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-2018-02
1. Overview of Verification RoundIn this Verification Round, four criteria were investigated in forty (40) investigations either because
they had not been verified recently or they were targeted for investigation during EPEAT’s annual
planning process. The four criteria were as follows:•4.3.4.2 – Required – Minimum reusable/recyclable rate based on requirement of EUWEEE Directive•

4.4.1.1 – Required – Early failure process•

4.7.2.1 – Required – Public disclosure of key environmental aspects•

4.9.3.3 – Optional – Manufacturer recycles or reuses plastics collected through its
cartridge and container take-back program

All products and all geographies were eligible for inclusion in this Verification Round.

2. Summary of Outcomes
Highlights from this Verification Round:•

40 total investigations assigned•

36 decisions of Conformance•

4 decisions of Non-Conformance

Outcomes Report
EPEAT Verification Round IE-2018-02

Page 1
August 2018

Figure 1: Overall Conformance Status for
IE-2018-02 (as % of total investigations)
10%

90%

Conformance

Non-Conformance

Figure 2: Reasons for Non-Conformance
54132
31
0
Insufficient documentation to prove conformance
Demonstrated non-conformance

3. Key Lessons
4.7.2.1 Required: Public disclosure of key environmental aspects
This criterion requires a large amount of disparate information to be made publicly available. The
criterion requires specific information to be reported and if Manufacturers to do not report on theexact information required, they will receive a Non-Conformance. Manufacturers should review
their publicly available information to ensure that all required information is available.
4.9.3.3 Required: Manufacturer recycles or reuses plastics collected through its cartridge andcontainer take back programThis criterion has reporting requirements and the data must be reported annually. Manufacturers
should review the reporting requirements to ensure that all required information is up to date.

Outcomes Report
EPEAT Verification Round IE-2018-02

Page 2
August 2018

4. General Message to Manufacturers
Understanding documentation requirements for Verification Rounds:
You can find more guidance and examples of conformance documents in the Conformity Sample
Packets located in “Key Documents” under My Account. Go to epeat.net to log in.
Initial response to Auditors:
When contacted regarding participation in a Verification Round, Manufacturers should respond to
the 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:
A total of four Verification Rounds have been planned for Imaging Equipment products in 2018.
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 “Key Documents” inMy Account.

Outcomes Report
EPEAT Verification Round IE-2018-02

Page 3
August 2018

6. Investigations Table

TABLE 1: Specific Non-Conformance Findings and Corrective Action Taken
Participating
Manufacturer

Dell, Inc.

Toshiba

Kodak Alaris

KonicaMinolta

Product

S5830dneStudio
2809A

i940

bizhub
C3851

Country

United States

United States

United States

Australia

Outcomes Report
EPEAT Verification Round IE-2018-02

Product TypePrinter

Multifunction
Device (MFD)

Scanner

Multifunction
Device (MFD)

Criterion

4.7.2.1

4.7.2.1

4.7.2.1

4.9.3.3

Requiredor OptionalCriterion Description

NC Finding
Description

Corrective Action Taken

Public disclosure of key
environmental aspects

Demonstrated
nonconformance

If NC due to demonstrated nonconformance, Manufacturer provided
evidence of changes made resulting
in conformance.

Public disclosure of key
environmental aspects

Demonstrated
nonconformance

If NC due to demonstrated nonconformance, Manufacturer provided
evidence of changes made resulting
in conformance.

Required

Public disclosure of key
environmental aspects

Insufficient
documentation
to prove
conformance

If NC due to insufficient evidence,
Manufacturer provided additional
evidence to demonstrateconformance.

Required

Manufacturer recycles orreuses plastics collected
through its cartridge andcontainer take backprogramDemonstrated
nonconformance

If NC due to insufficient evidence,
Manufacturer provided additional
evidence to demonstrate
conformance.

Required

RequiredPage 4
August 2018

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 a four-person
panel of independent technical experts (called the Conformity Decision Panel) who are also
contractors free of conflicts of interest. Decisions of conformity by the Conformity Decision Panelare made blind to the identity of the products and companies they are judging, based only on
evidence collected and analyzed by Auditors. A serious consequence of receiving a NonConformance is that it is published publicly in an Outcomes Report, for purchasers, competitors, andothers 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 a
Level 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.

Outcomes Report
EPEAT Verification Round IE-2018-02

Page 5
August 2018