EPEAT Program
Continuous Monitoring Outcomes Report
Imaging Equipment
IE-2020-02
April 12, 2021

1.0 Background
EPEAT® is a comprehensive voluntary sustainability Type 1 ecolabel that helps purchasers identify sustainable
technology products and services. Central to EPEAT are conformity assurance activities that meet the technicalrigor and credibility needs of the institutional purchasers who rely upon EPEAT. The EPEAT Program ensures
the ongoing conformance of EPEAT-registered products through an ongoing surveillance process known asContinuous Monitoring. Continuous Monitoring activities occur throughout the year and test the ability ofParticipating Manufacturers to prove conformance with EPEAT Criteria on an ongoing basis.
Some Continuous Monitoring activities require that Investigations be conducted in discrete timeframes calledRounds. The EPEAT Program develops an individual plan for each Continuous Monitoring Round, which
specifies the EPEAT Criteria to be investigated, the method of investigation that GEC-approved Conformity
Assurance Bodies (CABs) must use and the specific dates when the Investigation activities must be completed.
The EPEAT Program also selects the Participating Manufacturers and EPEAT-registered products and assigns
Investigations to CABs, which must fully participate in and are responsible for implementing Continuous
Monitoring Round activities with their Participating Manufacturer clients. Participating Manufacturers arerequired to cooperate fully with their GEC-approved CAB during Round activities.
To maintain the level of transparency relied on by purchasers, the EPEAT Program publishes an Outcomes
Report at the conclusion of each Round to summarize the activities conducted and to identify the products andParticipating Manufacturers that received major nonconformances and the actions taken to restore accuracyof the EPEAT Registry.
This document summarizes the activities and results of Continuous Monitoring Round IE-2020-02 conductedfor the Imaging Equipment category.

2.0 Overview of Continuous Monitoring Round IE-2020-02
2.1

Investigation Activities

As per the published Round Plan, Continuous Monitoring Round IE-2020-02 used Level 1 Investigations(documentation review activities to determine Participating Manufacturers’ conformance with specific EPEAT
Criteria). Participating Manufacturers had a discrete time period to provide their CABs with evidence
supporting conformance with the selected EPEAT Criteria. GEC-approved CABs reviewed the documentation,
made recommendations on conformity based solely on the evidence provided by Participating Manufacturers,
and sent Investigation Reports to the EPEAT Program. The EPEAT Program made the final decisions on
conformity for the Investigations.

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Criteria InvestigatedCriteria were selected for Continuous Monitoring Round IE-2020-02 based on the positive sustainability impact
the Criteria will have when adopted, and the potential to drive change in the sector. Each Participating
Manufacturer selecting the Criteria was assigned investigations and products were chosen randomly. Any
Participating Manufacturer that received a Major Nonconformance during 2019 Continuous Monitoring
activities in the Imaging Equipment category received an additional Investigation in this Round.
Table 1: Criteria Investigated in Round IE-2020-02
Criteria Number

Criterion Title

4.3.1.1

Ease of disassembly of product4.7.2.1

Public disclosure of key environmental impacts3.0 Summary of Investigations and Final Decisions on Conformity for IE-2020-02
Highlights from this Continuous Monitoring Round are:•33 investigations completed•

19 decisions of Conformance•

14 decisions of Nonconformance

Further details provided in Section 4Figure 1: Final Conformity Decisions for IE-2020-02(shown as percentage of total investigations)Global Electronics Council

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4.0 Further Details on Nonconformances for IE-2020-02
Figure 2 below provides a further breakdown of the nonconformances by Criterion.
Figure 2: Breakdown of Nonconformances by Criterion for IE-2020-02(shown as a percentage of total nonconformances)

Figure 3 provides a further breakdown by the underlying reason for the nonconformances.
Figure 3: Underlying Reason for Nonconformances in IE-2020-02(shown as a percentage of total nonconformances)

4.1

Major Versus Minor Nonconformances

All nonconformances must be categorized as either major or minor. Minor nonconformances are non-criticalor clerical in nature and do not materially affect the validity of conformance with EPEAT Criteria. Allnonconformances that do not meet the definition of minor are categorized as major. All of thenonconformances identified in IE-2020-02 were Major Nonconformances.

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Minor Nonconformances

For Level 1 Investigations, nonconformances may be categorized as minor for the following reasons:•••Minor human error in data entry (e.g., value cited for EPEAT-product registration is insignificantly
above or below the actual value).
Minor administrative errors (e.g., broken URLs, reports/certificates marginally outdated).
No documentation provided by a Participating Manufacturer where the Participating Manufacturer
indicated the product has reached end-of-life and is no longer available on the market.

There were no Minor Nonconformances found in Round IE-2020-02.
4.3

Major Nonconformances

Major nonconformances may be found due to a demonstrated nonconformance, insufficient evidence
provided to demonstrate conformance, or because no documentation was provided. Major nonconformanceswere found for both Criteria investigated in this Round. Both Criteria have multiple elements, all of which must
be met to demonstrate conformance.
Criterion 4.3.1.1 requires a description of the disassembly process or statements from recyclers that
demonstrate ease of access to materials with special handling needs, materials, components andsubassemblies that could be reused and components and subassemblies that may need to be removed forrepair or replacement. This also requires demonstrating that all electrical and communication cables that comestandard with the product are removable by hand or with commonly available tools without being renderedunusable.
All demonstrated Nonconformances identified in this Round were for Criterion 4.7.2.1. This Criterion requires
disclosure of GHG emissions, water data, waste data and toxics data for at least two consecutive years, and foreach disclosure, a plan with goals, targets and objectives and last year’s goals, targets and objectives and theactual performance against them, and a brief report on progress made in meeting the manufacturer’s
environmental performance commitments. In addition, the disclosure for water specifically requires both thepercentage and total volume of water recycled and reused and information on the quality of water discharges.
The waste disclosure requires the disclosure of waste reduced from a baseline year, reused, recycled,
landfilled, sent to waste-to-energy, incinerated or other disposal facilities as applicable.
For most Investigations where Criterion 4.7.2.1 was found Nonconformant due to insufficient evidence or ademonstrated nonconformance, the Manufacturer provided publicly available disclosures for the four keyenvironmental aspects but had just not addressed all Criterion elements. Commonly missed for this criterion is
the requirement for current goals, targets and objectives and the previous year’s goals, targets and objectives
and the performance against them. Nine nonconformances in this Round were due, or partially due to notincluding a current or previous goal for one or more key environmental aspects. Two nonconformances in thisRound were due, or partially due, to disclosures for water not including water discharge quality information orwaste disclosures not including values for each type of waste required by the criterion. Historically,nonconformances for Criterion 4.7.2.1 have also been due to all elements of the Criterion not being addressedin publicly available disclosures.
In addition, two nonconformances were related or partially related to the scope of disclosures. The
Participating Manufacturer is responsible for disclosing data for all four key environmental aspects at either

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the whole enterprise level or for parts of the company having significant or complete responsibility for thedesign and manufacture of the declared product. For the toxics key environmental disclosure this applies tocompany owned manufacturing, assembly facilities and office operations for the whole enterprise or withsignificant responsibility for design and manufacture.
Figure 4 provides a breakdown of reasons for the Major Nonconformances found in Round IE-2020-02 byCriterion.
Figure 4: Reasons for Major Nonconformances By Criterion

5.0 Actions to Restore Conformance
Where the final conformity decision is nonconformance (whether major or minor), Participating Manufacturers
must make corrections to restore the accuracy of the EPEAT Registry during the Corrective Action Phase. Theseactivities may include providing additional evidence to demonstrate conformance with the Criterion or
unselecting the Criteria in the EPEAT Registry. Where the product was found nonconformant and is no longer
available in the marketplace, the product must be archived.
During the Corrective Action Phase, Participating Manufacturers must also develop Corrective Action Plans forother EPEAT-registered products that may be affected by the same underlying issue causing thenonconformance but were not the subject of investigation (called “similarly affected products”).
The following actions were taken to restore accuracy to the EPEAT Registry as a result of ContinuousMonitoring Round IE-2020-02:•13 investigations

Additional data provided by Participating Manufacturers, bringing the products
into conformance with the Criterion•1 investigation

Product archived by the CAB or by the EPEAT Program

Table 2 in Section 7 identifies the Participating Manufacturers and products that received major
nonconformances in Continuous Monitoring Round IE-2020-02.

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6.0 Key Findings
6.1

Conformity Against All Elements of 4.3.1.1

As identified in Section 4.3 of this report, Criteria 4.3.1.1 and 4.7.2.1 have multiple elements against which
conformance must be demonstrated.
Criterion 4.3.1.1 requires a description of the disassembly process or letters from recycler to demonstrate that
Criterion elements are met. Additional evidence such as product photographs or exploded diagrams anddeclarations must be accompanied by a description of the disassembly process or letters from recyclers.
6.2

Conformity Against All Elements of 4.7.2.1

Manufacturers are reminded to review the scope requirements for disclosures for each of the key
environmental aspects in Criterion 4.7.2.1, including the scope of their disclosure, disclosures for reused andrecycled water use and water discharge quality and disclosures for different types of waste. Manufacturers arealso reminded to review their disclosures for goals, targets and objectives including those for the current year
and their previous year’s, as well as their progress on meeting the previous year’s goals, targets, andobjectives. Participating Manufacturers are encouraged to work with their CABs if they have questions.

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7.0 Identification of Major Nonconformances and Corrections Made by Participating Manufacturers
In the interest of transparency, the EPEAT Program identifies the Participating Manufacturers and products that received major nonconformances and the actions taken to restore accuracy of the EPEAT
Registry. Minor nonconformances are generally clerical in nature and do not materially affect the validity of products in the EPEAT Registry. As such, these are not identified in the table below.

Table 7: Summary of Major Nonconformances and Corrections Made by Participating Manufacturers
Participating
Manufacturer

ProductProduct TypeCountry

Criterion
NumberPanasonic

N/A- Corporate Criterion

N/A- Corporate Criterion

N/A- Corporate Criterion

4.7.2.1

Visioneer

Visioneer Patriot H80

Scanner

United States

4.3.1.1

Visioneer

N/A- Corporate Criterion

N/A- Corporate Criterion

N/A- Corporate Criterion

4.7.2.1

Kodak Alaris

N/A- Corporate Criterion

N/A- Corporate Criterion

N/A- Corporate Criterion

4.7.2.1

Brother

N/A- Corporate Criterion

N/A- Corporate Criterion

N/A- Corporate Criterion

4.7.2.1

Fujitsu Limited

N/A- Corporate Criterion

N/A- Corporate Criterion

N/A- Corporate Criterion

4.7.2.1

HPPrinter

United States

4.3.1.1

HP

HP LaserJet Enterprise
M610dnN/A- Corporate Criterion

N/A- Corporate Criterion

N/A- Corporate Criterion

4.7.2.1

Konica Minolta

N/A- Corporate Criterion

N/A- Corporate Criterion

N/A- Corporate Criterion

4.7.2.1

Kyocera

KYOCERA TASKalfa 8003i

Multifunction device

United States

4.3.1.1

KyoceraN/A- Corporate Criterion

N/A- Corporate Criterion

N/A- Corporate Criterion

4.7.2.1

Lexmark

N/A- Corporate Criterion

N/A- Corporate Criterion

N/A- Corporate Criterion

4.7.2.1

Ricoh

N/A- Corporate Criterion

N/A- Corporate Criterion

N/A- Corporate Criterion

4.7.2.1

Sharp

N/A- Corporate Criterion

N/A- Corporate Criterion

N/A- Corporate Criterion

4.7.2.1

Global Electronics Council

Required or
Optional

Underlying Reason for
Nonconformance

Public disclosure of key environmental
impacts
Ease of disassembly of productRequired

Demonstratednonconformance
No documentation provided

Public disclosure of key environmental
impacts
Public disclosure of key environmental
impacts
Public disclosure of key environmental
impacts
Public disclosure of key environmental
impacts
Ease of disassembly of productRequired

Public disclosure of key environmental
impacts
Public disclosure of key environmental
impacts
Ease of disassembly of productRequired

Public disclosure of key environmental
impacts
Public disclosure of key environmental
impacts
Public disclosure of key environmental
impacts
Public disclosure of key environmental
impacts

RequiredCriterion Title

Required

Required
Required
Required
Required

Required
Required

Required
Required
Required

Outcomes Report – Level 1 Investigations (P41B Issue2 Rev0)

Demonstrated
nonconformance
Insufficient evidence todemonstrate conformance
Insufficient evidence todemonstrate conformance
Insufficient evidence todemonstrate conformance
Insufficient evidence todemonstrate conformance
Insufficient evidence todemonstrate conformance
Insufficient evidence todemonstrate conformance
Insufficient evidence todemonstrate conformance
Insufficient evidence todemonstrate conformanceDemonstrated
nonconformance
Insufficient evidence todemonstrate conformance
Demonstrated
nonconformance

Corrective Action Taken

Participating Manufacturer left the Imaging
Equipment product category
Participating Manufacturer provided
additional data demonstrating conformance
Participating Manufacturer provided
additional data demonstrating conformance
Participating Manufacturer provided
additional data demonstrating conformance
Participating Manufacturer provided
additional data demonstrating conformance
Participating Manufacturer provided
additional data demonstrating conformance
Participating Manufacturer provided
additional data demonstrating conformance
Participating Manufacturer provided
additional data demonstrating conformance
Participating Manufacturer provided
additional data demonstrating conformance
Participating Manufacturer provided
additional data demonstrating conformance
Participating Manufacturer provided
additional data demonstrating conformance
Participating Manufacturer provided
additional data demonstrating conformance
Participating Manufacturer provided
additional data demonstrating conformance
Participating Manufacturer provided
additional data demonstrating conformance

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Document Control and Change HistoryIssue
1

Revision01120Owner
EPEAT Conformity
Assurance Manager
EPEAT Conformity
Assurance Manager
Senior Manager,
Ecolabels andResources

Global Electronics Council

ApproverDirector, EPEAT
ProgramDirector, EPEAT
Program
Senior Director,
Ecolabels andManufacturer
Resources

Description
Initial release

Reformatting of document. Addition ofstandardized text.

Outcomes Report – Level 1 Investigations (P41B Issue2 Rev0)

Approval Date

Effective Date2018 Dec 112018 Dec 112021 Mar 25

2021 Mar 30

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