EPEAT Program
Continuous Monitoring Outcomes ReportServers
SV-2021-02
November 10, 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 are
required to cooperate fully with their GEC-approved CAB during Round activities.
To maintain the level of transparency relied on by purchasers, the EPEAT Program publishes an Outcomes
Report at the conclusion of each Round to summarize the activities conducted and to identify the products andParticipating Manufacturers that received major nonconformances and the actions taken to restore accuracyof the EPEAT Registry.
This document summarizes the activities and results of Continuous Monitoring Round SV-2021-02 conducted
for the Servers product category.

2.0 Overview of Continuous Monitoring Round SV-2021-02
2.1

Investigation Activities

As per the published Round Plan, Continuous Monitoring Round SV-2021-02 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.

Global Electronics Council

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Criteria Investigated

The products and Criteria selected for investigation in Continuous Monitoring Round SV-2021-02 were selectedrandomly using a random number generator.
Table 1: Criteria Investigated in Round SV-2021-02
Criteria Number

Criterion Title

5.2.1

Allowable temperature and humidity specifications

9.2.1

Information and reporting in preparation for reuse and recycling

11.1.1

Provision of product take-back service (corporate)

11.2.1

End of life process requirements (corporate)

11.2.2

Trans-boundary movements (corporate)

12.1.1

Environmental management system (EMS) (corporate)

12.3.3

Participating in in-region conflict-free sourcing programs (corporate)

12.4.1

Manufacturer conformance with occupational health and safety performance (corporate)

3.0 Summary of Investigations and Final Decisions on Conformity for SV-2021-02
Highlights from this Continuous Monitoring Round are:•8 investigations completed•

6 decisions of Conformance•

2 decisions of Nonconformance

Further details provided in Section 4Figure 1: Final Conformity Decisions for SV-2021-02(shown as percentage of total investigations)Global Electronics Council

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4.0 Further Details on Nonconformances for SV-2021-02
Table 2 below provides a further breakdown of the nonconformances by Criterion.
Table 2: Breakdown of Nonconformances by Criterion for SV-2021-02
Criteria Number

Criterion Title

Total Nonconformances

5.2.1

Allowable temperature and humidity specifications

09.2.1

Information and reporting in preparation for reuse and recycling

111.1.1

Provision of product take-back service (corporate)

011.2.1

End of life process requirements (corporate)

011.2.2

Trans-boundary movements (corporate)

012.1.1

Environmental management system (EMS) (corporate)

012.3.3

Participating in in-region conflict-free sourcing programs (corporate)
Manufacturer conformance with occupational health and safety performance(corporate)

012.4.1

1

Figure 2 provides a further breakdown by the underlying reason for the nonconformances.
Figure 2: Underlying Reason for Nonconformances in SV-2021-02(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 nonconformances for Continuous Monitoring Round SV-2021-02 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 Continuous Monitoring Investigation SV-2021-02.
4.3

Major Nonconformances

Major nonconformances may be due to a demonstrated nonconformance, insufficient evidence
provided to demonstrate conformance, or because no documentation was provided. Major nonconformanceswere found for two Criteria investigated in this Round, and in both cases, the nonconformance was due toinsufficient evidence submitted to demonstrate conformance.
Criterion 9.2.1 requires the Manufacturer to publish information required by Article 15 of the European Union
WEEE Directive 2012/19/EU for use by third-party reuse and recycling organizations and demonstrate that thisinformation is available in all regions or countries in which the Criterion is declared. In addition, themanufacturer must have a written procedure to ensure the information is available for seven years following
the end of production of the product.
Criterion 12.4.1 requires the Manufacturer to demonstrate conformance to ANSI/AIHA/ASSE Z10, Occupational
Health and Safety Management Systems, or OHSAS 18001 [ISO 45001] for all manufacturer-owned operations
with significant responsibility for the manufacture or assembly of products declared to conform to the EPEAT
Servers Criteria. Manufacturers must demonstrate they have a management system that covers all elements ofthe occupational health and safety standard.

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 Continuous
Monitoring Round SV-2021-02:•2 investigations

Global Electronics Council

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

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Table 3 in Section 7 identifies the Participating Manufacturers and products that received major
nonconformances in Continuous Monitoring Round SV-2021-02.

6.0 Key Findings
6.1

Conformity Against All Elements of Criterion 9.2.1:

Manufacturers are reminded to review all Criterion elements for Criterion 9.2.1. Participating Manufacturers
are reminded to ensure that they have all of the following:
••
•

6.2

Documentation available for reuse and recycling facilities which includes all information required for
Article 15 of the European Union WEEE Directive 2012/19/EU (presence and location of materials
requiring selective treatment per Annex VII of the European Union WEEE Directive 2012/19/EU).
Demonstration that the information above is made available to reuse and recycling facilities in all
regions or countries in which the criterion is declared; andA written procedure that assures that the information is available for seven years following the end ofproduction of the product.
Conformity Against All Elements of Criterion 12.4.1:

Manufacturers are reminded that conformance to ANSI/AIHA/ASSE Z10, Occupational Health and Safety
Management Systems, or OHSAS 18001 [ISO 45001] must be demonstrated for all manufacturer-owned
operations with significant responsibility for the manufacture or assembly of products declared to conform tothis product category. All aspects of the occupational health and safety standard must be addressed in theManufacturer’s evidence.
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 EPEATRegistry. 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 3: Summary of Major Nonconformances and Corrections Made by Participating Manufacturers
Participating Manufacturer

ProductProduct TypeCountry

Criterion Number

Criterion Title

Cisco

UCSB-B200-M5

Blade Server

United States

9.2.1

Hewlett Packard
Enterprise

HPE ProLiant XL225n Gen 10Plus Server

Multi-nodeServerFrance

12.4.1

Information and reporting in
preparation for reuse andrecycling
Manufacturer conformancewith occupational health andsafety performance(corporate)

Global Electronics Council

Required orOptional

Underlying Reason for Nonconformance

Corrective Action Taken

RequiredInsufficient evidence to demonstrateconformance.

Manufacturer submitted evidence
demonstrating conformance.

RequiredInsufficient evidence to demonstrateconformance.

Manufacturer submitted evidence
demonstrating conformance.

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Document Control and Change HistoryIssue1Revision01120Owner
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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