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-2017-03
1. Overview of Verification RoundThis report provides detailed results for Verification Round IE-2017-03. This round included fortyseven (47) Level 1 investigations on randomly chosen criteria and products. All manufacturers andall geographies were eligible for inclusion. Criteria investigated during this round included:•••••••••••••••••••••••••••

4.1.1.1 Required: Compliance with provisions of European Union RoHS Directive
4.1.4.1 Optional: Reduction of substances on the EU REACH Candidate List of SVHCs
4.1.5.1 Required: Compliance with provisions of EU Battery Directive
4.1.6.1 Required: Reducing BFR/CFR/PVC content of external plastic casings
4.2.1.1 Required: Declaration of postconsumer recycled plastic content
4.2.1.2 Required: Minimum content of postconsumer recycled plastic
4.2.2.1 Required: Declaration of biobased plastic materials content
4.3.1.1 Required: Ease of disassembly of product4.3.1.2 Optional: Ease of disassembly of consumer products
4.3.3.1 Required: Notification regarding the identification of both materials and componentsthat have hazardous characteristics or special handling needs.
4.3.4.1 Required: Preparation of product end-of-life characterization report
4.5.1.1 Required: ENERGY STAR
4.5.3.1 Required: Standby power level ≤ 1 W and disclosure
4.5.3.2 Optional: Auto standby capability
4.5.4.1 Optional: Default to automatic duplex printing
4.6.1.2 Optional: Provision of take-back service for broader scope of products
4.6.2.1 Required: End-of-life processing requirements
4.7.1.1 Required: Self-declared environmental management system for design andmanufacturing organizations
4.7.1.2 Optional: Third-party certified environmental management system for design andmanufacturing organizations
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 life-cycle assessment and public disclosure of analyses
4.8.2.1 Required: Separable packing materials
4.8.3.1 Required: Recovered content in select fiber-based packaging materials
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 cartridge or container is not designed to prevent its
reuse and recycling
4.10.1.1 Required: Indoor air quality emission requirements

Outcomes Report
EPEAT Verification Round IE-2017-03
April 2018

Page 12. Summary of Outcomes
Highlights from this Round:••••

47 total investigations assigned
44 decisions of Conformance
2 decisions of Nonconformance
1 investigation cancelled

Figure 1: Overall Conformance Status for IE-201703 (as a percentage of total investigations)
2 1

44Conformance

Nonconformance

Cancelled

Figure 2: Reasons for nonconformance
2.5

2

1.5
Demonstrated
Nonconformance
12

0.5

0

3. Key Lessons
4.3.3.1 Required: Notification regarding the identification of both materials and components thathave hazardous characteristics or special handling needs
Outcomes Report
EPEAT Verification Round IE-2017-03
April 2018

Page 2This criterion requires that manufacturers provide information to reuse and recycling facilities
regarding the presence and location of any materials or components in the product which require
special handling, in accordance with the most recent version of the EU WEEE Directive. A list ofmaterials and components for which this information must be provided is available in Annex VII ofthe WEEE Directive (2012).
4.1.5.1 Required—Compliance with provisions of EU Battery Directive
This criterion requires compliance with the material content limits in the most recent version of theEU Battery Directive for all batteries in the product. If the product does not contain batteries, pleasedeclare “N/A” in the EPEAT Registry, rather than “Yes”.

4. General Message to Manufacturers
Active Products:
Products “Active” on the EPEAT Registry: All Active products on the EPEAT Registry are subject toVerification. When products reach their end of life, Manufacturers should remove the products fromthe EPEAT Registry. If a product which is Active on the EPEAT Registry has reached end of life and aManufacturer cannot obtain required evidence for verification due to the age of the product, itwould still be considered a Non-Conformance.
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 be
prepared 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:
Four (4) Verification Rounds are planned for Imaging Equipment products in 2018.
Conformity Packets:
This and all future Verification Rounds have and will be conducted according to the guidance
provided in the Conformity Packets posted on www.epeat.net under “Key Documents” in My
Account.

Outcomes Report
EPEAT Verification Round IE-2017-03
April 2018

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6. Investigations Table

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

Product TypeCriterion

Requiredor Optional

Criterion Description

NC Finding
Description

Corrective Action Taken

Lexmark
International, Inc.

MX912
XM9165

CanadaMultifunction
Device (MFD)

4.3.3.1

Required

Notification regarding theidentification of both materials andcomponents that have hazardous
characteristics or special handlingneeds

Demonstrated
Nonconformance

Manufacturer provided
evidence of changes maderesulting in conformance.

BrotherInternationalCorporation

HL-L2320D

UnitedStatesPrinter

4.1.5.1

RequiredCompliance with provisions of EU
Battery Directive

Demonstrated
Nonconformance

Manufacturer revised
declaration for criterion

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EPEAT Verification Round IE-2017-03
April 2018

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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 aConformity 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 onevidence 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 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 the
Manufacturer’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 the
Manufacturer’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-2017-03
April 2018

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