available on the EPEAT Registry

Overview
EPEAT Criteria address attributes of the product and corporate activities of the Participating
Manufacturer and are identified as either Required or Optional. Required Criteria must be met for a
product to become EPEAT-registered. Optional Criteria represent a Participating Manufacturer’scommitment to innovation in environmental and social performance.
The EPEAT Program recognizes three tiers of sustainability performance: EPEAT Bronze, EPEAT Silver,and EPEAT Gold. The tier is determined by the Optional Criteria for which a Participating Manufacturer
has demonstrated conformance. Optional Criteria are designed to offer flexibility and allow Participating
Manufacturers to select different Criteria to achieve the EPEAT Silver and EPEAT Gold tiers.
•

EPEAT Bronze products meet all Required Criteria.

•

EPEAT Silver products meet all Required Criteria and a minimum of 50% of the available points
for Optional Criteria.

•

EPEAT Gold products meet all Required Criteria and a minimum of 75% of the available points
for Optional Criteria.

Participating Manufacturers choose to designate their EPEAT-registered products as available for use bypurchasers in specific countries. As a result, some EPEAT Criteria may be selected differently for
individual countries (also called individual locations of use). Participating Manufacturers must meet
EPEAT Criteria for those countries to ensure the country-specific benefits are realized for purchasers inthose countries, such as in-country product take-back and recycling requirements or the provision of
spare parts in a particular market.

Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 7

Published February 15, 2024 and Effective July 1, 2024

For some product categories, Innovation Points can be awarded if actions, programs, or policies exceed
existing EPEAT Criteria or represent sustainability benefits not already addressed for the productcategory. GEC’s Innovation Committee, an independent group of individuals with technology andsustainability expertise, reviews applications for Innovation Points and determines if Points should beawarded. Participating Manufacturers are not permitted to claim Innovation Points until awarded by the
Innovation Committee.

Criteria Development, Revision and Adoption

EPEAT Criteria

4.2.1

Selection of Product Categories

Prior to developing criteria for a new product category, GEC completes a Business Case (for internal use)
and releases a summary of its findings and recommendations, referred to as a Product Category
Proposal, for public comment. As a Type 1 ecolabel operating in accordance with the principles andrequirements of ISO 14024 Environmental labels and declarations – Type 1 environmental labelling –Principles and procedures, GEC ensures that the process which guides its selection of product categories
is transparent, and that interested stakeholders are appropriately engaged and consulted. GEC’s
procedure to select new product categories is described in GEC Selection of Product Categories (P75),
which is publicly available on the EPEAT Registry.

4.2.2

Criteria Development Process

GEC’s criteria development and revision processes are described in GEC Criteria Development Process(P74), which is publicly available on the EPEAT Registry. The criteria development process has three key
components which are described in further detail below: publication of State of Sustainability Research,
criteria development through balanced voluntary consensus processes, and continuous maintenance of
Criteria.
4.2.2.1

State of Sustainability Research

GEC publishes State of Sustainability Research as an important initial step in the development or revisionof criteria. The research identifies science-based social and environmental impacts across the life cycleof technology products and services, and strategies to reduce the identified sustainability impacts. The
research also identifies best practices, existing regulations, and existing voluntary leadership programs
designed to reduce sustainability impacts. The data and analyses in State of Sustainability Research
serves as the scientific basis for the development or revision of criteria, as well as identification ofopportunities for harmonization. GEC releases State of Sustainability Research for public consultation fora minimum of 60 days.
4.2.2.2

Balanced, Voluntary Consensus Process

EPEAT Criteria are developed in a balanced, voluntary consensus process that aligns with and draws
from characteristics of voluntary consensus defined in ISO 14024 Environmental labels and declarations– Type 1 environmental labelling – Principles and procedures and the US Federal Government’s

Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 8

Published February 15, 2024 and Effective July 1, 2024

EPEAT Criteria

description of characteristics of a voluntary consensus process1. Key characteristics of the criteria
development process, whether developed by GEC or in conjunction with a third-party criteria
development organization, are:•Openness: The process is open to participation by all interested parties. Such parties areprovided meaningful opportunities to participate in criteria development on a nondiscriminatory basis. The procedures or processes for participating in criteria development andfor developing the criteria are transparent.

•

Balance of interests: The process includes a balance of stakeholders including manufacturers;
other industry; government policy representatives and sustainability advocates; andpurchasers and ecolabel criteria users. Balance means that no single interest type shallcomprise more than 25% of the consensus body or dominate the voting process. If balanced
representation is not achieved, weighted voting may be used to achieve equal representation
among the four stakeholder categories identified above.

•

Due process: The process must include documented and publicly available policies andprocedures, adequate notice of meetings and other activities, sufficient time to review drafts
and prepare views and objections, access to views and objections of other participants, and afair and impartial process for resolving conflicting views.

•

Appeals process: A process must be available for the impartial handling of procedural appeals.

•

Consensus: Consensus is defined as general agreement, but not necessarily unanimity, andincludes a process for attempting to resolve objections by interested parties. All comments
must be fairly considered, each objector must be advised of the disposition of his or her
objection(s) and the reasons why, and the consensus body members must be given an
opportunity to change their opinion after reviewing the comments.

4.2.2.3

Collaboration with Criteria Development Organizations

GEC may partner with criteria development organizations (sometimes referred to as standards
development organizations) to collaboratively develop and revise criteria. GEC only engages with anorganization to do so if the following requirements are fulfilled:

1•

Shared Intellectual Property Rights: GEC must, at minimum, share the intellectual property
rights for the output of every criteria development, revision, and maintenance process so that
GEC can make the criteria and any accompanying resources freely available to stakeholders.

•

Balanced, Voluntary Consensus Criteria Development Process: All criteria must be developed
under a balanced, voluntary consensus process that is consistent with the elements describedin Section 4.2.2.2 and in accordance with GEC Criteria Development Process (P74).

U.S. Executive Office of the President, Office of Management and Budget (OMB), Circular No. A-119.

Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 9Published February 15, 2024 and Effective July 1, 2024•

GEC Criteria Development Process: The process must adhere to GEC’s Criteria Development
Process described in Section 4.2.2 and further detailed in GEC Criteria Development Process(P74).

•

Fees: GEC has a strong preference to partner with organizations that do not charge fees for
criteria development or for stakeholders to participate in the criteria development process,including committees such as Expert Ad Hoc Groups or the consensus body (TechnicalCommittee).

4.2.3

Criteria Revisions

EPEAT Criteria

GEC reviews and revises Criteria, as needed, approximately every three years from publication to ensurethat the Criteria remain relevant, continue to be impactful, and incentivize leadership performance. If
results of the initial GEC review determine that revisions are not necessary, GEC evaluates the need forrevision approximately every 12 months thereafter.
Two categories of criteria revisions exist: Full Criteria Revisions and Limited Criteria Revisions. Interim
Corrections address minor errors, omissions, and outdated references. The scope of each type ofrevision is identified in GEC Criteria Development Process (P74).
Any full or limited revision to EPEAT Criteria is conducted in accordance with the principles andprocedures outlined in GEC Criteria Development Process (P74), including establishment of Expert Ad
Hoc Groups and decision making by a balanced Technical Committee in a voluntary consensus process.
Limited Criteria revisions are an out-of-cycle revision to EPEAT Criteria that has a narrowly defined scopeor addresses a limited number of criteria, whereas an Interim Correction is a provisional modification tocorrect an error, omissions, or outdated reference in EPEAT Criteria that is considered in the next
relevant criteria revision process. Decisions on Interim Corrections are determined by a Correction
Committee, comprised of a balance of stakeholder interest, by voluntary consensus.
GEC accepts ongoing feedback on its criteria from all interested stakeholders, including requests forrevisions to criteria, addition of new criteria, or removal of existing criteria. Stakeholders must use theCriteria Revision and Revision Request Form (available upon request) to submit written feedback. All
feedback is considered in the next regularly scheduled Full Criteria Revision, unless the feedback meetsthe qualification for a Limited Criteria Revision or Interim Correction, as outlined in GEC Criteria
Development Process (P74).
When EPEAT Criteria are updated or revised, GEC establishes a transition period to allow Participating
Manufacturers time to come into conformance with the updated or revised Criteria. GEC considers thenumber and complexity of new Criteria or proposed changes to existing Criteria, as well as productdevelopment cycles, and product availability on the Registry when developing the timeframe of thetransition period. Further details on implementation requirements are identified in EPEAT Conformity
Assurance Implementation Manual (P66).

Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 10

Published February 15, 2024 and Effective July 1, 2024

4.2.4

Adopting Criteria for Use in the EPEAT Program

As a Type 1 ecolabel operating in accordance with the principles and requirements of ISO 14024
Environmental labels and declarations – Type 1 environmental labelling – Principles and procedures, GEC
evaluates criteria against the following requirements before they can be adopted for use as EPEAT
Criteria:

EPEAT Criteria•

The criteria must only be attainable by leadership sustainability performance in the market
and provide one or more of the following sustainability benefits:oMeasurable environmental and/or social benefits.

oIncremental steps towards a sustainability benefit, establishment of systems to provide
benefit, or foundational elements of environmental or social management systems.

oReporting of data that will allow the comparison of key sustainability aspects ofproducts or that will help fill critical information gaps to facilitate future development.

•

The criteria must have been developed using a balanced voluntary consensus process.

•

The criteria must be both lifecycle-based and science driven.

•

The criteria must be clearly written and verifiable through use of objective metrics andcommonly accepted tools, methodologies, and/or standards.

•

Optional criteria must provide a continuing challenge for improvement of sustainability
performance and be defined such that the technological or operational capability canreasonably be expected to be achieved before the next Full Criteria Revision.

•

The criteria must be available to the public free of charge.

•

To the extent possible, criteria should also be harmonized with international environmental
and social requirements and standards, including voluntary ecolabels and market
requirements.

GEC only considers for adoption Criteria as developed and approved by the voluntary consensus process
without modification. This includes newly developed criteria, Full Criteria Revisions or Limited Criteria
Revisions. Interim Corrections are considered informative (not normative). As such, adoption for use by
the EPEAT Program is not necessary.
GEC solicits feedback from the Advisory Council regarding the adoption of criteria, however the final
decision to adopt any criteria ultimately resides with GEC.

Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 11

Published February 15, 2024 and Effective July 1, 2024

5.0 EPEAT Conformity Assurance System

EPEAT Conformity Assurance System

Overview
To ensure consistent and objective assessment of products and to maintain the credibility of the EPEAT
Registry as a trusted resource for purchasers, the EPEAT Program operates a Conformity Assurance
System, which identifies the rules for conformity assurance activities and provides oversight andongoing approval of CABs. EPEAT Conformity Assurance Implementation Manual (P66) outlines theimplementation requirements for the EPEAT Conformity Assurance System, which must be followed by
all GEC-approved CABs and Participating Manufacturers.
To participate in the EPEAT Program, Participating Manufacturers must engage a GEC-approved CAB.
CABs are impartial, independent conformity assurance experts responsible for assessing Participating
Manufacturers’ initial and ongoing conformance with EPEAT Criteria (Documentation Review) and for
implementing surveillance activities (Continuous Monitoring).
The EPEAT Program offers Participating Manufacturers two conformity assurance pathways to choose
from – the Certification Pathway and the Verification Pathway. Both Pathways require Participating
Manufacturers to work with a GEC-approved CAB for Documentation Review and Continuous
Monitoring. The key differences in the Pathways are how products are sampled for Documentation
Review and the length of validity of results from Initial Documentation Review. EPEAT-registeredproducts are not publicly identified in the EPEAT Registry as being assessed through Certification or
Verification as both pathways are equally robust, credible, and valid.

Documentation Review
Documentation Review is the process by which a GEC-approved CAB assesses documentation provided
by a Participating Manufacturer to determine if the evidence supports conformance with EPEAT Criteria.
Documentation Review for all selected Criteria must be completed prior to products initially becoming
EPEAT-registered for a specific product category (called Initial Documentation Review) and on an
ongoing basis (called Ongoing Documentation Review), for various scenarios including, but not limited
to, selection of new Optional Criteria, addition of new products to the EPEAT Registry, and decisions ofnonconformance resulting from Continuous Monitoring.
When the CAB is confident that evidence supports conformance with all Required Criteria and all
selected Optional Criteria, and a review has been completed by EPEAT, the assessed products andselected Criteria may appear in the EPEAT Registry.
In both pathways, the Initial Documentation Review is completed immediately and requires Participating
Manufacturers to demonstrate conformance with all selected EPEAT Criteria at the outset.
In both pathways, the Initial Documentation Review results are valid until the EPEAT Program
implements updated or revised Criteria resulting from a Full Criteria Revision. At this point, Initial
Documentation Review against the resulting revised criteria must be performed again.

Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 12

Published February 15, 2024 and Effective July 1, 2024

Regardless of the pathway chosen, all products are subject to Continuous Monitoring on an annual
basis.
Additional details on product registration and conformity assurance requirements for both Participating
Manufacturers and GEC-approved CABs are identified in EPEAT Conformity Assurance Implementation
Manual (P66).

EPEAT Conformity Assurance System

Continuous Monitoring
To ensure the ongoing conformance of EPEAT-registered products, the EPEAT Program requires GECapproved CABs to conduct Continuous Monitoring. These activities occur throughout the year and test
the ability of Participating Manufacturers to prove conformance with EPEAT Criteria on an ongoingbasis. All EPEAT-registered products in all product categories are subject to Continuous Monitoring at
any time, regardless of the conformity assurance pathway chosen. Specific Continuous Monitoring
activities, requirements, and associated definitions are described in EPEAT Conformity Assurance
Implementation Manual (P66).
Some Continuous Monitoring activities require that investigations be conducted in discrete timeframescalled Rounds. The EPEAT Program is responsible for developing timelines for the Rounds, selecting the
EPEAT-registered products and EPEAT Criteria to be investigated, and identifying the method ofinvestigation. Methods of investigation may include review of publicly available information or
documentation provided by Participating Manufacturers, and independent laboratory evaluation of
products without the Participating Manufacturers’ involvement.
The EPEAT Program assigns the investigations to GEC-approved CABs, which must fully participate in andare responsible for implementing Continuous Monitoring activities with their Participating Manufacturer
clients in accordance with the Round Plan and/or instructions issued by GEC. GEC-approved CABs submit
Investigation Reports to the EPEAT Program with their recommendation on conformity and the EPEAT
Program makes the final decision on conformity (conformance, nonconformance, minor error,
nonconformance due to CAB inaction or delay not attributable to Participating Manufacturer, orinconclusive) based on the Investigation Report and accompanying evidence. All nonconformances(including those due to CAB inaction or delay) and minor errors must be corrected during the Correction
and Corrective Action Phase of the Round, and corrective action plans developed to address otherproducts that may be affected by the same issue underlying the nonconformance. For inconclusive
findings, the EPEAT Program may require the CAB to investigate the same Criterion in a subsequent
Round or address the issue outside of a Round to definitively determine conformance. Additional details
are available in EPEAT Conformity Assurance Implementation Manual (P66).
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 and Participating Manufacturers that received nonconformances (including those due to
CAB inaction or delay) and the actions taken to restore accuracy of the EPEAT Registry. Minor errors areclerical in nature and do not materially affect the validity of products in the EPEAT Registry. As such,these are not identified in the Outcomes Report. Similarly, Outcomes Reports do not identify the
products and Participating Manufacturers where the final decision on conformity is inconclusive.

Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 13

Published February 15, 2024 and Effective July 1, 2024

EPEAT Conformity Assurance System

Continuous Monitoring also includes Annual Renewal for Participating Manufacturers using theCertification Pathway. Annually, GEC-approved CABs must review evidence submitted by Participating
Manufacturers to demonstrate ongoing compliance with EPEAT Criteria that have annual performance,
reporting or other disclosure requirements at the corporate level. GEC-approved CABs must also
determine if product and/or corporate changes made by Participating Manufacturers or revisions madeto EPEAT Criteria have the potential to affect ongoing conformance with EPEAT Criteria and, where
necessary, review additional evidence to support conformance.
If any Continuous Monitoring activity results in a nonconformance (including those due to CAB inaction
or delay) or a minor error, the Participating Manufacturer must make corrections to address theidentified nonconformance or minor error and restore accuracy to the EPEAT Registry, where applicable.
Should a Participating Manufacturer fail to make the necessary corrections, the products will be
removed from the Registry by either the Participating Manufacturer’s CAB or the EPEAT Program.

Nonconformances Identified Outside of Continuous
Monitoring
GEC-approved CABs may identify nonconformances outside of planned Continuous Monitoring
activities. In such cases, the GEC-approved CAB must notify the EPEAT Program and work with theParticipating Manufacturer to resolve the nonconformance within 30 calendar days, as per therequirements identified in EPEAT Conformity Assurance Implementation Manual (P66).
The EPEAT Program may also identify nonconformances outside of planned Continuous Monitoring
activities. In such cases, the EPEAT Program will notify the Participating Manufacturer and their GECapproved CAB of the finding and require the Participating Manufacturer to resolve the nonconformancewithin 30 calendar days, as per the requirements identified in EPEAT Conformity Assurance
Implementation Manual (P66). The EPEAT Program may also initiate a formal Continuous Monitoring
investigation.

Rebranding of EPEAT-Registered Products
The EPEAT Program allows for a Participating Manufacturer to rebrand another Participating
Manufacturer’s active EPEAT-registered product and register it under its own brand, through anamended Documentation Review process. Both Participating Manufacturers are demonstrating ongoing
conformance with EPEAT Criteria that address corporate activities and the Participating Manufacturer
that originally registered the product has already demonstrated that the product meets EPEAT Criteria.
This amended process does not require either Participating Manufacturer to change from their existing
GEC-approved CAB. Details and requirements of the amended Documentation Review process aredescribed in EPEAT Conformity Assurance Implementation Manual (P66).

EPEAT Technical Guidance and Authority
As a Type 1 ecolabel operating in accordance with the principles and requirements of ISO 14024
Environmental labels and declarations – Type 1 environmental labelling – Principles and procedures, the
EPEAT Program is solely responsible for making technical interpretations of EPEAT Criteria, determining

Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 14

Published February 15, 2024 and Effective July 1, 2024

the necessary conformity assurance requirements for assessing conformance to EPEAT Criteria, andadjudicating disagreements in the interpretation of Criteria and the associated conformity assurance
requirements. Careful consideration is given to the specific language used in EPEAT Criteria.

EPEAT Conformity Assurance System

To further the understanding of EPEAT Criteria and ensure consistent and objective conformity
assurance activities, the EPEAT Program publishes informative guidance materials and further details
regarding conformity requirements, convenes Calibration Meetings with all GEC-approved CABs, andseeks technical feedback from a group of experts.
During their ongoing interactions with Participating Manufacturer clients, GEC-approved CABs may
identify that there is a conflicting or disparate understanding of EPEAT Criteria and/or the associatedconformity assurance requirements. In such situations and where they are unable to resolve the conflictwith the Participating Manufacturer, CABs must inform the EPEAT Program. The EPEAT Program willthen make a definitive technical interpretation and share it with all GEC-approved CABs andParticipating Manufacturers.

5.6.1

Clarifications

Historically, the EPEAT Program issued a formal Clarification when EPEAT Criteria were ambiguous. The
EPEAT Program now takes issues requiring clarification to the Conformity Guidance Group.
Clarifications include an effective date, which was typically 30 calendar days after publication but may
have been longer, depending on the impact to conformity assurance activities. Clarifications are stillrequired to be used in conformity assurance activities after the effective date.
Clarifications provide additional information on interpreting the Criteria and how they should be
implemented and do not change the criterion text. All existing Clarifications will be maintained until thetransition to the updated criteria by sustainability impact area. These Clarifications are accessible by all
GEC-approved CABs and Participating Manufacturers on the EPEAT Registry and available tostakeholders upon request.

5.6.2

Conformity Requirements and Guidance Materials

The EPEAT Program publishes Conformity Requirements and Guidance Materials to help Participating
Manufacturers and GEC-approved CABs further understand EPEAT Criteria requirements, provide
supplementary information and where necessary, provide further details regarding demonstration ofconformance with EPEAT Criteria. Where content in these materials is specifically identified as“guidance”, EPEAT Criteria take precedence over that content. Conformity Requirements and GuidanceMaterials are prepared for all Criteria and are made available to all GEC-approved CABs and Participating
Manufacturers.

Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 15

Published February 15, 2024 and Effective July 1, 2024

EPEAT Conformity Assurance System

5.6.3

Calibration Meetings

The EPEAT Program convenes regularly scheduled Calibration Meetings with all GEC-approved CABs topromote a uniform understanding of EPEAT Criteria and a consistent and objective application ofconformity assurance requirements among all CABs. Calibration Meeting materials are made available toall GEC-approved CABs and the results of technical questions and technical topics are incorporated into
conformity resources. At least one representative from each GEC-approved CAB must attend each
Calibration Meeting. The frequency of Calibration Meetings may increase when deemed necessary by
the EPEAT Program. Calibration Meetings are not held in person to enable broader participation and all
meeting participants are expected to abide by Chatham House Rule2 and an anti-trust statement.

5.6.4

Conformity Guidance GroupOn an as-needed basis, the EPEAT Program may seek feedback and guidance from the Conformity
Guidance Group. The Conformity Guidance Group may be asked to provide technical input and expertiseon EPEAT conformity assurance processes, technical requirements in EPEAT Criteria, andimplementation of updated and amended EPEAT Criteria. The EPEAT Program may also seek Conformity
Guidance Group input when adjudicating disagreements in the interpretation of a criterion and theassociated conformity assurance requirements. Conformity Guidance Group feedback does not replace
GEC’s criteria development and revision processes.
The Conformity Guidance Group is open to all stakeholders including, but not limited to, Participating
Manufacturers, GEC-approved CABs, purchasers, and Technical Committee members. There are nostanding members and participants are asked to be technical experts themselves or individuals withaccess to relevant technical resources. To ensure appropriate expertise is available for a given topic, the
EPEAT Program may invite individuals with expert knowledge of that topic to participate. EPEAT
Conformity Assurance Implementation Manual (P66) provides additional details on the Conformity
Guidance Group, including how to participate.

2

https://www.chathamhouse.org/about-us/chatham-house-rule

Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 16

Published February 15, 2024 and Effective July 1, 2024

6.0 Requirements of Conformity Assurance Bodies

Requirements of Conformity Assurance Bodies

CAB Eligibility Requirements
The EPEAT Program maintains formal Eligibility Requirements that must be fulfilled for an organization
to become a GEC-approved CAB and provide conformity assurance services for Participating
Manufacturers in specific product categories. These requirements must also be met on an ongoing basis
for an organization to maintain its status as a GEC-approved CAB. GEC-approved CABs must fulfill all
applicable requirements in this document [EPEAT Policy Manual (P65)] and operate EPEAT conformity
assurance services under a valid accreditation to either ISO/IEC 17020 Conformity assessment –Requirements for the operation of various types of bodies performing inspection or ISO/IEC 17065
Conformity assessment – Requirements for bodies certifying products, processes, and services. Fulldetails on CAB Eligibility Requirements are identified in EPEAT Conformity Assurance Implementation
Manual (P66).

Approval
GEC accepts applications from all organizations interested in becoming a GEC-approved CAB and issolely responsible for the review and approval of CABs. GEC seeks to maintain a network of approved
CABs to meet Participating Manufacturer needs globally while also ensuring sufficient EPEAT Program
capacity exists to support and oversee the entire CAB network. When reviewing CAB applications, GEC
considers a variety of factors including technical capabilities of the organization, as well as the diverse
needs of Participating Manufacturers regarding linguistic capabilities and the ability to provide
conformity assurance services in regions of the world required by Participating Manufacturers.
If GEC determines that the applicant meets these needs and the application supports an organization’s
capabilities to perform conformity assurance activities for the EPEAT Program, the organization may be
identified as a Provisional CAB.
Provisional CABs must fully execute GEC Conformity Assurance Body Agreement (P33). They may thenbegin soliciting business for EPEAT conformity assurance services but may not provide these services
until formally approved by GEC.
Within 12 months of becoming a Provisional CAB, an organization must:•

Provide to GEC all procedures, policies and accreditation documents related to the provision ofconformity assurance services for the EPEAT Program.

•

Ensure personnel complete Initial EPEAT Auditor Training and pass the Initial EPEAT Auditor
Exam for each product category3 in which the CAB wishes to provide EPEAT conformity
assurance services.

3

When the updated EPEAT Criteria by sustainability impact area are finalized, all impact area training modules,
along with product-specific modules, where applicable, must be passed for an Auditor to be considered qualified inthose product categories adopting the updated Criteria.
Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 17

Published February 15, 2024 and Effective July 1, 2024

Requirements of Conformity Assurance Bodies•

Successfully complete the Initial EPEAT Audit of CABs to determine if the CAB Eligibility
Requirements are met.

Upon completion of the above in accordance with the requirements outlined in EPEAT Conformity
Assurance Implementation Manual (P66), the organization is identified as a GEC-approved CAB and may
provide conformity assurance services to Participating Manufacturers for product categories in which
they have completed training.
GEC-approved CABs are also required to pay an annual CAB Participation Fee to GEC to maintain theirstatus as an approved CAB for the EPEAT Program.
GEC seeks to maintain a network of approved CABs to meet Participating Manufacturer needs and may
solicit an organization to apply to become a GEC-approved CAB. GEC does not control the pricing of CAB
services and Participating Manufacturers are free to choose any GEC-approved CAB to support theirconformity assurance requirements.

Qualified Auditor Proficiency and Training Requirements
To ensure consistency, objectivity and technical competency, GEC-approved CABs must use Qualified
Auditors to perform conformity assurance activities for the EPEAT Program. Auditors become qualified
to perform conformity assurance for one or more product categories4 by completing Initial EPEAT
Auditor Training and passing the Initial EPEAT Auditor Exam for each product category. Separate training
and exams are required for each product category.
To maintain their qualifications, Qualified Auditors must abide by the requirements in EPEAT Conformity
Assurance Implementation Manual (P66) and attend required training sessions, pass corresponding
exams (where applicable), and pass an Annual EPEAT Auditor Proficiency Exam, which is intended toestablish the ongoing technical competency of the Qualified Auditor.
Auditors who fail to maintain their qualification for a given product category must retake the Initial
EPEAT Auditor Training and pass the Initial Auditor Exam. At the EPEAT Program’s discretion, Auditorswith ongoing absences due to illness, parental leave, sabbaticals, or other duties outside of EPEAT
conformity assurance activities may be allowed to attend training and pass exams upon their return.
To be qualified for a new EPEAT product category, Auditors must attend EPEAT training for the newcategory and pass the accompanying exam.

Additional Oversight and Support
6.4.1

CAB Mentored Work Phase

The EPEAT Program supports and oversees newly approved CABs as they perform Documentation
Review for their first Participating Manufacturer clients. This CAB oversight process is called CAB
4When the updated EPEAT Criteria by sustainability impact area are finalized, all impact area training modules,
along with product-specific modules, where applicable, must be passed for an Auditor to be considered qualified inthose product categories adopting the updated Criteria.
Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 18

Published February 15, 2024 and Effective July 1, 2024

Requirements of Conformity Assurance Bodies

Mentored Work Phase and is intended to confirm and support CABs in understanding the conformity
assurance requirements of EPEAT Criteria, seeking appropriate documentary evidence from
Participating Manufacturers, and appropriately evaluating evidence and assessing conformance in amanner consistent with published guidance and EPEAT Conformity Assurance Implementation Manual(P66).
During the Mentored Work Phase, a CAB cannot approve products and selected Criteria to appear in the
EPEAT Registry, or independently evaluate a Participating Manufacturer’s conformance to EPEAT
Criteria. To move out of the Mentored Work Phase, a CAB must obtain the EPEAT Program’s review andapproval of conformity decisions made in the Initial Documentation Review process for the CAB’s initial
Participating Manufacturer clients.

6.4.2

Annual EPEAT Audit of CAB

The EPEAT Program conducts an annual EPEAT Audit of all approved CABs to ensure the CABs’ ongoing
conformance with CAB Eligibility Requirements and all provisions in EPEAT Conformity Assurance
Implementation Manual (P66). Audit results are confidential and not disclosed to the public. As a resultof the audit, the EPEAT Program may identify opportunities for improvement, present
nonconformances, and/or develop a Performance Improvement Assistance Plan for the CAB. GECapproved CABs must implement the requirements in Performance Improvement Assistance Plans.
Within 30 calendar days of receiving the audit results, GEC-approved CABs must correct identified
nonconformances and develop corrective action plans to prevent reoccurrence. A nonconformance may
be related to a CAB’s conformity decision in Documentation Review or Annual Renewal and may
subsequently result in a Participating Manufacturer client being found nonconformant with one or more
EPEAT Criteria. In such cases, the CAB must identify similar conformity decisions made across all
Participating Manufacturer clients and inform the EPEAT Program of these cases. All affected
Participating Manufacturers are then provided three months to submit additional documentation todemonstrate conformance to the CAB or to make appropriate corrections to the EPEAT Registry.

6.4.3

Performance Metrics

The EPEAT Program evaluates the performance of all GEC-approved CABs against a series of conformity
assurance and service provision metrics at least annually and shares the results with CABs during theirannual EPEAT Audit. These performance metrics are designed to encourage continuous improvement in
the provision of conformity assurance services, maintain a high level of competency across all GECapproved CABs, and ensure consistent and objective conformity assurance decisions within and across
CABs.
If warranted, the EPEAT Program may assign corrective actions to GEC-approved CABs with
unsatisfactory performance. Results of performance evaluations are confidential and not disclosed tothe public.
The performance metrics are identified in EPEAT Conformity Assurance Implementation Manual (P66)
and are reviewed on an annual basis by the EPEAT Program, to ensure they remain relevant.

Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 19

Published February 15, 2024 and Effective July 1, 2024

6.4.4

Annual CAB Summit

Requirements of Conformity Assurance Bodies

On an annual basis, the EPEAT Program hosts a CAB Summit to further its goals of consistency,
objectivity, and proficiency in the assessment of products in the EPEAT Registry. The CAB Summit isintended to:•Strengthen GEC-approved CAB understanding of current EPEAT policies and conformity
assurance requirements.

•

Ensure the EPEAT Program benefits from GEC-approved CABs’ experience, expertise, and tacitknowledge on proposed changes to EPEAT policies and conformity assurance requirements.

•

Stimulate collaboration by providing a venue to discuss high-level conformity assurance issues
and share information.

•

Further empower GEC-approved CABs in their decision making with additional and focusedtraining.

Depending on the topics addressed, one or more GEC-approved CAB representatives or Qualified
Auditors are required to attend the Annual EPEAT CAB Summit. CABs are encouraged to invite additional
personnel to specific sessions, where relevant. Provisional CABs are also encouraged, but not required,
to attend the Annual CAB Summit.

Suspension or Termination
GEC, at its sole discretion, may suspend or terminate a GEC-approved CAB. CABs that are suspended
may continue to provide EPEAT-related conformity assurance services to their existing Participating
Manufacturer clients while in suspension, for no longer than six months as they undertake corrective
action but may not accept new Participating Manufacturer clients. GEC informs affected Participating
Manufacturer clients that their CAB has been suspended but does not disclose the reason(s) for
suspension. A CAB’s suspension status is not otherwise made publicly available.
CABs are permitted to appeal suspension within 14 calendar days of receiving the suspension noticefrom GEC. Appeals regarding CAB suspension may be made only on procedural grounds. Moreinformation regarding the appeal process is available in Section 9.2
Termination is cancellation of the agreement between GEC and the CAB and bars the CAB fromproviding conformity assurance services for the EPEAT Program for a fixed period. Any decision toterminate a CAB is considered final. EPEAT Conformity Assurance Implementation Manual (P66) provides
additional details regarding both suspension and termination of CABs.
Grounds for suspension or termination include any of the following:•

Nonconformances identified during the Annual EPEAT Audit, or an audit performed by anaccreditation body that remain uncorrected beyond the agreed time.

•

Failure to implement and complete all requirements of a Performance Improvement
Assistance Plan within the designated timeframe.

Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 20

Requirements of Conformity Assurance Bodies

Published February 15, 2024 and Effective July 1, 2024•

Non-payment of annual EPEAT CAB Participation Fees to GEC.

•

Any breach of GEC Conformity Assurance Body Agreement (P33) that goes uncorrected beyond
the agreed upon time.

•

Failure to meet the same Performance Metric for three consecutive years.

•

Failure to conform with the requirements identified in EPEAT Conformity Assurance
Implementation Manual (P66) that remain uncorrected beyond the agreed time.

•

Loss of accreditation to ISO/IEC 17020 Conformity assessment – Requirements for theoperation of various types of bodies performing inspection or ISO/IEC 17065 Conformity
assessment – Requirements for bodies certifying products, processes and services, or failure toprovide a valid certificate.

•Intentionally sharing upcoming Continuous Monitoring Round details with Participating
Manufacturers before the date specified by the EPEAT Program with the intention of providing
the Participating Manufacturer an unfair advantage.

•

Obtaining a product directly from a Participating Manufacturer for laboratory evaluation
without first obtaining approval from the EPEAT Program.

•

Undertaking actions that put the integrity and credibility of the EPEAT Program at risk, such asproviding consulting-like advice or services that impacts the CAB’s ability to remain impartial in
EPEAT-related activities or providing unfair advantage to one or more Participating
Manufacturer clients.

In the case of CAB termination, GEC informs the CAB’s EPEAT clients of the pending termination andsupports an orderly transition of these clients to other GEC-approved CABs.

Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 21

Published February 15, 2024 and Effective July 1, 2024

7.0 Requirements of Participating Manufacturers

Requirements of Participating Manufacturers

Initial Requirements
Participating Manufacturers must fulfill all applicable requirements in this document [EPEAT Policy
Manual (P65)] as well as EPEAT Conformity Assurance Implementation Manual (P66), execute GEC
EPEAT License and Participating Manufacturer Agreement (P26) with GEC, and pay an annual EPEAT
Participation Fee for each product category, which allows an unlimited number of EPEAT-registeredproducts for a given product category. Participating Manufacturers are granted access to the EPEAT
Registry only after a fully executed GEC EPEAT License and Participating Manufacturer Agreement (P26)
is in place and GEC has received payment for the applicable EPEAT Participation Fees.
To participate in the EPEAT Program, Participating Manufacturers must also establish a contractual
relationship with a GEC-approved CAB for the provision of conformity assurance services. A Participating
Manufacturer may engage different CABs for different product categories but can only use a single CAB
for each product category.
Prior to products becoming EPEAT-registered for any given product category, Participating
Manufacturers must successfully complete the Initial Documentation Review conducted by their GECapproved CAB. During this process, Participating Manufacturers are responsible for providing sufficientevidence and responding to all questions raised by the CAB. The requirements for Initial Documentation
Review are identified in EPEAT Conformity Assurance Implementation Manual (P66).
Participating Manufacturers acknowledge that selecting EPEAT Criteria is an indication that they are
conforming to the Criteria as written, unless exceptional configurations are identified, subject to any
guidance and Clarifications published by GEC. Participating Manufacturers must identify exceptional
configurations where the configurations or variations of a product means that the product does notmeet EPEAT Criteria.

Ongoing Requirements
Participating Manufacturers must fulfill all applicable requirements in this document [EPEAT Policy
Manual (P65)] and EPEAT Conformity Assurance Implementation Manual (P66) on an ongoing basis.
Participating Manufacturers are also required to update their EPEAT Criteria selections in the EPEAT
Registry as needed to reflect changes (including, but not limited to, changes in product materials,
components, contract services or corporate activities) if any of the changes impact how they are
conforming with the Criteria and/or their ability to successfully meet the Criteria. Participating
Manufacturers must also immediately unselect EPEAT Criteria they are no longer able to meet.
Participating Manufacturers are only able to achieve and maintain EPEAT-registration for products thatare available on the market. Participating Manufacturers must remove/archive products when the
products are no longer offered for sale or if the products no longer meet all Required Criteria.
Participating Manufacturers must be prepared at any time to provide evidence to demonstrate
conformance with EPEAT Criteria in response to a request from their CAB. As such, Participating

Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 22

Published February 15, 2024 and Effective July 1, 2024

Manufacturers are required to fully participate in Documentation Review (both Initial and Ongoing) andContinuous Monitoring activities.

Requirements of Participating Manufacturers

Participating Manufacturers must abide by the requirements in GEC EPEAT License and Participating
Manufacturer Agreement (P26) and EPEAT Conformity Assurance Implementation Manual (P66) on an
ongoing basis.

Changing CABs
Participating Manufacturers may transition from one GEC-approved CAB to a different GEC-approved
CAB for any given product category. Participating Manufacturers must transfer the conformity assurance
activities for all EPEAT-registered products in the product category to the new CAB but may engage
different CABs for different product categories. Participating Manufacturers must maintain a contractual
relationship with a GEC-approved CAB for all product categories in which they are active during thetransition process. Details and requirements for the process of changing CABs are identified in EPEAT
Conformity Assurance Implementation Manual (P66).

Termination
GEC may terminate a Participating Manufacturer according to the provisions in GEC EPEAT License andParticipating Manufacturer Agreement (P26). A decision to terminate a Participating Manufacturer isconsidered final. Grounds for termination include:•

Nonconformances identified during any investigation undertaken by a CAB or the EPEAT
Program that remain uncorrected beyond the agreed upon time.

•

Non-payment of annual EPEAT Participating Manufacturer Fee to GEC.

•

Any breach of GEC EPEAT License and Participating Manufacturer Agreement (P26) that goes
uncorrected beyond the agreed upon time.

•

Failure to conform with the requirements identified in EPEAT Conformity Assurance
Implementation Manual (P66) that remain uncorrected beyond the agreed time.

•

A CAB recommendation to terminate a Participating Manufacturer.

If a Participating Manufacturer is terminated, their GEC-approved CAB or the EPEAT Program
removes/archives all of the Participating Manufacturer’s products.

Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 23

Published February 15, 2024 and Effective July 1, 2024

Managing Impartiality and Conflicts of Interest

8.0 Managing Impartiality and Conflicts of Interest
GEC recognizes that impartiality and managing conflicts of interest are fundamental to maintaining the
integrity of the EPEAT Program. Impartiality is defined as the presence of objectivity, where objectivity
means that conflicts of interest do not exist or are resolved so as not to adversely influence subsequent
activities. Any situation where the EPEAT Program may be influenced by pressure from commercial,financial, organizational, or other obligations is considered a potential conflict of interest and risk to
impartiality.
To this end, GEC does not allow commercial, financial, or other pressures to compromise impartiality inthe EPEAT Program and eliminates or mitigates conflicts of interest that may influence development andrevision of EPEAT Criteria, management of the EPEAT Conformity Assurance System, and oversight ofprogrammatic activities.
The GEC leadership team ensures that the EPEAT Program is operated in a manner to safeguard
objectivity and impartiality. GEC evaluates risks to impartiality on an ongoing basis, including those thatarise from its activities, its relationships, or from the relationships of its personnel, and its sources offunding.
In instances where a risk to impartiality is identified and presents a serious threat to the credibility of
the EPEAT Program, the conflict is eliminated. In other cases, GEC mitigates the risks in such a way toensure impartiality is not compromised. This is accomplished through organizational and personnel
control measures, checks and oversight within criteria development and maintenance processes, andthe rigorous requirements in the EPEAT Conformity Assurance System. GEC also accepts and investigatesstakeholder complaints regarding potential conflicts of interest.
All GEC personnel are contractually obligated to comply with the rules defined by GEC relating toconfidentiality and independence from commercial and other interests, to disclose any actual or
perceived conflicts that may arise in the course of their work for GEC, and to act objectively and freefrom any pressures that could compromise their objectivity. GEC maintains signed statements to thiseffect for all personnel.
GEC’s policy on impartiality and conflicts of interest and administration of this policy are nondiscriminatory and are not used to impede or inhibit access to the EPEAT Program by Participating
Manufacturers or CABs. GEC monitors conformance to this policy through implementation of the EPEAT
Program’s quality management system.

Recognized Potential Conflicts of Interest
Although conflicts may arise in any facet of GEC’s operations or the EPEAT Program, GEC recognizes thefollowing as key sources of possible conflicts of interest:•

Sources of income and commercial pressures: The need to be fiscally solvent is an inherent
conflict of interest. GEC generates revenues through collecting trademark fees to allow the useof the EPEAT Mark by Participating Manufacturers and through collecting EPEAT CAB
Participation Fees from CABs. GEC also receives grants and research funding. Sources of

Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 24

Published February 15, 2024 and Effective July 1, 2024

Managing Impartiality and Conflicts of Interest

income present financial pressures that have the potential to influence the outcomes ofconformity assurance activities, and the development and maintenance of EPEAT Criteria.
•

Technical assistance and conformity assurance: GEC provides technical assistance and training
to Participating Manufacturers, GEC-approved CABs and Qualified Auditors, while also
operating and overseeing the Conformity Assurance System.

•

Individual stakeholder pressure and conformity assurance: Stakeholders may pressure GEC tochange the requirements of the EPEAT Program or a Criterion so that it is easier or moredifficult to achieve compliance, or they may pressure GEC to make the conformity assurance
process more or less rigorous.

•

GEC CAB and independence: GEC recognizes that as EPEAT Program owner and operator of a
Conformity Assurance Body, GEC is responsible for conformity assurance activities at the
EPEAT Program level and GEC CAB level. GEC CAB is subject to the same level of scrutiny andperformance requirements as all other GEC-approved CABs.

•

Using competent personnel while avoiding conflicts of interest: Given the highly specialized
nature of the EPEAT Program, there are a limited number of individuals who possess thequalifications and specific knowledge needed to work within these operations. It is likely thatsome GEC personnel may be involved in multiple aspects of the EPEAT Program activities.

GEC CAB and Independence
GEC recognizes that as the owner of both the EPEAT Program and a Conformity Assurance Body (GEC
CAB), there is an inherent risk to impartiality and a potential for conflicts of interest to arise, simply
because the EPEAT Program is responsible for overseeing all CABs. To eliminate this risk, GEC maintains
an organizational structure that effectively creates a firewall between EPEAT Program personnel and
GEC CAB personnel. EPEAT Program staff and GEC CAB staff do not share a physical office, and GEC’s
internal file platform has restrictions such that operational staff in each department cannot access, view,or edit documents and records from the other department.
GEC CAB receives no preferential treatment, is held to the same requirements as all other CABs, is notmade aware of any EPEAT Program announcements or decisions earlier than other CABs and does nothave any ability to influence the EPEAT Program more than any other CAB. Furthermore, questions
asked by GEC-approved CABs, including those asked by GEC CAB, are shared in regularly scheduled CAB
Calibration Meetings, although questions and responses are anonymized to protect confidentiality.
GEC CAB also is subject to the same oversight as all other GEC-approved CABs, including required
conformance with EPEAT Conformity Assurance Implementation Manual (P66) and participation in
Annual EPEAT Audits of CABs. GEC ensures that GEC CAB operates under independent accreditation that
evaluates its management of conflicts of interest. GEC CAB’s relationship to GEC does not compromise
the impartiality of GEC CAB’s conformity assurance activities or the integrity of the EPEAT Program.

Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 25

Published February 15, 2024 and Effective July 1, 2024

9.0 Complaints and Appeals
The EPEAT Program has a documented process to receive, evaluate and make decisions on complaints
and appeals and requires GEC-approved CABs to have a complaints and appeals process in place. GEC
organizational activities continue without limitation during an investigation into a complaint or appeal of
any nature. Complaints and appeals must be submitted in writing.

Complaints and Appeals

Complaints and appeals shall be handled swiftly and as transparently as possible, while still respecting
the confidentiality of all parties involved. Any GEC personnel who is the subject of the complaint orappeal will not be involved in the investigation of that complaint or appeal.
The EPEAT Program ensures that complaints and appeals do not result in discriminatory actions. No
complainant, appellant or other individual shall be negatively treated for bringing forward a complaint
or appeal, providing information related to a complaint or appeal, or helping to resolve a complaint orappeal.
The EPEAT Program is responsible for managing investigations into complaints and appeals and GEC
retains full authority to make the final determinations in the case of all complaints and appeals under its
purview.

Complaints
Complaints may be raised, in writing, by any person or organization and may address EPEAT-registeredproducts, misuse of the EPEAT mark or misleading claims about EPEAT product registration, conformity
recommendations or decisions, GEC’s c criteria development or revision activities, and/or GEC’s
management of the EPEAT Program.
GEC-approved CABs may receive complaints that are not related to its Participating Manufacturer clients(e.g., complaints about non-client’s EPEAT-registered products, conformity decisions made by other
CABs, other conformity assurance activities, potential misuse of the EPEAT mark, or misleading claims).
CABs must forward all such complaints to the EPEAT Program and should not initiate an investigation
regarding these issues unless explicitly instructed by the EPEAT Program to do so.
Complaints regarding dissatisfaction with a GEC-approved CAB must first be directed to that CAB. If thecomplainant is not satisfied with the resolution of the complaint, then the complainant may raise theissue directly with the EPEAT Program. The EPEAT Program strives to resolve such issues jointly with the
GEC-approved CAB.
Complaints pertaining to the Voluntary Consensus Process must first be directed to, and investigated by,
the criteria development organization managing the Voluntary Consensus Process. If the complainant is
not satisfied with the resolution of the complaint, then the complainant may raise the issue, in writing,directly with GEC. Complaints regarding other aspects of GEC’s criteria development or revision activities
are received and managed by GEC. Details regarding the management of such complaints are identified
in GEC Criteria Development Process (P74).

Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 26

Published February 15, 2024 and Effective July 1, 2024

Appeals
Appeals regarding conformity assurance recommendations and decisions may be raised, in writing, byParticipating Manufacturers and GEC-approved CABs. Such appeals may be made on technical orprocedural grounds. Details regarding the management of such complaints and appeals are identified in
EPEAT Conformity Assurance Manual (P66).

Complaints and Appeals

Provisional CABs and GEC-approved CABs may appeal decisions made by the EPEAT Program during theInitial EPEAT Audit or Annual EPEAT Audit. Such appeals may be made on technical or procedural
grounds. Details regarding the management of such appeals are identified in EPEAT Conformity
Assurance Implementation Manual (P66).
GEC-approved CABs that have been suspended may appeal the decision. Such appeals may be madeonly on procedural grounds and must be submitted in writing within 14 days. Details regarding themanagement of such appeals are identified in EPEAT Conformity Assurance Implementation Manual(P66).
Procedural appeals pertaining to the Voluntary Consensus Process must first be directed to, andinvestigated by, the criteria development organization managing the Voluntary Consensus Process. If theappellant is not satisfied with the resolution of the appeal, then the appellant may raise the procedural
issue in writing directly with GEC. Procedural appeals regarding other aspects of GEC’s criteria
development and revision activities are received and managed by GEC. Technical appeals related to any
aspect of GEC’s criteria development and revision activities are not permitted. Details regarding themanagement of such procedural appeals are identified in GEC Criteria Development Process (P74).

Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 27

Published February 15, 2024 and Effective July 1, 2024

10.0 Use of the EPEAT Name and MarkThe EPEAT name and marks are trademarked in the United States, the European Union, and several
other countries worldwide by the Global Electronics Council. GEC licenses the use of the EPEAT nameand marks only through formal license agreements. Inappropriate use of the EPEAT name and marks will
be prosecuted to protect the credibility of the EPEAT brand.

Use of the EPEAT Name and MarkMany countries around the world have requirements that govern how organizations may communicate
the sustainability characteristics of their products. Participating Manufacturers are responsible for
ensuring compliance with local laws and regulations when using the EPEAT mark.
To enable coordination and consistent messaging about the EPEAT Program, GEC-approved CABs may
be required to obtain GEC’s approval of any communications related to the EPEAT Program and theirrole as a CAB. As independent, impartial conformity assurance experts, GEC-approved CABs areprohibited from claiming or inferring that they receive any preferential treatment from the EPEAT
Program.
Participating Manufacturers are granted a license to use the EPEAT name and relevant marks topromote their active EPEAT-registered products. Participating Manufacturers must abide by therequirements in GEC EPEAT License and Participating Manufacturer Agreement (P26) regarding EPEATrelated advertising, promotional, marketing, and related uses of the marks. The marks must be used in amanner consistent with the EPEAT designation of Bronze, Silver or Gold achieved by the product.
Participating Manufacturers shall not imply that they as an organization have been endorsed, approved,or rated by the EPEAT Program or GEC.

Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 28

Published February 15, 2024 and Effective July 1, 2024

11.0 Other EPEAT Activities
The EPEAT Program may, at its sole discretion, develop programs or mechanisms to encourage adoptionof EPEAT Criteria or promote the EPEAT Program. Participation in any supplementary program ormechanism of this nature shall not be required for Participating Manufacturers, nor will it influence or
impact a product’s EPEAT tier level of Bronze, Silver, or Gold.

Other EPEAT Activities

Any program or mechanism designed to encourage adoption of EPEAT Criteria shall not circumvent the
EPEAT Program’s Documentation Review process in any way, and a program of this nature shall notconfer EPEAT-registration to products. The EPEAT Program will develop and issue to key stakeholders
clear communication guidelines and general requirements for any program or mechanism developed toencourage adoption of EPEAT Criteria.

Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 29

Published February 15, 2024 and Effective July 1, 2024

12.0 Force Majeure EventsThe EPEAT Program may issue temporary policy addenda to this document, EPEAT Policy Manual (P65),
to address unforeseeable and extraordinary circumstances that are beyond the control of Participating
Manufacturers or GEC-approved CABs. Such circumstances include but are not limited to natural
disasters, acts of war or terrorism, devastating accidents to a supplier facility, epidemics, or pandemics.

Force Majeure EventsThe EPEAT Program may also issue temporary exemptions during Documentation Review andContinuous Monitoring activities due to force majeure events.

Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 30

Published February 15, 2024 and Effective July 1, 2024

13.0 Revisions and Effective Date
The EPEAT Program reviews EPEAT Policy Manual (P65) on an annual basis to determine if revisions are
required. Revisions to this document are generally published on February 15 and take effect on July 1 ofany given year; however, GEC may, at its sole discretion, identify specific revisions which take effect onanother date before or after July 1.

Revisions and Effective Date

GEC considers programmatic needs when determining the effective date for all revisions and iscommitted to ensuring its decision is transparent and fair for all stakeholders, including Participating
Manufacturers, GEC-approved CABs, and purchasers.

Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 31

Published February 15, 2024 and Effective July 1, 2024

14.0 Supplementary Information
Acronyms
The following acronyms are used in this document.
ANAB: ANSI National Accreditation Board
ANSI: American National Standards Institute
CAB: Conformity Assurance Body

Supplementary Information

CGG: Conformity Guidance Group

References
The following documents are referenced in this document, EPEAT Policy Manual (P65), and are
indispensable for its application. Undated references indicate that the latest edition of the referenced
document applies.
•

EPEAT Conformity Assurance Implementation Manual (P66)•

GEC Conformity Assurance Body Agreement (P33)•

GEC EPEAT License and Participating Manufacturer Agreement (P26)•

ISO 9000 Quality management systems – Fundamentals and vocabulary•

ISO 14020 Environmental labels and declarations — General principles•

ISO 14024 Environmental labels and declarations – Type 1 environmental labelling – Principles
and procedures•

ISO/IEC 17020 Conformity assessment—Requirements for the operation of various types ofbodies performing inspection•

ISO/IEC 17065 Conformity assessment—Requirements for bodies certifying products,
processes, and services

Definitions
The following definitions are referenced throughout this document, EPEAT Policy Manual (P65), and are
indispensable for its application.
Active / Activate: Term that refers to the status of a product that is currently identified in the EPEAT
Registry as meeting EPEAT Criteria (“active”) or the process of using the EPEAT Registry software to
make a product appear in the EPEAT Registry (“activate”).

Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 32

Published February 15, 2024 and Effective July 1, 2024

Annual Renewal: Continuous Monitoring activities conducted by a GEC-approved CAB for a Participating
Manufacturer’s products that have used the Certification Pathway.

Supplementary Information

Antitrust Statement: GEC assigns the highest priority to full compliance with both the letter and thespirit of antitrust laws and therefore a statement is read at the beginning of meetings that are facilitatedby GEC and include industry members to remind participants not to engage in anti-trust behaviors andthat care should be taken to avoid discussions that may suggest or tend to reflect agreements among
competitors as to: price; terms of sale that could impact price; allocation of customers, markets or
territories; bid-rigging; and boycotts or joint refusals to do business with others. Participants must abideby the antitrust statement and avoid any conduct that might violate, or would create the appearance ofa violation of, antitrust laws.
Appeal: For the purposes of this document, EPEAT Policy Manual (P65), an appeal is a written request
for reconsideration of (1) a recommendation or decision based on either procedural or technicalgrounds, or (2) a procedural decision in the development of GEC Criteria that is considered by theappellant to be inconsistent with the policies and procedures. Based on definition of appeal in ISO/IEC
17000 Conformity assessment — Vocabulary and general principles.
Applicant Conformity Assurance Body (Applicant CAB): Conformity Assurance Body whose CAB
Application Form (P40) and all supporting documentation have been received by GEC but has not yet
been granted status as a Provisional Conformity Assurance Body.
Archived / Archive: Term that refers to the status of a product that once appeared in the EPEAT Registry
but no longer meets EPEAT Criteria (“archived”).
Certification Pathway: One of two ways to complete Initial Documentation Review.
Clarification: Formal guidance issued by the EPEAT Program to clarify ambiguous wording in EPEAT
Criteria or in associated conformity assurance requirements. Typically issued to mitigate the potential
for different conformity decisions being made because of the ambiguous language.
Complaint: For the purposes of this document, EPEAT Policy Manual (P65), a complaint is a written
expression of dissatisfaction, other than an appeal, regarding EPEAT-registered products, misuse of the
EPEAT mark or misleading claims about EPEAT product registration, conformity recommendations or
decisions, GEC’s criteria development or revision activities, and/or GEC’s management of the EPEAT
Program. Based on definition of complaint in ISO/IEC 17000 Conformity assessment – Vocabulary andgeneral principles.
Conformance: Conclusion, based on the results of conformity assurance activities, in which the party
being assessed has demonstrated the fulfillment of specified requirements. Based on definition of“decision” in ISO/IEC 17000 Conformity assessment – Vocabulary and general principles.
Conformity Assurance Body (CAB): A body that performs conformity assessment activities, excluding
accreditation. Based on definition of conformity assessment body in ISO/IEC 17000 Conformity
assessment — Vocabulary and general principles.
Conformity Assurance Body Mentored Work Phase (CAB Mentored Work Phase): Period of time where
GEC provides additional support to a newly approved Conformity Assurance Body to increase its

Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 33

Published February 15, 2024 and Effective July 1, 2024

proficiency in EPEAT Program required methods of conformity assurance. During this Phase, GEC
evaluates and approves the Conformity Assurance Body’s conformity decisions made in the Initial
Documentation Review for its initial Participating Manufacturer clients. Because Conformity Assurance
Bodies in this Phase cannot activate products or newly selected Criteria, GEC facilitates these activities
for them.

Supplementary Information

Conformity Guidance Group (CGG): A group of stakeholders with technical expertise, or with access tosuch expertise, that is convened by the EPEAT Program to obtain technical input and feedback on EPEAT
conformity assurance processes, technical requirements in EPEAT Criteria and implementation of
updated and amended EPEAT Criteria. The Conformity Guidance Group is open to all stakeholders but is
not a standing committee and does not hold any decision-making authority.
Conformity Requirements and Guidance Materials: Documents developed by the EPEAT Program
designed to help Participating Manufacturers and GEC-approved CABs further understand EPEAT Criteria
requirements, provide supplementary information and where necessary, provide further details
regarding demonstration of conformance with EPEAT Criteria.
Continuous Monitoring: Ongoing surveillance process for confirming the accuracy of information
identified by Participating Manufacturers in the EPEAT Registry. Continuous Monitoring includes
conformity assurance activities conducted in Continuous Monitoring Rounds and in Annual Renewals.
Continuous Monitoring Round: Discrete period of time where GEC-approved Conformity Assurance
Bodies conduct investigations that have been selected and assigned to them by the EPEAT Program. The
EPEAT Program identifies which products and EPEAT Criteria must be evaluated, specifies the method ofinvestigation, and assigns investigations to Conformity Assurance Bodies.
Correction: Action(s) taken to immediately correct a nonconformance within a specified timeframe.
Corrective Action Plan: Plan, with actions and timelines, developed to eliminate the root cause(s) of anonconformance so as to prevent reoccurrence. Based on definition of corrective action in ISO 9000
Quality management systems – Fundamentals and vocabulary.
Documentation Review: Iterative process used by a GEC-approved Conformity Assurance Body toevaluate a Participating Manufacturer’s Criteria selections by assessing conformance (i.e., assess theintegrity of documentation provided by a Participating Manufacturer and determine if demonstrates
conformance with the Criteria).
EPEAT Audit of Conformity Assurance Body (EPEAT Audit of CAB): Audit conducted by the EPEAT
Program to evaluate a Conformity Assurance Body’s ability to meet EPEAT Program requirements as
identified in EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66).
EPEAT Criteria: Environmental and social requirements developed through a balanced, voluntary
consensus process and adopted by the EPEAT Program. Sometimes referred to as “Criteria” or“Criterion”.
EPEAT Program: A comprehensive voluntary sustainability Type 1 ecolabel that helps purchasers identify
more sustainable technology products and services, which is owned and managed by the Global
Electronics Council (GEC). EPEAT Program staff are employees of GEC. All activities and responsibilities

Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 34

Published February 15, 2024 and Effective July 1, 2024

associated with “EPEAT” or the “EPEAT Program” identified in this document are undertaken by GEC
employees.
EPEAT-registered Product: Product appearing on the EPEAT Registry with active status. Sometimes
referred to as “registered product”.

Supplementary Information

EPEAT Registry: Online repository that identifies more sustainable technology products and services in avariety of different product and service categories that currently meet EPEAT Criteria (referred to as“active”) and that previously met EPEAT Criteria (referred to as “archived”).
EPEAT Trademark: Visual representations of the name EPEAT and stylized marks EPEAT Bronze, EPEAT
Silver, EPEAT Gold, and the EPEAT logo, which Participating Manufacturers are licensed to use
contingent on meeting the terms in GEC License and Participating Manufacturer Agreement (P26).
Active products appearing in the EPEAT Registry have been verified as meeting specific EPEAT
environmental and social Criteria associated with the Marks. By appearing in the EPEAT Registry,
Products are considered to be using the Marks and Participating Manufacturers are not required to use
the Marks on their physical Products. Also known as EPEAT Marks.
Expert Ad Hoc Group: A multi-stakeholder group convened by GEC and serving in an advisory capacity toreview and draft criteria that address sustainability impacts for a technology or service.
Full Criteria Revision: The periodic review and update of EPEAT Criteria that follows the process
outlined GEC Criteria Development Process (P74).
GEC-approved Conformity Assurance Body (GEC-approved CAB): Status of a Conformity Assurance
Body assigned by GEC after successful completion of the Initial EPEAT Audit, including correction of allnonconformances and implementation of all corrective action plans, and successful qualification of atleast two individuals to be Qualified Auditors for each product category in which the Conformity
Assurance Body offers conformity assurance services for the EPEAT Program. GEC-approved CABs may
provide EPEAT conformity assurance services for Participating Manufacturer clients.
Impartiality / Impartial: Presence of objectivity, where objectivity is understood to mean that conflictsof interest do not exist or are resolved so as not to adversely influence conformity assurance andprogrammatic activities. Based on the definition of impartiality in ISO/IEC 17000 Conformity assessment— Vocabulary and general principles and ISO/IEC 17065 Conformity assessment—Requirements forbodies certifying products, processes, and services.
Inconclusive: Result of an Investigation where sufficient and objective evidence has been evaluated but
a conclusion of conformance or nonconformance cannot be determined due to limitations in theevaluation technique(s).
Initial Documentation Review: Documentation Review activities conducted by a GEC-approved
Conformity Assurance Body when a Participating Manufacturer initially registers its first products in the
EPEAT Registry or registers products in a new product category. Initial Documentation Review must becompleted before a Participating Manufacturer’s products can become EPEAT-registered for a productcategory.

Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 35

Published February 15, 2024 and Effective July 1, 2024

Interim Correction: A provisional, consensus-based modification of criteria text to correct an error,
omission, or outdated reference in EPEAT Criteria that is considered in the next relevant criteria revision
process.
Investigation: Activities conducted in a Continuous Monitoring Round where a Participating
Manufacturer’s conformance to EPEAT Criteria is evaluated by a GEC-approved Conformity Assurance
Body.
Limited Criteria Revision: An out-of-cycle revision to EPEAT Criteria that has a narrowly defined scope oraddresses a limited number of criteria.

Supplementary Information

Minor Error: Category assigned to a nonconformance for the following four scenarios:•

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 during a Level 1 Investigation
where the Participating Manufacturer indicated the product has reached end-of-life and is nolonger available on the market, and•A GEC-approved CAB is unable to obtain a product from the market during a Level 2
Investigation where the Participating Manufacturer indicated the product has reached end-oflife and is no longer available on the market.

Nonconformance: Conclusion, based on the results of conformity assurance activities in which the party
being assessed has not demonstrated the fulfillment of specified requirements. Based on definition of“decision” in ISO/IEC 17000 Conformity assessment – Vocabulary and general principles.
Nonconformance Due to CAB Inaction or Delay Not Attributable to the Participating Manufacturer:
EPEAT Program conformity decision regarding a Continuous Monitoring investigation in which the CAB
failed to submit an Investigation Report and/or supporting evidence by the deadline, for a reason not
attributable to the Participating Manufacturer.
Ongoing Documentation Review: Documentation Review activities conducted by a GEC-approved
Conformity Assurance Body after a Participating Manufacturer’s initial products first appear in the
EPEAT Registry for a product category. Ongoing Documentation Review can occur for a variety ofreasons, such as the addition of new products, changes to the EPEAT Criteria selected for EPEATregistered products and addressing nonconformances arising from Continuous Monitoring activities.
Optional Criterion / Criteria: EPEAT Criteria that represent a Participating Manufacturer’s commitment
to innovation in environmental and social performance. Participating Manufacturers have the option to
select one or more Optional Criteria for each EPEAT-registered product. If selected, the Participating
Manufacturers must demonstrate conformance with the Optional Criterion. EPEAT-registered products
are identified by tier as EPEAT Bronze, EPEAT Silver or EPEAT Gold. All products must meet all Required
EPEAT Criteria, and the tiers differentiate products by the percentage of Optional EPEAT Criteria the
products meet.

Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 36

Published February 15, 2024 and Effective July 1, 2024

Outcomes Report: Report published by the EPEAT Program at the conclusion of each Continuous
Monitoring Round to summarize the activities conducted, identify EPEAT Criteria investigated and themethod of investigation, highlight overall conformity results and trends, and identify the products andParticipating Manufacturers that received nonconformances and the corrections made to restore
accuracy of the EPEAT Registry.
Participating Manufacturer: Brand owner that registers products in the EPEAT Program and is
responsible for ensuring ongoing conformance of the products against the EPEAT Criteria selected for
those products. A Participating Manufacturer must retain the services of a Provisional Conformity
Assurance Body or a GEC-approved Conformity Assurance Body to participate in the EPEAT Program.
Sometimes referred to as Manufacturer.

Supplementary Information

Verification Pathway: One of two ways to complete Initial Documentation Review.
Procedural Appeal: Appeal made on the grounds that a decision should be reconsidered because arequired internal or external process was not followed.
Provisional Conformity Assurance Body (Provisional CAB): Status of a Conformity Assurance Body
assigned by GEC after successful evaluation of the submitted CAB Application Form (P40), review ofaccreditations, and full execution of Agreement Between Conformity Assurance Body (P33). Provisional
CABs may solicit business for EPEAT conformity assurance services but may not provide these services
until granted status as a GEC-approved CAB.
Qualified Auditor: CAB personnel who has met and maintained the necessary qualifications and been
approved by the EPEAT Program to provide conformity assurance services for the EPEAT Program.
Sometimes referred to as “Auditor”.
Required Criterion / Criteria: EPEAT Criteria against which a Participating Manufacturer must
demonstrate conformance before a product can become EPEAT-registered and appear in the EPEAT
Registry.
Technical Appeal: Appeal made on the grounds that a conformity assurance recommendation ordecision should be reconsidered because a specified requirement was not interpreted correctly.
Technical Committee: The multi-stakeholder committee serving as the voluntary consensus body for
GEC Criteria and administered by a third-party Criteria Development Organization.
Voluntary Consensus Process: The process used to develop GEC Criteria that aligns with and draws fromsimilar principles for the characteristics of voluntary consensus as defined in ISO 14024 Environmental
labels and declarations – Type 1 environmental labelling – Principles and procedures and in the U.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.

Global Electronics Council

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 37

Published February 15, 2024 and Effective July 1, 2024

Supplementary Information

Document Change History
Issue

Revision

AuthorDescription of Change

ApproverApproval Date

Effective Date

10

Initial release2020 Jan 17

0

Director
EPEAT
Program
SeniorDirector,
Ecolabels andManufacturer
Resources2020 Jan 17

2

Director
EPEAT
Program
SeniorManager,
Ecolabels
andResources2021 Feb 15

2021 July 01

2

1

SeniorManager,
Ecolabels
andResources

SeniorDirector,
Ecolabels andManufacturer
Resources2022 Feb 152022 July 01

2

2

SeniorManager,
Ecolabels
andResources

VP, Ecolabels
andManufacturer
Resources2023 Feb 152023 July 01

Global Electronics Council

Reformatting of document. Restructuring of
document and further clarifying existing
policies. Addition or changes to policies for:Rebranding of EPEAT-registered products;
Use of attestations for Required Criteria incountries where regulations address thecriteria; CAB reporting of discrepancies orconflicts in the understanding of EPEAT
Criteria; Conformity Guidance Group; CAB
Calibration Meetings; EPEAT audits ofprovisional and existing CABs; auditor
qualifications; CAB performance metrics;
annual CAB Summit; grounds fortermination; additional definitions andreferences; acronyms; Force Majeure
Events.
Additional Clarity: Updates to identify why
GEC performs specific actions (4.2.3, 5.6)
and to further clarify policies (4.1, 5.6.1,
5.6.5, 6.2, 6.4.2); Consensus body isTechnical Committee (2.5); Additional
details from P74 (4.2.1.1, 4.2.1.2, 4.2.1.3);
Performance assistance improvement plan
(6.4.2, 6.5); Complaint and appeals (9.0, 9.1,9.2); Re-ordering to reflect the key
components of GEC's Dynamic Criteria
Development Process (4.2); Update toreflect that EPEAT categorizes criteria
revisions and why (4.2.2); Addition ofdefinitions used in other EPEAT documents(12.3). Additions: P74 publicly available(4.2.1); Use of attestations is only
applicable to select Required Criteria in
specific jurisdictions (5.6.5);
Nonconformances outside of Continuous
Monitoring to reflect P66 (5.3).
Additional Clarity: Participation in EPEAT
Program is voluntary (1.0); CABs andParticipating Manufacturers are required tofulfill all applicable requirements in P65(1.0, 6.1, 7.1, 7.2); GEC makes annual
financial statements publicly available (2.3);
Considerations when developing criteria(4.0); Criteria revision details (4.2.3);
Grounds for suspension or termination toalign with P66 (6.5); Sources of funding andimpartiality (8.0); Potential for conflicts ofinterest in criteria development (8.1).
Additions: Section on selection of productcategories (4.2.1); Added new
nonconformance category to address CAB
inaction or delay (5.3); Footnote to address
auditor training requirements for new
criteria from Sustainability Impact Modules(6.2, 6.3); Section on Other EPEAT Activities(11.0); Address impacts of force majeure

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 38

Published February 15, 2024 and Effective July 1, 2024
Issue

3

AuthorDirector,
Ecolabels
andResources

Supplementary Information

2

Revision

Global Electronics Council

Description of Change
events on ongoing conformity assurance
activities (12.0); Section on revisions andeffective date (13.0). Changes: Reference topriority criteria removed (5.2, 13.3); Nameand intent of conformity guidance materials(5.6.2); Removed section on conformity
assurance where equivalent regulatory
requirements exist (5.6.5); Updated
definitions (13.3).
Additional Clarity: Inclusion of additional
stakeholder groups (2.5); EPEAT Registry
review process (3.0, 5.2); Inconclusive
investigation follow-up (5.3); Additional
information on GEC CAB independence(8.2). Additions: Criteria are developed toaddress product function characteristics(4.0); Decisions to terminate CABs are final(7.4). Changes: Alignment with P74 (4.2.3);
Verification Pathway title changed (5.0);
Removal of competence (5.2); Validity ofDocumentation Review (5.2); Corrective
Action Phase name changed to Correction
and Corrective Action Phase (5.3);
Clarification process replaced by
Conformity Guidance Group (5.6, 5.7);
Disclosure of CAB Suspension (6.5), CABs
can appeal CAB Suspension (6.5, 9.2);
Removal of significant labor strikes (12.0);
Updated definitions (14.3).

ApproverApproval Date

Effective Date

Vice
President,
Ecolabels andManufacturer
Resources2024 Feb 152024 Jul 1

EPEAT Policy Manual (P65 Issue 2 Rev 3)
Hard copy print outs of this document are uncontrolled.
© 2020 Green Electronics Council dba Global Electronics Council. All rights reserved.

Page 39