Green Electronics Council
227 SW Pine Street, Suite 300 • Portland, OR 97204 • V: (503) 279-9382 • F: (503) 279-9381 • www.epeat.net

OUTCOMES REPORTEPEAT VERIFICATION ROUND IE-2019-03
1. Overview of Verification RoundIE-2019-03 included fifty-four (54) Level 0 and 1 investigations on sixteen (16) criteria. The selected
criteria were those that lent themselves well to Level 0 investigations or those for which demonstrationof conformance is difficult. All geographies and manufacturers with products active on the EPEAT
Registry were eligible for inclusion in this Round. Criteria investigated during this Round include:
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4.3.3.1 Required - Notification of identification of hazardous materials with special handlingneeds
4.3.4.1 Required - End of life characterization report
4.4.1.1 Required - Early failure process
4.4.2.1 Optional - Product upgradeability
4.5.1.1 Required - ENERGY STAR
4.5.2.2 Optional - LCA publicly available
4.5.3.2 Optional - Auto standby capability
4.5.4.1 Optional - Default to auto duplex printing
4.7.2.1 Required - Public disclosure of key environmental aspects
4.7.2.2 Optional - Public disclosure of supply chain toxics
4.7.3.1 Optional - Product LCA assessment and public disclosure of analyses
4.8.4.1 Optional - Provision of take-back service for packaging
4.9.1.1 Required - Allow use of general office paper with renewable content, recycled content,
and that is chlorine free
4.9.2.1 Required - Documentation that product does not prevent the use of non-manufacturer
cartridges and non-manufacturer containers
4.9.3.1 Required - Provision of take-back and end-of-life management for cartridges andcontainers
4.9.4.1 Required - Documentation that the cartridges or container is not designed to prevent its
reuse and recycling

All criteria were investigated via Level 0 investigation. In a Level 0 investigation, an Auditor assesses
Conformance to a criterion by examining publicly available information only. No products are obtainedfor inspection or testing, and the Manufacturer is not asked to submit documentation. If the publicly
available information was inconclusive (i.e. was not available, could not be found from public sources, or
did not provide enough details to determine conformance), the Auditor was instructed to proceed witha Level 1 investigation.

2. Summary of Outcomes

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•54 investigations were completed during this verification round•52 findings of Conformance•

2 findings of Non-ConformanceoBoth findings of Non-Conformance were Demonstrated Non-Conformances.

Figure 1: Overall Conformance Status for
IE-2019-03 (as % of total investigations)
4%

96%Conformance

Non-Conformance

Figure 2: Reason for Non-Conformance
210
Demonstrated Non-Conformance

3. Key Lessons
4.9.2.1 – Required - Documentation that product does not prevent the use of non-manufacturer
cartridges and non-manufacturer containers
Manufacturers need to ensure that information from different sources (website, product manual,service documentation) matches when there are specific requirements for documentation.

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4.9.3.1 – Required – Provision of take-back and end-of-life management for cartridges andcontainers
Manufacturers need to have a process in place to ensure that reported volume numbers areupdated annually per the criterion.

4. General Message to Manufacturers
Initial response to Auditors:
When contacted regarding participation in a Verification Round, Manufacturers should respond tothe Auditor as soon as possible to let them know they are communicating with the correct person or
to inform them of the correct contact. This also helps the Auditor know that the e-mail address isvalid.
Conformance of products that may share similar traits and/or supply chains:
If a Non-Conformance is found for a particular criterion and product, Manufacturers should beprepared to determine if other products on the EPEAT Registry are similarly impacted due to use ofsimilar materials and/or supply chains, and develop corrective action plans to address the future
conformance of these other products.

5. Looking Forward
Plans for Future Verification Activities:
The annual Verification Plan has been published and can be found here.
Conformity Sample Packets:
This and all future Verification Rounds have and will be conducted according to the guidance
provided in the Conformity Sample Packets posted on www.epeat.net under “Help & FAQ” in My
Account.

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6. Investigations Table
TABLE 1: Specific Non-Conformance Findings and Corrective Action Taken
Participating
Manufacturer

ProductCountry

Product Type

Criterion

Requiredor Optional

Criterion Description

NC Finding
Description

Corrective Action Taken

Undisclosed
due to Minor
NC

Undisclosed due to MinorNC

UnitedStatesMultifunction
Device4.9.2.1

RequiredDocumentation that product does notprevent the use of non-manufacturer
cartridges and non-manufacturer
containers

Demonstrated nonconformance

Manufacturer in process ofupdating manuals for all affectedproducts.

Undisclosed
due to Minor
NC

Undisclosed due to Minor
NCUnited
StatesMultifunction
Device4.9.3.1

Required

Provision of take-back and end-of-life
management for cartridges and containers

Demonstrated nonconformance

Manufacturer added updated
recycling volume numbers totheir website.

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7. BackgroundTo assure the credibility of the EPEAT Registry, verification of the claims by Participating
Manufacturers are rigorous, independent and transparent. Verification is conducted according topolicies and procedures described in documents provided on www.epeat.net. Manufacturers are
given no forewarning that their products will be verified, and verification is performed based on thedeclarations as they are in the Registry at the time the Verification Round begins.
Investigations are performed by expert technical contractors called Auditors working for a
Conformity Assurance Body approved by the Green Electronics Council (GEC). Auditors are free ofconflicts of interest, and their recommended decisions are reviewed and finalized by the Conformity
Assurance staff of GEC. Decisions of conformity are made blind to the identity of the products andcompanies they are judging, based only on evidence collected and analyzed by Auditors. A serious
consequence of receiving a Major Non-Conformance is that it is published publicly in an Outcomes
Report, for purchasers, competitors, and others to see.
•In a Level 0 investigation, an Auditor assesses Conformance to a criterion by examining publicly
available information only – no products are obtained for inspection or testing, and theManufacturer is not asked to submit documentation. If the publicly available information isinconclusive (i.e. was not available, could not be found from public sources, or did not provide
enough details to determine conformance), the Auditor may be instructed to proceed with aLevel 1 investigation.

•In a Level 1 investigation, an Auditor assess Conformance to a criterion by examining
information submitted by a Manufacturer. The Manufacturer is required to provide detailed andaccurate information in a timely manner.

•In Level 2 investigations, the Conformity Assurance Body obtains a product without theManufacturer’s knowledge or involvement, and has the product disassembled and inspected toassess conformance with one or more criteria.

•In Level 3 investigations, the Conformity Assurance Body obtains a product without theManufacturer’s knowledge or involvement, and has the product analytically tested to assess
conformance with one or more criteria.

Manufacturers must correct Non-Conformances, either by bringing the product into Conformance,by un-declaring the criterion until Conformance is achieved, or by removing the product from theRegistry. The Green Electronics Council also requires that Manufacturers examine other registeredproducts to determine if their declarations should be corrected as well. If a Manufacturer corrects
the Non-Conformance by un-declaring the criterion and the criterion is an optional criterion, theylose that point, and possibly the product drops a tier. If it is a required criterion, they must archive
the product. If it is a required corporate criterion, they must archive all of their registered products.

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