EPEAT Program
Stakeholder Comment Report
October 17, 2022 – December 31, 2022 Comment Period
Proposed Revisions to GEC Criteria Development Process (P74) and First Issue of GEC Selectionof Product Categories (P75)

Introduction
The Global Electronics Council (GEC) released a draft revised version of GEC Criteria Development
Process (P74) and the first issue of GEC Selection of Product Categories (P75) to seek public comment onthese documents from October 17 through December 31, 2022. Stakeholder consultation in the form ofa public comment period is a crucial element of Type 1 ecolabels, and an important component of the
EPEAT Program. Stakeholders were invited to submit written feedback on both documents using the
GEC provided stakeholder comment form. GEC also held a series of virtual information sessions forstakeholders to highlight and provide clarity on key proposed revisions.
GEC thanks all stakeholders for the constructive and thoughtful feedback provided during the publiccomment period and appreciates the time and effort stakeholders took to review the documents andprovide comments.
GEC believes that transparency strengthens the EPEAT Program in an important way. GEC received morethan 70 written comments across both documents from different stakeholder groups which have been
compiled into this Stakeholder Comment Report. The comments are first listed alphabetically by the last
name of the individual providing comments, and then listed numerically by section in the document.
GEC reviewed and considered all stakeholder comments when making final revisions to GEC Criteria
Development Process (P74) and GEC Selection of Product Categories (P75).

Overview of Received Comments: GEC Criteria Development Process (P74)
Editorial comments and requests for clarity
Stakeholders suggested text edits and additions for clarity on a variety of topics, including for instance,
the role and composition of Expert Ad Hoc Groups, and details regarding the second stakeholder
consultation period for draft criteria. GEC incorporated many of these requested revisions. Somerequests were considered too specific for a policy document; for example, adding references to specific
URLs.
Overview Graphic of Dynamic Criteria Development Process
Stakeholders requested changes to Figure 1 in Section 2.0, which provides an overview of GEC’s
Dynamic Criteria Development Process. GEC agreed with most of the comments and proposed changes,
which presented an opportunity to reflect on whether the graphic aligns with current practice andfuture goals. As a result, Figure 1 was modified to highlight the goal of harmonization with best practices
and existing standards in the State of Sustainability Research. For the Voluntary Consensus Process,

Global Electronics Council

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EPEAT Program Stakeholder Comment Report
Proposed Revisions to GEC Criteria Development Process (P74) and First Issue of GEC Selection of Product Categories (P75)

consideration of “security and data privacy implications” was removed. While EPEAT Criteria may
address these issues (e.g., secure data deletion), inclusion in this graphic implied a greater emphasis onthese issues over other sustainability topics addressed by EPEAT Criteria.
Alignment with ISO 14024 for Type 1 Ecolabels and elements of voluntary consensus process
Multiple comments expressed concerns that the GEC Criteria Development Process does not align withthe principles of voluntary consensus outlined in the Office of Management and Budget (OMB) Circular
A-119 and similar elements in ISO 14024 Environmental labels and declarations – Type 1 environmental
labelling – Principles and procedures, with a particular focus on openness and transparency.
GEC consulted with practitioners of voluntary consensus processes, and confirmed that the GEC
Technical Committee process, and the resulting Criteria, meet the principles of voluntary consensus. NSF
administers GEC Technical Committees using the same practices and principles of voluntary consensus it
uses when developing ANSI standards. The EPEAT Program, including its Criteria Development Process,is also recognized as a Type 1 Ecolabel meeting the requirements of ISO 14024, by both ANAB and the
Global Ecolabelling Network (GEN).
While GEC strives to apply the principles of voluntary consensus throughout the criteria development
process, voluntary consensus is not required for all activities that feed into the Technical Committee,
which is the consensus body. All activities are open and transparent to interested parties through public
consultation (e.g., State of Sustainability Research, Full Criteria Document) or participation (e.g., Expert
Ad Hoc Groups, Voting Member or Observer on Technical Committee).
State of Sustainability Research
GEC received comments about authorship, approval, and content of the State of Sustainability Research.
The purpose of the State of Sustainability Research is to compile publicly available data on sustainability
impacts, best practices to mitigate these impacts, and relevant standards, and based on thiscompilation, identify topics and potential direction for criteria development. State of Sustainability
Research is a resource for use by Expert Ad Hoc Groups and the Technical Committee, and for thisreason, its development does not take place as part of the voluntary consensus process.
As the owner of the EPEAT ecolabel, GEC is responsible for documenting data on life cycle impacts asjustification for criteria and making this available for public comment. Where GEC has the technicalexpertise, it takes the lead in preparing the State of Sustainability Research. If GEC lacks expertise or
determines that others are better suited to prepare the report, GEC may contract with experts in
preparation of the research. The draft State of Sustainability Research is made available for a 60-day
public comment period, affording all interested stakeholders with the opportunity to review, provide
comments, and submit additional data or sources of information. Ultimately, the State of Sustainability
Research is a resource, providing background and justification for criteria. It is the voluntary consensus
process – the Technical Committee – that ultimately makes decisions on criteria.
Criteria Drafting
GEC received comments regarding aspects of Section 2.2, which addresses concepts related to criteria
drafting, including verification requirements and the identification of Required and Optional Criteria.
GEC provided additional clarity in response to several comments, including for instance, clarifying that
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Proposed Revisions to GEC Criteria Development Process (P74) and First Issue of GEC Selection of Product Categories (P75)

the Technical Committee develops and/or approves verification requirements and identifies evidence
necessary to demonstrate conformance with the criterion requirements.
Commenters requested several additions to Section 2.2.3, Required and Optional Criteria, which GEC did
not incorporate as the changes would circumvent important program elements. Some of thesecomments include:•

A request for GEC to add an option for the Technical Committee to designate specific optional
criteria as “required” to obtain EPEAT Gold recognition. However, this approach would alter the
purpose of Optional Criteria and the structure of EPEAT, which is to differentiate products basedon the percentage of criteria met, incentivize innovation, and promote continuous
improvement. An alternative approach is for the Technical Committee to consider a higher
points value for criteria to provide manufacturers with an incentive to pursue conformance withthe criterion.

•

A suggestion for GEC to specify that any new topic or criteria should be designated as optional,
when first introduced into EPEAT and remove criteria that are no longer value-added to ensurethat the number of criteria do not become unwieldy. In Table 1, GEC provides guiding Principles
for Criteria, outlining multiple factors that should be taken into account by the TechnicalCommittee when developing and reviewing criteria, including new criteria or existing criteria,such as environmental impact, current best practices and ability of the market to meet thecriterion

A comment suggested that GEC consider a process to review criteria under development acrossTechnical Committees working on different sustainability issues to ensure appropriate emphasis on
topics (e.g., number of criteria and optional points) and maximize efficiencies for manufacturers, while
addressing all key hotspots of the product life cycle. GEC appreciates this sensitivity and is open tosuggestions on how to accomplish this, while respecting and adopting the outcome of each voluntary
consensus process.
There was a request to add a new section for EPEAT Program Terms with an accompanying process for
public review and approval by voluntary consensus. GEC agrees with providing an opportunity for public
review and comment and added this topic to the agenda for the February 2023 Conformity GuidanceGroup meeting. It is worth noting that these terms were also subject to public comment during the firstpublic comment periods for Climate Change Mitigation, Sustainable Use of Resources, and Chemicals ofConcern. Comments received through these public comments were considered and the definitions
modified. It is these modified definitions that were distributed for further review and comment throughthe Conformity Guidance Group.
Criteria Development Organization and Management of Voluntary Consensus Process
In response to comments, GEC included additional details in Section 2.5 on the selection of Criteria
Development Organizations that GEC partners with for management of the Voluntary Consensus
Process, to address conflicts of interest or undue influence of any one stakeholder group. Additionally, it
was clarified that while GEC may provide technical support to the Criteria Development Organization, allfinal decisions regarding criteria are made by the Technical Committee, following the Criteria
Development Organization’s procedures for voluntary consensus.

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Proposed Revisions to GEC Criteria Development Process (P74) and First Issue of GEC Selection of Product Categories (P75)

One commenter noted that the Criteria Development Organization may not be safeguarding against useof commercial terms. GEC requested that the Criteria Development Organization undertake a legal
review of possible commercial terms and advise the Technical Committees if modifications are needed
to any criteria in order to avoid commercial terms. GEC also requested that the Criteria Development
Organization takes steps, as needed, to ensure quorum is met in the Technical Committee process.
A couple of comments questioned whether the Criteria Development Organization was adequately
addressing all public comments and following procedures to notify public commenters of the dispositionof their comments. GEC reviewed the actions of the Criteria Development Organization to date and notethat procedures are being followed and meet the requirements of voluntary consensus. [It is possiblethat these comments were submitted before the Technical Committee process had progressed to thispoint in the process.] The Technical Committee is given the opportunity to discuss all comments andproposed resolutions. Responses to all public comments and Technical Committee ballot comments areprovided to the commenter with notice of the right to appeal. In addition, the disposition of all TechnicalCommittee ballot comments is provided to the Technical Committee for consideration and opportunity
to change their ballot after considering comments.
Technical Committee
GEC received comments and suggestions regarding various aspects of Technical Committees, including arequest to add a separate (fifth) category for suppliers to the list of stakeholder interests whose
perspectives and representation are sought in the criteria development process. GEC recognizes thatsustainability criteria can have a big impact on suppliers and, as such, suppliers are explicitly covered in
the “Other Industry” stakeholder category, which is one of the four stakeholder categories. Adding aseparate (fifth) category for suppliers would increase representation of industry on the consensus body
(Technical Committee) from 50% to 60% of stakeholders, which would not adhere to the principle ofvoluntary consensus including a balance of interests.
Continuous Maintenance
GEC received multiple comments to clarify various aspects of the Continuous Maintenance process,outlined in Section 2.6. In 2023, GEC plans to further refine and develop the continuous maintenanceprocess, and consult with stakeholders as necessary, before releasing proposed revisions in October
2023 as part of the annual revision process.
Conflict of Interest and Complaints and Appeals
In response to comments, additional details were added to Section 2.8 to delineate a specific funding
threshold that triggers disclosure of funding sources throughout the criteria development process.
Additional procedural details were also added to Section 2.7 to identify that the complainant orappellant is informed of the name and title of the individuals serving on the Committee and clarified
that Complaints and Appeals Committee members may include individuals who are not GEC staff.

Global Electronics Council

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Proposed Revisions to GEC Criteria Development Process (P74) and First Issue of GEC Selection of Product Categories (P75)

Overview of Received Comments: GEC Selection of Product Categories (P75)
Editorial comments and requests for clarity
Most of the stakeholder comments on P75 suggested text edits and additions for clarity. GEC
incorporated most of these requested revisions. Additions to the text include, for example, that thebusiness case considers life cycle sustainability impacts and manufacturers/providers ability to address
sustainability impacts.
In response to comments, GEC also added further details on notification and feedback mechanisms. The
document now states that if a stakeholder requests that GEC consider a new product category, thestakeholder will be informed of GEC’s decision to pursue a product category, as well as not to pursue thecategory. GEC will also seek feedback from the Advisory Council.
Confidential Information
Section 4.1 describes the content of the publicly available Product Category Proposal, based on the key
findings of the internal Business Case. At the request of a stakeholder, GEC added a statement that if
confidential business information is omitted from the Product Category Proposal, a statement isincluded regarding the nature of the information withheld.

Publication of Revised Documents
GEC published the revised version of GEC Criteria Development Process (P74) on February 15, 2023, andnew requirements take effect on July 1, 2023. GEC published the first edition of GEC Selection of
Product Categories (P75) on February 15, 2023, and it takes effect on the same date. Both documents
are available on the EPEAT Registry, and through an EPEAT Registry account under “Resources”, or uponrequest.
Please direct any questions on this Stakeholder Comment Report to EPEAT@GEC.org.

Global Electronics Council

Published February 15, 2023

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EPEAT Program Stakeholder Comment Report
Proposed Revisions to GEC Criteria Development Process (P74) and First Issue of GEC Selection of Product Categories (P75)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to GEC Criteria Development Process (P74) and the First Issue of GEC Selection of Product Categories (P75)
Comments are first listed alphabetically by the last name of the individual providing comments and then listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Topic

Comment

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P74

N/A

GeneralThe concept of EPEAT Program terms (such as “product”) has been discussed in several TechnicalCommittees but not done in the TCs. ITI suggests that the Criteria Development Process add asection on EPEAT program terms, with a process for public review and comment and a committee toprovide a vote on these.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P74

1.0

Consistency with OMB
Circular A-119

ITI has significant concerns that the Dynamic Criteria Development Process is not consistent with therequirements of OMB Circular A-119. In particular the process is lacking in areas of openness and due
process. Examples of these concerns are outlined in comments below and in multiple discussions
with GEC and NSF. Section 1 either needs to remove the references OMB Circular A-119 or GEC needs
to modify its processes to actually meet the requirements of the Circular.
Specifically, ITI has concerns about these sections of the Circular:
OMB Circular A-119 Section 2e(i) Openness: The procedures or processes used are open to interested
parties. Such parties are provided meaningful opportunities to participate in standards development
on a non-discriminatory basis. The procedures or processes for participating in standards
development and for developing the standard aretransparent.
A-119 Section 2e(iii) Due process: Due process shall include documented and publicly available
policies and procedures, adequate notice of meetings and standards development, sufficient time toreview drafts and prepare views and objections, access to views and objections of other participants,
and a fair and impartial process for resolving conflicting views.

Cleet, Chris

Information Technology Industry
Council (ITI)

Global Electronics Council

December 31, 2022

P74

2.0

Key Goals

Published February 15, 2023

The document notes that criteria are “developed with and adhering to the principles of transparency
and voluntary consensus, including a process that is open without discrimination to interested parties
and representing a balance of stakeholder interests.” However, in no meaningful way is the process
open to all interested parties. A single public consultation on the draft criteria before they enter the“consensus” process cannot be construed as “open participation.” Membership in all criteria
development groups: the Expert Ad-Hoc Groups and the Technical Committee, is closed only tomembers invited by the GEC. This is not the spirit or letter of “open without discrimination.”

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EPEAT Program Stakeholder Comment Report
Proposed Revisions to GEC Criteria Development Process (P74) and First Issue of GEC Selection of Product Categories (P75)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to GEC Criteria Development Process (P74) and the First Issue of GEC Selection of Product Categories (P75)
Comments are first listed alphabetically by the last name of the individual providing comments and then listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P74

2.0

Topic

Comment

Restart Process

As we note below, the State of Sustainability Research is the output of a single stakeholder in theprocess and must be treated as such. Further, the quality of the research and writing in the SOSRs
has been to date severely lacking. The SOSRs published to date have shown little to nounderstanding of existing criteria or draft criteria or regulations, and in most cases, therecommendations of the SOSR have reflected neither the current best practices of manufacturers nor
an understanding of regulations or criteria in development. We further suggest that the SOSR reflect
both purchaser and manufacturer priorities as the manufacturer is the only entity that is actuallyrequired to do anything to conform to EPEAT criteria.
Suggested changes for first box:-

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P74

2.0

Restart Process

Reflect purchaser and manufacturer priorities
Identify existing criteria (both published and draft) for harmonization
Understand the underlying regulatory landscape and look to harmonize with leading
regulations

VCS Development Process box: it is not clear how security and data privacy are an sustainability issue,
other than as a potential limit to repair and recycling of devices. Security and data are not part ofany of the UN Sustainability Development Goals and no authoritative sources place it there. There
are several NGOs and standards that are better placed than GEC and EPEAT to address data security
and privacy, and it is not clear what value GEC would bring to addressing these issues. Additionally,
privacy and data security require different expertise than existing ESG criteria, which neither the GEC
nor current stakeholders have.
Suggested change (for last bullet in middle square):-Global Electronics Council

Published February 15, 2023

Consider security and data privacy implications as they relate to repair and circularity ofdevices

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EPEAT Program Stakeholder Comment Report
Proposed Revisions to GEC Criteria Development Process (P74) and First Issue of GEC Selection of Product Categories (P75)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to GEC Criteria Development Process (P74) and the First Issue of GEC Selection of Product Categories (P75)
Comments are first listed alphabetically by the last name of the individual providing comments and then listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P74

2.0

Topic

Comment

2nd stakeholder
comment period

The document notes that a “second stakeholder comment period may also occur…”. A second
stakeholder comment period should be the default option and GEC can note conditions under which
a second stakeholder comment period may be shorter if no substantive changes are made.
Suggested change (for bottom of page 3):“A second 30-day stakeholder comment period may also will occur to solicit feedback on changes
made to the Full Draft Criteria Document. The Technical Committee may determine that a shorter
second comment period is warranted if it determines that changes made to the Full Draft Criteria
editorial or unsubstantial enough to not need a full second review.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P74

2.1

State of Sustainability
Research

The SOSR is the input of a single stakeholder in the process – the GEC. The SOSRs published to datehave not been well developed nor robust documents. As such, they should not be “the foundation
for the development and revision of criteria.” At best, the SOSR should serve as a resource for the
Ad-Hocs and Technical Committee discussions.
Suggested change:
The data and analysis of the State of Sustainability Research serves as the foundation for thedevelopment and revision of criteria a resource for further discussion in the Expert Ad-Hoc Groups
and Technical Committee.

Cleet, Chris

Information Technology Industry
Council (ITI)

Global Electronics Council

December 31, 2022

P74

2.1

State of Sustainability
ReportThis first step in the criteria development process is not based on a consensus decision-making
process that is open to all interested stakeholders. Lack of openness in this stage prevents all
interested stakeholders from participating equally in the criteria development process. It also risks
creating criteria favored by one stakeholder or stakeholder category to the exclusion of others. Whilepublic consultation is a critical part of this development stage, it is not a substitute for a voluntary
consensus process. GEC should allow all interested stakeholders to participate in the development of
the SOSR and utilize consensus-based processes to finalize this report.

Published February 15, 2023

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EPEAT Program Stakeholder Comment Report
Proposed Revisions to GEC Criteria Development Process (P74) and First Issue of GEC Selection of Product Categories (P75)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to GEC Criteria Development Process (P74) and the First Issue of GEC Selection of Product Categories (P75)
Comments are first listed alphabetically by the last name of the individual providing comments and then listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Topic

Comment

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P74

2.1

State of Sustainability
Research

The document notes that “the GEC may contract with third parties for research and data analysis
assistance during this step.” However, the GEC has gone well beyond this allowance and contracted
the drafting of the SOSR to third parties. The parties that GEC has contracted with for thedevelopment of SOSRs have been clearly partisan and do not present a well-balanced picture of thestate of sustainability in an area. The GEC should follow their own processes, restricting thecontracting to research and data analysis (i.e., not drafting) or either disallow the use of third parties
or provide a set of criteria for how third parties should approach the development of the SOSR.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P74

2.2

Criteria Drafting

As noted above, the SOSR is the input of a single stakeholder and should only serve as a resource forfurther discussion by the Ad-Hocs and TCs.
Suggest change for Table 1 line 1:
Criteria address priority sustainability impacts, as identified in the State of Sustainability Research,and throughout the life cycle of products and services, inclusive of the supply chain.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P74

2.2

Criteria DraftingThis section is not clear in indicating how discussions are managed and decisions are made; and who
is drafting the criteria, compiling inputs from different sources, resolving overlaps or conflicts in the
inputs received, and deciding when to form the Expert Ad Hoc Groups and what they will work on.
The ISO 14020 standard at Section 4.9.1 states: “The process of developing environmental labels anddeclarations should include an open, participatory consultation with interested parties. Reasonable
efforts should be made to achieve a consensus throughout the process.” (emphasis added). The lackof consensus and the limitations on participating in the decision-making at all stages of the processcontravenes ISO requirements and voluntary consensus principles. GEC should use consensus-based
processes—open to all interested stakeholders—for all stages of the development and progression of
criteria.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P74

2.2.1

Criteria Drafting
Principles

New concepts, especially product criteria, should start as optional criteria. For example, the concept
of using recycled plastics started as optional and then moved to required. Suggest that this concept
be added in Principle 3 or as a stand-alone concept.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P74

2.2.1

Criteria Drafting
Principles

A principle of removing criteria that are no longer value-added should be placed here to ensure thatthe criteria modules do not become unwieldy.

Global Electronics Council

Published February 15, 2023

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EPEAT Program Stakeholder Comment Report
Proposed Revisions to GEC Criteria Development Process (P74) and First Issue of GEC Selection of Product Categories (P75)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to GEC Criteria Development Process (P74) and the First Issue of GEC Selection of Product Categories (P75)
Comments are first listed alphabetically by the last name of the individual providing comments and then listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Topic

Comment

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P74

2.2.1

Draft Criteria

The GEC is a single stakeholder in the criteria development process and as such should not be
specifically called out.
Suggest combining the second and third bullets at the end of the section to:
Submissions from stakeholders, including GEC staff or partner organizations.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P74

2.2.2

Selection of
Verification
Requirements

This section should make it clear that verification requirements cannot add new requirements to acriterion. For example, if the criterion does not call for testing, the verification cannot call for test
reports. The criterion, not the verification requirements, should list standards (for example, ENERGYSTAR or ISO 14001) or required tests (such as material testing) that allow for meeting the criterion,and verification is limited to the evidence necessary to show conformity to that criterion.
Suggested change:
Verification requirements cannot add new requirements to a criterion and align with all requiredelements of the criterion, and to the extent applicable, specify published test methods, international
standards (e.g., ISO, IEC) and certifications, regional and national standards (e.g., EU CEN, US ENERGYSTAR), and recognized voluntary programs.

Cleet, Chris

Information Technology Industry
Council (ITI)

Global Electronics Council

December 31, 2022

P74

2.2.2

Selection of
Verification
Requirements

Published February 15, 2023

Uncertainty exists for all measurements and testing. Verification requirements should note that
there is uncertainty in any quantitative measurement.

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EPEAT Program Stakeholder Comment Report
Proposed Revisions to GEC Criteria Development Process (P74) and First Issue of GEC Selection of Product Categories (P75)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to GEC Criteria Development Process (P74) and the First Issue of GEC Selection of Product Categories (P75)
Comments are first listed alphabetically by the last name of the individual providing comments and then listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Topic

Comment

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P74

2.3

Expert Ad Hoc Groups

According to this section, GEC is not bound by the voluntary consensus principles of ensuring balanceand openness in the Expert Ad Hoc Groups. While this document mentions that “GEC seeks balanced
representation from the following stakeholder categories,” balance is required if GEC is to align withvoluntary consensus characteristics articulated in Table 3 of the GEC Criteria Development Process
document and OMB Circular A-119. There is no indication of how balance is achieved nor discussionof consensus-based processes for this critical stage of development. Expert views should be sought,
discussed, and refined based on real world practices, using these principles, in order to improve theultimate quality of the resulting deliverables. There is no voting or other procedure set forth for how
to arrive at consensus or resolve objections in the absence of unanimity. (that this exists in the NSF
doc is insufficient for the entirety of the process prior to the TC where in the ‘final draft criteria’ aredeveloped). Sending summaries of Expert Ad Hoc Group discussions to the Technical Committee (asSection 2.3 contemplates) is an inadequate substitute for real-time debate, deliberation and iterative
drafting amongst all interested experts. As with Section 2.2, GEC should use consensus-based
processes—open to all interested stakeholders—to develop and progress criteria developed by theExpert Ad Hoc Groups.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P74

2.3

Expert Ad Hoc Groups

The Ad Hoc Groups make the decisions to which options and criteria are sent to the TechnicalCommittee. The middle paragraph on page 7 should be changed to reflect this:Suggested change:
The Expert Ad Hoc Group GEC may choose to forward 2 or more criteria options…

Global Electronics Council

Published February 15, 2023

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EPEAT Program Stakeholder Comment Report
Proposed Revisions to GEC Criteria Development Process (P74) and First Issue of GEC Selection of Product Categories (P75)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to GEC Criteria Development Process (P74) and the First Issue of GEC Selection of Product Categories (P75)
Comments are first listed alphabetically by the last name of the individual providing comments and then listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P74

2.3

Topic

Comment

Expert Ad Hoc Groups

ITI and other stakeholders in the Ad Hoc Groups have seen decisions made on criteria outside theGroup. While it is in good faith to have offline discussions of criteria and how to resolve issues, these
discussions must be taken to the Ad Hoc for final discussion and consensus prior to moving on with aproposal. Section 2.3 or 2.4 needs to identify a process by which all participants in an Ad Hoc Groupare involved in any final recommendations, especially if there is no consensus among the group.
Suggested change: Add to the second to last paragraph in section 2.3:
Members of an Expert Ad Hoc Group are allowed to hold discussions among small groups ofstakeholders and/or GEC staff, but all proposals for recommendations to the Technical Committee
must be discussed at a meeting of the Expert Ad Hoc Group.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P74

2.3.1

Expert Ad Hoc Group
Membership

Since suppliers are the entities that must (by definition) supply the parts and requested information
to conform with EPEAT, suppliers should be considered to be their own stakeholder category insteadof “other industry”. Suggest creating another Stakeholder Category for Suppliers to Manufacturers
and their trade associations.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P74

2.4

Full Draft Criteria
Document“Recommendations” seems too weak of a word for what the Ad-Hocs are designed to do. Further,
the GEC should not have the authority to unilaterally change outcomes from the Ad-Hocs.
Suggested changes:
GEC compiles a comprehensive Full Draft Criteria Document based on the recommendations
proposals of the Expert Ad Hoc Groups

Global Electronics Council

Published February 15, 2023

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Proposed Revisions to GEC Criteria Development Process (P74) and First Issue of GEC Selection of Product Categories (P75)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to GEC Criteria Development Process (P74) and the First Issue of GEC Selection of Product Categories (P75)
Comments are first listed alphabetically by the last name of the individual providing comments and then listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P74

2.4

Topic

Comment

Full Draft Criteria
Document

If the output of the Ad Hoc Group does not reflect the State of Sustainability Research the GEC cannot
unilaterally add this to the plan for the Technical Committee.
Suggested changes:
GEC confirms that reviews the Full Draft Criteria Document to addresses the environmental andsocial impacts identified in the State of Sustainability Research. If gaps are identified in the Full Draft
Criteria Document, GEC prepares a plan for addressing the gaps and provides it to the may note thisfor consideration by the Technical Committee.
(and in next paragraph)
This summary may also identify identifies whether an Expert Ad Hoc was unable or chose not todevelop a recommendation proposal to address an impact identified in the State of Sustainability
Research, and why.

Cleet, Chris

Information Technology Industry
Council (ITI)

Global Electronics Council

December 31, 2022

P74

2.4

Full Draft Criteria
Document

Published February 15, 2023

As we note in our comments to Section 2.3, the Full Draft Criteria Document should also be
developed through an open voluntary consensus process. However, the process is that GEC alone
compiles the Full Draft Criteria Document based on the recommendations of the Expert Ad HocGroups and submits it to the Technical Committee as the starting point for the TC’s deliberation.
GEC’s dominance over this significant stage of criteria development means that other interested
parties are denied any meaningful opportunity to participate in the drafting, gap analysis,
identification of key discussion points and areas of disagreement, and conclusions about why some
impacts could not be addressed. Further, as we note below, all interested stakeholders should beallowed to contribute and participate in the Technical Committee, including voting or other processes
that are designated for resolving objections.

Page 13 of 27

EPEAT Program Stakeholder Comment Report
Proposed Revisions to GEC Criteria Development Process (P74) and First Issue of GEC Selection of Product Categories (P75)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to GEC Criteria Development Process (P74) and the First Issue of GEC Selection of Product Categories (P75)
Comments are first listed alphabetically by the last name of the individual providing comments and then listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P74

2.5

Topic

Comment

Criteria Development
Org

This section describes the voluntary consensus process that should apply to all stages of GEC criteria
development, not just one late stage. It is in GEC’s interest in advancing “credible and objective
criteria” to itself reflect the virtues it describes in its own processes, including: managing a voluntary
consensus processes of diverse stakeholders; maintaining impartiality; documented procedures that
address and adhere to the five characteristics of voluntary consensus; procedures in place toobjectively select participants; safeguards against anti-competitive behaviors; rules to avoid the useof commercial terms and other requirements that may restrict trade and competition; and arequirement that minutes be taken, approved and made publicly available.
There is no articulated process for how proposals or counter-proposals are made, how decisions are
made, when votes or straw polls might be appropriate, or even how matters are put onto a meeting
agenda.
Even within this section that focuses on consensus, there are processes that don't achieve consensus.
For example, in Section 2.5.1.1, the Technical Committee should address public comments throughTechnical Committee consensus and should reach consensus on final criteria. Similarly the end of
Section 2.5.2 should make clear that the Criteria Development Organization prepares a comment
resolution report and notifies public commenters of the resolution of their comments based onconsensus of the Technical Committee. Further, it is unclear why GEC is consulted on processing ofTechnical Committee membership applications if the Criteria Development Organization (CDO)
ordinarily would process membership applications independently. GEC interference, or even a
perception of interference, could impact the CDO’s satisfaction of voluntary consensus principles.
GEC should make clear, in the GEC Criteria Development Process document, that CDOs must operate
independently from GEC and that GEC shall not interfere in CDO processes. Rather than prohibit
Observers from speaking, the CDO should merely prohibit stakeholders who have selected to be an
Observer (over a participatory role) from voting.

Global Electronics Council

Published February 15, 2023

Page 14 of 27

EPEAT Program Stakeholder Comment Report
Proposed Revisions to GEC Criteria Development Process (P74) and First Issue of GEC Selection of Product Categories (P75)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to GEC Criteria Development Process (P74) and the First Issue of GEC Selection of Product Categories (P75)
Comments are first listed alphabetically by the last name of the individual providing comments and then listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Topic

Comment

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P74

2.5

Voluntary Consensus
Process and TechnicalCommittee
Participation

In accordance with ISO 14024 section 6.2, the ecolabeling body shall implement a consultation
mechanism that facilitates full participation of interested parties. As such, full membership in theTechnical Committee must be made available to all interested stakeholders. The TechnicalCommittee may implement measures to ensure balanced stakeholder participation after ensuring fullparticipation of interested stakeholders. Several specific changes to the Criteria Development
Process are proposed below.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P74

2.5

Page 9To allow for all interested members to participate:
Suggested Changes:
The Criteria Development Organization must also have procedures in place to objectively select allow
interested stakeholders to become Technical Committee members, safeguard against anticompetitive behaviors, and avoid the use of commercial terms and other requirements that may
restrict trade and competition. If necessary, the Criteria Development Organization may implement
measures to ensure balanced representation of Stakeholder Categories.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P74

2.5

Voluntary Consensus
Process

While there is a definition of “Criteria Development Organization” in Section 5.2, there is no
description in this document of how this organization is identified, who chooses the CDO and what
the CDO does or how it manages its processes. ITI suggests that sections be added to this document
to address this.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P74

2.5

Criteria Development
Org

Currently NSF is not safeguarding against commercial terms. Criteria related to warranties,
manufacturer spend on suppliers and wages are being developed, most of which need at least acursory commercial term review. ITI suggests that GEC work with NSF to review their commercial
terms guidance.

Global Electronics Council

Published February 15, 2023

Page 15 of 27

EPEAT Program Stakeholder Comment Report
Proposed Revisions to GEC Criteria Development Process (P74) and First Issue of GEC Selection of Product Categories (P75)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to GEC Criteria Development Process (P74) and the First Issue of GEC Selection of Product Categories (P75)
Comments are first listed alphabetically by the last name of the individual providing comments and then listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P74

2.5.1.1

Topic

Comment
To allow for all interested members to participate:
Suggested changes:
GEC seeks individuals with expertise on the topics under consideration by the allows all parties
interested in a particular Technical Committee to participate on the consensus body.
The Criteria Development Organization processes applications for Technical Committee membership,in consultation with GEC. The Criteria Development Organization is responsible for ensuring thatinterested parties are able to participate in the final selection of Technical Committee Members.
Delete the paragraph on page 10 beginning with “Technical Committee Members are selected…”

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P74

2.5.1

TC Participation

TCs are having issues with achieving quorum at TC meetings. This is because invited voting members
are not attending meetings. Most standards processes have attendance and participation
requirements that members must follow to remain voting members of the committee. ITI suggests
adding typical for SDOs attendance (such as must attend 3 of 4 meetings) and voting (must vote in all
virtual ballots) requirements and replace members who fall off of the TC.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P74

2.5.1

TC Participation

There are many examples in the current TC process in which none of the TC members are experts on
the topic being discussed, and in some cases are making incorrect statements. Observers, despite
having expertise on the topic at hand, are not allowed to speak up even when the TC members aresaying they are not knowledgeable about the topic being discussed, or TC members are making
incorrect statements, and/or comments are being misinterpreted. A more open process would lead
to better outcomes in developing the criteria.

Global Electronics Council

Published February 15, 2023

Page 16 of 27

EPEAT Program Stakeholder Comment Report
Proposed Revisions to GEC Criteria Development Process (P74) and First Issue of GEC Selection of Product Categories (P75)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to GEC Criteria Development Process (P74) and the First Issue of GEC Selection of Product Categories (P75)
Comments are first listed alphabetically by the last name of the individual providing comments and then listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Topic

Comment

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P74

2.5.1.2

TC Observers

There are benefits to allowing multiple observers including transparency of the process and allowing
stakeholders to bring in subject matter experts. It is not clear what benefits limiting observers gives.
The TC process should not limit observer participation.
Suggested changes:
Technical Committee Observers are limited to one representative from an organization. Organizations
that have a representative with Technical Committee Member status are not eligible to have aTechnical Committee Observer. All Observers must sign an Observer Agreement before receiving
Technical Committee documents or attending meetings. The names and affiliations of all TechnicalCommittee Observers are publicly available.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P74

2.5.2

Public Consultation

The default process should be to provide a second public consultation, unless the TC decides thatthey did not make substantive changes and a second consultation is not necessary.
Suggested changes:
If the Technical Committee makes substantive modifications to the Full Draft Criteria Document, theCriteria Development Organization may shall provide stakeholders with a second opportunity toprovide comments, unless the Technical Committee decides that it had not made substantive
modifications to the Full Draft Criteria Document and a second comment period is not necessary. The
second public consultation is limited to changes to the document and must be open for no less than
30 days. GEC notifies stakeholders of the public consultation periods or an explanation of why theTechnical Committee believes there is no need for a second public consultation through GEC
newsletters and announcements.

Global Electronics Council

Published February 15, 2023

Page 17 of 27

EPEAT Program Stakeholder Comment Report
Proposed Revisions to GEC Criteria Development Process (P74) and First Issue of GEC Selection of Product Categories (P75)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to GEC Criteria Development Process (P74) and the First Issue of GEC Selection of Product Categories (P75)
Comments are first listed alphabetically by the last name of the individual providing comments and then listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Topic

Comment

2.5.2

Public Consultation

We suggest not to limit the scope of 2nd public consultation only to the change to the document
through TC. The criteria structure is very complicated and change in the description in certain portion
would affect to the interpretation of other portion which are not changed.
Here is the proposed revision;
If the Technical Committee makes substantive modifications to the Full Draft Criteria Document, theCriteria Development Organization may provide stakeholders with a second opportunity to provide
comments. The second public consultation is limited to changes to the document and must be open
for no less than 30 days.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P74

2.5.2

Public Consultation

The Technical Committee should either consider all comments submitted through the public
consultation process or be informed at the beginning of the TC process if the GEC and CDO have notdecided to address certain public comments in the TC. As currently written, the process requires that
the TC consider ALL comments submitted. This is not what is happening at the TCs. If the GEC
wishes to continue not addressing all comments submitted, the final paragraph of this section willneed revision.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P74

2.5.2

Public Consultation

Simply publishing a comment resolution document as noted in the last sentence of this section is
insufficient to adequately address comments. For example, ANSI Essential Requirements at Section
2.6 require that SDOs respond in writing to all objections made as part of public comments or votes
with “the disposition of the objection and the reasons therefor,” plus notice that an appeals process
exists. ITI suggests developing a process to explicitly address and provide per-comment disposition.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P74

2.6

Continuous
Maintenance

A full revision of the criteria should be done longer than every 3 years. Establishing criteria takes alengthy amount of time and implementing programs can take up 24 months to 48 months dependingon the product. Thus, this can create undue burden in manufacturers given the timelines for productdevelopment. If updated every 3 years, manufacturers would constantly be pursuing new criteria,
especially as it relates to optional criteria when manufactures want to pursue EPEAT silver and gold
levels. Full revisions should be done every 5 years.

Global Electronics Council

Published February 15, 2023

Page 18 of 27

EPEAT Program Stakeholder Comment Report
Proposed Revisions to GEC Criteria Development Process (P74) and First Issue of GEC Selection of Product Categories (P75)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to GEC Criteria Development Process (P74) and the First Issue of GEC Selection of Product Categories (P75)
Comments are first listed alphabetically by the last name of the individual providing comments and then listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P74

2.6

Topic

Comment

Continuous
MaintenanceThis section should also include considerations for how and why an update to a criterion would bedelayed and/or not updated upon request. Examples may be:-

The proposed criterion is new and would require significant discussion
Whether a criterion is no longer adding value and should be removed

Suggest adding these bullets to section 2.6
Suggested change:
Adding to the end of the 1st paragraph on an ‘ad hoc revision’: GEC puts forward the reasoning for arevision to the Advisory Council and seeks their input on whether to proceed with the revision.
Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P74

2.6

Continuous
MaintenanceThe development of an assessment on Continuous Maintenance should be a consensus processincluding the Advisory Council.
Suggested change:
GEC shares the outcome of the assessment with puts forward the reasoning for a revision theAdvisory Council and seeks their input on whether to proceed with a full revision.
GEC makes the final decision as to whether any revision to EPEAT Criteria is warranted. Any fullrevision to EPEAT Criteria is conducted in accordance with the principles and procedures of GEC’s
Dynamic Criteria Development Process

Global Electronics Council

Published February 15, 2023

Page 19 of 27

EPEAT Program Stakeholder Comment Report
Proposed Revisions to GEC Criteria Development Process (P74) and First Issue of GEC Selection of Product Categories (P75)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to GEC Criteria Development Process (P74) and the First Issue of GEC Selection of Product Categories (P75)
Comments are first listed alphabetically by the last name of the individual providing comments and then listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P74

2.7

Topic

Comment

Complaints andAppeals

It is not clear what has GEC done to establish an appeal process that is unbiased. GEC has control
over appeals related to its own process and implementation: “GEC retains full authority to make thefinal determination in the case of all complaints and appeals pertaining to GEC’s Dynamic Criteria
Development Process.”
All SDOs that ITI works with have a process by which an appeal is reviewed by an external, volunteer
group. This removes the conflict of interest of GEC staff ruling on an appeal of a GEC action or
inaction. ITI suggests that GEC add a section here either about an external Complaints Appeals
Committee, which is comprised of individuals outside of GEC, or a two-tier process where there is a
“GEC appeal” and then an “external appeal.” The decisions of the external appeal would be final.
For the viability of the process, it is critical for GEC to involve parties outside of GEC and unrelated to
EPEAT and the GEC criteria development, to process and manage appeals and to set up an appeal
panel made up of a balanced group of stakeholders.
Also, GEC should make clear that its appeals process allows for, among other things, appeals basedon: a) inaction, not solely based on actions; b) exclusion from membership in Expert Ad Hoc Groups(currently explicitly prohibited), Technical Committees, or other activities; c) whether a technical issue
was afforded due process (for example, see ANSI Essential Requirements at Section 1.8); d) failure toadequately address public or member comments and objections; and e) GEC’s failure to follow
voluntary consensus processes.

Cleet, Chris

Information Technology Industry
Council (ITI)

Global Electronics Council

December 31, 2022

P74

2.7

Complaints andAppeals

Published February 15, 2023

The participating manufacturer should be informed as to who is part of the Complaints/Appeals
Committee. The make-up of this committee should be made available to the appellant given that
confidential business information may be included in the complaint/appeal process, the participating
manufacturer should have the ability to not approve if there are potential conflicts or CBI concerns.

Page 20 of 27

EPEAT Program Stakeholder Comment Report
Proposed Revisions to GEC Criteria Development Process (P74) and First Issue of GEC Selection of Product Categories (P75)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to GEC Criteria Development Process (P74) and the First Issue of GEC Selection of Product Categories (P75)
Comments are first listed alphabetically by the last name of the individual providing comments and then listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P74

2.8

Topic

Comment

Conflict of Interest

Following voluntary consensus principles requires GEC to abide by due process. According to GEC
Criteria Development Process at Table 3 and OMB Circular A-119: “Due process shall include
documented and publicly available policies and procedures, adequate notice of meetings andstandards development, sufficient time to review drafts and prepare views and objections, access toviews and objections of other participants, and a fair and impartial process for resolving conflicting
views.” The GEC Criteria Development Process document lacks critical elements.
Aside from other examples in comments for prior sections, there is no clear delineation of roles andresponsibilities between GEC, CDOs, TC, and Expert Ad Hoc Groups to ensure that these bodies canoperate without undue interference from each other, but also with an appropriate degree ofcooperation as may be needed.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P75

1.0

Introduction

As noted in our comments to P74, ITI does not believe that EPEAT criteria are “developed in abalanced, voluntary, consensus process” nor does it “align with” the characteristics of voluntary
consensus in OMB Circular A-119 and ISO 14024. ITI is suggesting specific revisions to P74 to address
both the spirit and letter of the documents referenced.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P75

2.0

Identification of
Product Categories

What happens if GEC decides to not act on a written request? ITI suggests providing the provider of awritten request a notice of whether a product category selection has initiated, if the GEC has declined(for now) to initiate a product category, or if no decision has been made and/or if additional
information could potentially sway the decision.
Suggested Change:
If GEC progresses with the product category selection process, GEC informs the stakeholder of theavailability of the Product Category Proposal and the opportunity to provide feedback through the
public consultation process, as summarized in Section 5.0. The stakeholder will also be informed if
GEC chooses to not pursue a new product category or if GEC would like additional information to
make a decision. Since initiation and decisions regarding potential product categories are carefully
evaluated, there may be a considerable time lapse before a decision is reached. Further, GEC may
choose not to pursue a new product category at all.

Global Electronics Council

Published February 15, 2023

Page 21 of 27

EPEAT Program Stakeholder Comment Report
Proposed Revisions to GEC Criteria Development Process (P74) and First Issue of GEC Selection of Product Categories (P75)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to GEC Criteria Development Process (P74) and the First Issue of GEC Selection of Product Categories (P75)
Comments are first listed alphabetically by the last name of the individual providing comments and then listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Topic

Comment

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P75

3.1/3.2.3

Business Case

Purchasers and manufacturers should be equally and specifically identified as more than simply“stakeholders” in the process.
Suggested changes:
3.1:
The Business Case identifies the landscape of relevant technology providers, manufacturer and largescale purchaser demand, and where criteria have the potential to reduce sustainability impacts.
3.2.3:The Business Case evaluates demand for products and services in the category by large-scaleinstitutional purchasers in the private and public sectors and the desire and ability of manufacturers
to meet EPEAT criteria for that product category. GEC also gathers viewpoints from a variety ofinterested stakeholders, including but not limited to policy makers, environmental non-governmentorganizations, manufacturers, and suppliers.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P75

3.2

Development of theBusiness Case

CAB capacity should be considered in this process. Analysis should be given to whether there is CAB
capacity to take on given technical expertise and current capacity to engage in this.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P75

4.1

Product Category
Proposal

There needs to be a balance of CBI and transparency in the Product Category Proposal. Without aclear definition of the CBI excluded, it may appear that the GEC is leaving out key information.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 31, 2022

P75

6.0

Complaints andappeals

The appellant should be informed as to who is part of the Complaints/Appeals Committee. The makeup of the Complaints/Appeals Committee should be defined in the manual. The titles of who is to be
included should be disclosed and made transparent in these procedures.

Elwood, Holly

Environmental Protection Agency

December 12, 2022

P74

2.0

Figure 1 - Continuous
Maintenance box

Suggest revising “Analysis of product performance against criteria” to “analysis of market uptake of
criteria” – seems to more accurately reflect what is analyzed in this process.

Elwood, Holly

Environmental Protection Agency

December 12, 2022

P74

2.0

Where publiccomment is includedin the process

For clarity, suggest revising to: “Public consultation is actively sought and open to all stakeholders at
two critical points in the Dynamic Criteria Development Process: 1) on the issuance of the Draft Stateof Sustainability Research…”;

Global Electronics Council

Published February 15, 2023

Page 22 of 27

EPEAT Program Stakeholder Comment Report
Proposed Revisions to GEC Criteria Development Process (P74) and First Issue of GEC Selection of Product Categories (P75)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to GEC Criteria Development Process (P74) and the First Issue of GEC Selection of Product Categories (P75)
Comments are first listed alphabetically by the last name of the individual providing comments and then listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Topic

Comment

Elwood, Holly

Environmental Protection Agency

December 12, 2022

P74

2.0

How public notified ofcomment
opportunities

Suggest revising to: “GEC notifies stakeholders of public consultation through the website
epeat.net/announcements, GEC newsletters and specific announcements.” Make this change
throughout the document. For example, also in this sentence under 2.1: “GEC notifies stakeholders of
the availability of State of Sustainability Research for public consultation through the website
epeat.net/announcements, GEC newsletters and announcements”

Elwood, Holly

Environmental Protection Agency

December 12, 2022

P74

2.2.2

Selection of
Verification
Requirements

Suggest adding the following example to have examples for each item referenced: “Verification
requirements align with all required elements of the criterion, and to the extent applicable, specify
published test methods, international standards (e.g., ISO, IEC) and certifications, regional andnational standards (e.g., EU CEN, US ENERGY STAR), and recognized voluntary programs (e.g. USEPA
Smartway Transport Partnership Program)”.

Elwood, Holly

Environmental Protection Agency

December 12, 2022

P74

2.2.2

Selection of
Verification
Requirements

Suggest adding: “Verification requirements are built to rely heavily on these existing tools.
Requirements are avoided which direct GEC to select additional standards/criteria/test methods/etc.
outside of the criteria development process. In rare instances when the Technical Committee takes
this approach, the selection criteria that GEC shall use and an open and transparent process forsharing the outcome of the selection process is included in the verification requirements”.

Elwood, Holly

Environmental Protection Agency

December 12, 2022

P74

2.2.2

Selection of
Verification
Requirements

Please specify that all verification requirements will be developed and approved by TechnicalCommittees and not outside of the voluntary consensus based process in order to ensure maximum
transparency and stakeholder input.

Elwood, Holly

Environmental Protection Agency

December 12, 2022

P74

2.2.3

Required and Optional
Criteria

Consider adding in a sentence like this: “In some instances, a Technical Committee may elect torequire a product to meet a specific optional criterion in order to be eligible to be EPEAT Gold
Registered in order to address specific high priority sustainability impacts more swiftly in the market”.

Elwood, Holly

Environmental Protection Agency

December 12, 2022

P74

2.2.3

Required and Optional
Criteria

Consider if/how to address the need to review all criteria sets in the final draft stage to ensure
appropriate emphasis/i.e. number of points placed on each criterion, and to try to maximize
efficiencies for manufacturers and minimize the number of criteria products must meet while still
addressing all key hotspots of the product life cycle.

Global Electronics Council

Published February 15, 2023

Page 23 of 27

EPEAT Program Stakeholder Comment Report
Proposed Revisions to GEC Criteria Development Process (P74) and First Issue of GEC Selection of Product Categories (P75)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to GEC Criteria Development Process (P74) and the First Issue of GEC Selection of Product Categories (P75)
Comments are first listed alphabetically by the last name of the individual providing comments and then listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Topic

Comment

Elwood, Holly

Environmental Protection Agency

December 12, 2022

P74

2.3

Expert Ad Hoc Groups

Suggest replacing this sentence: “The delivery of fully drafted criteria to the Technical Committee
streamlines the voluntary consensus process in order to broaden multistakeholder participation” withthe following: “The review and refinement of draft criteria by the Expert Ad Hoc Groups prior toreview by the Technical Committees streamlines the criteria development process and broadensmultistakeholder participation”.

Elwood, Holly

Environmental Protection Agency

December 12, 2022

P74

2.3

Expert Ad Hoc Groups“A list of organizations participating in Expert Ad Hoc Groups is made available to the TechnicalCommittee and is publicly available”. Please specify where the list(s) are publicly available.

Elwood, Holly

Environmental Protection Agency

December 12, 2022

P74

2.3

Expert Ad Hoc Groups

It is noted that the size limitation is being proposed to be eliminated for Expert Ad Hoc Groups. We’d
propose retaining a minimum size for these groups to ensure some engagement with stakeholders
external to GEC prior to submitting to the Technical Committees. Four seems like an appropriate
minimum number.

Elwood, Holly

Environmental Protection Agency

December 12, 2022

P74

2.5

Voluntary Consensus
Process

For clarity, and to ensure partner organizations have solid proven success in developing productsustainability standards, suggest the following edit: “Since credible and objective criteria development
is important to GEC’s mission, GEC selects partner criteria development organizations with experiencein managing voluntary consensus processes involving participation of diverse stakeholders, whichhave documented funding sources, the lack of any conflicts of interest or undue influence by any one
stakeholder group on their activities, and which have resulted in a final voluntary consensus standard
successfully implemented in the marketplace”.

Elwood, Holly

Environmental Protection Agency

December 12, 2022

P74

2.5

Voluntary Consensus
Process – Table 3 –Balance of Interests

State source for Table 3. Suggest the following edits: “The Criteria Development Organization mustalso have procedures in place to objectively select Technical Committee members, ensure balance in
the Technical Committee, safeguard against anti-competitive behaviors, and avoid the use ofcommercial terms and other requirements that may restrict trade and competition. Approved minutesof Technical Committee meetings must be publicly available”. It is important that the Criteria
Development Organization ensures balance to align with the requirements in OMB Circular A119.

Elwood, Holly

Environmental Protection Agency

December 12, 2022

P74

2.5.1.1

Technical Committee
MemberSuggest the following edits: “Participation on the Technical Committee does not constitute an
endorsement of the EPEAT Program, nor the criteria set or standard developed by the TechnicalCommittee by the individual or their affiliated organization”.

Elwood, Holly

Environmental Protection Agency

December 12, 2022

P74

2.5.2

Public Consultation

Suggest the following edits: “GEC notifies stakeholders of the public consultation period through thewebsite epeat.net/announcements, GEC newsletters and announcement”.

Global Electronics Council

Published February 15, 2023

Page 24 of 27

EPEAT Program Stakeholder Comment Report
Proposed Revisions to GEC Criteria Development Process (P74) and First Issue of GEC Selection of Product Categories (P75)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to GEC Criteria Development Process (P74) and the First Issue of GEC Selection of Product Categories (P75)
Comments are first listed alphabetically by the last name of the individual providing comments and then listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Topic

Comment

Elwood, Holly

Environmental Protection Agency

December 12, 2022

P74

2.6

Continuous
Maintenance

Please clarify this is about FULL revisions throughout this section. “GEC assesses the need for a fullcriteria revision three years after Criteria were initially adopted for use for a product category”.

Elwood, Holly

Environmental Protection Agency

December 12, 2022

P74

2.6

Continuous
Maintenance

Please add as “factors considered when evaluating whether criteria require revisions”: “Whether new
sustainability impacts related to the manufacture, use, and/or disposal of this product have been
identified since the development of this standard requiring criteria to be developed to sufficiently
address them”.

Elwood, Holly

Environmental Protection Agency

December 12, 2022

P74

2.6

Continuous
Maintenance

Please add discussion of when/how minor revisions are made to the criteria. And mirror with text inthe EPEAT Policy Manual.

Elwood, Holly

Environmental Protection Agency

December 12, 2022

P74

2.8

Conflicts of Interest

Please clarify how GEC ensures there is no conflict of interest or undue influence for Criteria
Development Organizations being funded to manage the criteria development process by a particularstakeholder group.

Elwood, Holly

Environmental Protection Agency

December 12, 2022

P75

1.0

Conformity assurance:“Before becoming
EPEAT-registered, an
independent GECapproved Conformity
Assurance Body must
confirm the product’s
conformance with
EPEAT Criteria.”

We understood that under the Priority Verification Pathway, manufacturers go through desk reviewof their submissions for one product to ensure they are submitting responses in the ballpark of whatis needed to respond accurately while not confirming accuracy of any specific claims made. If the
responses seem reasonable, then GEC allows OEMs to put as many products on the registry as theywould like, which are then subject to post market verification via the verification rounds. Under thispath, a CAB is not confirming the products conformance with EPEAT criteria prior to posting on the
EPEAT Product Registry. If this process is still used, then this sentence should be revised for accuracy.

Elwood, Holly

Environmental Protection Agency

December 12, 2022

P75

1.0

Transparency of
category selection
process.

Since this is a new process, recommend for accuracy revising this sentence to say: “The process
outlined in this document is intended to guide all future selection of product categories and ensurethat the selection process is transparent, and interested stakeholders are appropriately engaged andconsulted per 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 andprocedures. , GEC ensures that the process which guides its selection of product categories istransparent, and that interested stakeholders are appropriately engaged and consulted.

Global Electronics Council

Published February 15, 2023

Page 25 of 27

EPEAT Program Stakeholder Comment Report
Proposed Revisions to GEC Criteria Development Process (P74) and First Issue of GEC Selection of Product Categories (P75)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to GEC Criteria Development Process (P74) and the First Issue of GEC Selection of Product Categories (P75)
Comments are first listed alphabetically by the last name of the individual providing comments and then listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Topic

Comment

Elwood, Holly

Environmental Protection Agency

December 12, 2022

P75

3.1

Business Case

Suggest the following edits if in line with GEC approach: “The Business Case identifies the landscape of
relevant technology providers, large-scale purchaser demand, and whether there are opportunities inthis product category to where criteria have the potential to reduce sustainability impacts”. Criteria
may or may not reduce sustainability impacts based on how they are crafted. The Business Case isfocused on whether there is an opportunity to reduce sustainability impacts to justify the work tocreate a hopefully effective criterion/criteria.

Elwood, Holly

Environmental Protection Agency

December 12, 2022

P75

3.1

Topics covered in thebusiness case

Recommend the following revision: “The Business Case may be developed by GEC or by a third-party
on behalf of GEC, and addresses at a minimum, the following topics: market research and policy
drivers, sustainability impacts related to the manufacture, use, and disposal of the product,
stakeholder interest, purchaser demand, and GEC capacity”. The document puts purchaser demand
into the stakeholder interest category, but it may be worth calling out separately due to the amountof importance of this piece.

Elwood, Holly

Environmental Protection Agency

December 12, 2022

P75

3.1

Decision the businesscase impacts

Recommend the following revisions: “The Business Case provides a data driven analysis and makes
an overall recommendation regarding the potential of successful impact resulting from whether GEC
and its stakeholders developing criteria for the product category and adding it to the EPEAT ProductRegistry would be successful and impactful”.

Elwood, Holly

Environmental Protection Agency

December 12, 2022

P75

3.1

Public visibility of the
product categories
GEC develops businesscases onIn the past, GEC determined which product categories to address based on a multi-stakeholder input
seeking process (called “the Roadmap”), and the product categories under consideration were sharedfor public input. It would be helpful to stakeholders to view the possible product categories underconsideration to allow them to provide key info to GEC to include in their Business Cases and toprepare for engagement in potential upcoming criteria development efforts, and related
procurement activities. Suggest adding this process step in some way to the document. Notices
could also be placed in the ANSI Standards Notice for all potential product categories simultaneous toa possible list of future product categories being made public.

Elwood, Holly

Environmental Protection Agency

December 12, 2022

P75

4.2

Feedback

Recommend that GEC also shares the Product Category Proposal with the EPEAT Advisory Council andseeks their input as well. Suggest adding this to this section. It would be helpful to clarify theAdvisory Council’s role in this process throughout the document where appropriate.

Elwood, Holly

Environmental Protection Agency

December 12, 2022

P75

5.0

Decision

Recommend revising to state: “The findings of the Business Case in conjunction with stakeholder and
EPEAT Advisory Council feedback on the Product Category Proposal serve as the basis from which GEC
makes its final decision regarding whether to develop criteria for a new product category”

Global Electronics Council

Published February 15, 2023

Page 26 of 27

EPEAT Program Stakeholder Comment Report
Proposed Revisions to GEC Criteria Development Process (P74) and First Issue of GEC Selection of Product Categories (P75)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to GEC Criteria Development Process (P74) and the First Issue of GEC Selection of Product Categories (P75)
Comments are first listed alphabetically by the last name of the individual providing comments and then listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Topic

Comment

Elwood, Holly

Environmental Protection Agency

December 12, 2022

P75

Throughout

Sharing publiccomment period
information withstakeholders

Suggest noting that GEC will be posting these public comment periods on epeat.net/announcements
as well, as stakeholders are now going there to see opportunities to engage.

Global Electronics Council

Published February 15, 2023

Page 27 of 27