EPEAT Program
Continuous Monitoring Outcomes Report
Imaging Equipment
IE-2024-02
August 19, 2024

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 nonconformances and the actions taken to restore accuracy of theEPEAT Registry.
This document summarizes the activities and results of Continuous Monitoring Round IE-2024-02 conductedfor the Imaging Equipment category.

2.0 Overview of Continuous Monitoring Round IE-2024-02
2.1

Investigation Activities

As per the published Round Plan, Continuous Monitoring Round IE-2024-02 used Level 0 Investigations, which
involve reviewing publicly available information to determine Participating Manufacturers’ conformance withspecific EPEAT Criteria. GEC-approved CABs had a discrete time period to locate and review publicly available
information to determine conformance with EPEAT Criteria selected for investigation. CABs then maderecommendations on conformity based solely on the publicly available evidence, and sent Investigation
Reports to the EPEAT Program. The EPEAT Program made the final decisions on conformity for theinvestigations.

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2.2

August 19, 2024

Criteria InvestigatedContinuous Monitoring Round IE-2024-02 focused exclusively on criteria that can be evaluated using publicly
available information. While the EPEAT Program generally tries to focus on a specific impact or issue area inselecting criteria for investigation, the focus in this Round was instead on criteria which have requirements tomake information publicly available.
Participating Manufacturers received up to three investigations: two of the criteria selected for investigation
were Required Criteria, and one was an Optional Criterion. As a result, all Participating Manufacturers received
at least two investigations, and a third investigation was assigned if the manufacturer had selected theOptional Criterion. Products for investigation were selected randomly using a random number generator.
Table 1: Criteria Investigated in Round IE-2024-02
Criteria NumberCriterion Title

4.3.4.1

Preparation of product end-of-life characterization report

4.9.3.1

Provision of take-back and end-of-life management for cartridges and containers
Manufacturer recycles or reuses plastic material collected through its cartridge and container take-backprogram

4.9.3.3

3.0 Summary of Investigations and Final Decisions on Conformity for IE-2024-02
Highlights from this Continuous Monitoring Round are:•39 investigations completed•

25 decisions of Conformance•

7 decisions of Inconclusive•

7 decisions of Nonconformance

Further details provided in Section 4

Figure 1: Final Conformity Decisions for IE-2024-02(shown as percentage of total investigations)Global Electronics Council

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Note: For inconclusive findings, the EPEAT Program may require the CAB to investigate the same Criterion in asubsequent Level 1 Round to definitively determine conformance.

4.0 Further Details on Nonconformances for IE-2024-02
Table 2 below provides a further breakdown of the nonconformances by Criterion. All nonconformances must
be categorized as either a minor error, nonconformance, or nonconformance due to CAB inaction or delay not
attributable to the Participating Manufacturer.
Table 2: Breakdown of Nonconformances by Criterion for IE-2024-02
Criteria Number

Criterion Title

Total Nonconformances

4.3.4.1

Preparation of product end-of-life characterization report

24.9.3.1

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

5All nonconformances in Continuous Monitoring Round IE-2024-02 were demonstrated nonconformances.
4.1

Minor Errors Versus Nonconformances

All nonconformances must be categorized as either a minor error, nonconformance, or nonconformance due
to CAB inaction or delay not attributable to the Participating Manufacturer. Minor errors are non-critical or
clerical in nature and do not materially affect the validity of conformance with EPEAT Criteria. Allnonconformances that do not meet the definition of minor errors are categorized as nonconformances (unlessthey are due to CAB inaction or delay).
No minor errors were identified in this Round.
4.2

Minor Errors

For Level 0 Investigations, nonconformances may be categorized as minor errors 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 minors errors were identified in Continuous Monitoring Round IE-2024-02.
4.3

Nonconformances

All nonconformances in Continuous Monitoring Round IE-2024-02 were demonstrated nonconformances,which means that evidence definitively proved the criterion was not met.

5.0 Actions to Restore Conformance
Where the final conformity decision is nonconformance (including minor errors and those due to CAB inaction
or delay), Participating Manufacturers must make corrections to restore the accuracy of the EPEAT Registryduring the Corrective Action Phase. These activities may include providing additional evidence to demonstrate

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conformance with the criterion or unselecting the criteria in the EPEAT Registry. Where the product was foundnonconformant 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 IE-2024-02:•6 investigations

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

Product archived by Participating Manufacturer

Table 3 in Section 7 identifies the Participating Manufacturers and products that received nonconformances inContinuous Monitoring Round IE-2024-02.

6.0 Key Findings
6.1

Required Criterion 4.9.3.1 —Provision of take-back and end-of-life management for cartridges
and containers: Disclosure of URL

Participating Manufacturers are reminded to ensure their Registry disclosure of the URL with required
information for Criterion 4.9.3.1 is correct and up to date for all active EPEAT products.

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7.0 Identification of Nonconformances and Corrections Made by Participating Manufacturers
In the interest of transparency, the EPEAT Program identifies the Participating Manufacturers and products that received nonconformances and the actions taken to restore accuracy of the EPEAT Registry.
Minor errors 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 Nonconformances and Corrections Made by Participating Manufacturers
Participating Manufacturer

ProductProduct TypeCountry

Criterion
NumberLexmark

Multifunction
DeviceUnited States

4.3.4.1

ToshibaLexmark CX825de,
CX825dte, CX825dtfe,
XC8155, XC8155deeStudio 4525AC

United States

4.9.3.1

Brother

HL-L6415DW

Multifunction
DevicePrinter

United States

4.9.3.1

HPHP Color LaserJetManaged MFP
E78228dn (8GS15A)
bizhub C3120i

Multifunction
DeviceUnited States

4.9.3.1

Multifunction
DeviceMultifunction
DevicePrinterCanada

4.9.3.1

United States

4.3.4.1

United States

4.9.3.1

Konica Minolta
KyoceraRiso Kagaku Corporation

Global Electronics Council

KYOCERA ECOSYS
MA2100cwfx
RISO ComColor GD9630

Required orOptional

Underlying Reason for
Nonconformance

Preparation of product end-of-life characterization
reportRequired

Demonstrated nonconformance

Manufacturer provided evidence
demonstrating conformance

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

Required

Demonstrated nonconformance

Required

Demonstrated nonconformance

Required

Demonstrated nonconformance

Manufacturer provided evidence
demonstrating conformance
Manufacturer corrected informationin the EPEAT Registry
Manufacturer provided evidence
demonstrating conformance

Provision of take-back and end-of-life
management for cartridges and containers
Preparation of product end-of-life characterization
reportProvision of take-back and end-of-life
management for cartridges and containers

Required

Demonstrated nonconformance

Required

Demonstrated nonconformance

Required

Demonstrated nonconformance

Criterion Title

Outcomes Report – Level 0 Investigations (P41C Issue1 Rev0)

Corrective Action Taken

Manufacturer corrected informationin the EPEAT Registry
Manufacturer provided evidence
demonstrating conformance
Manufacturer archived the product

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Document Control and Change History
Issue
1Revision0Owner
Senior Manager,
Ecolabels andResources

Global Electronics Council

ApproverVice President,Ecolabels andManufacturer
Resources

Description
Initial release

Outcomes Report – Level 0 Investigations (P41C Issue1 Rev0)

Approval Date
18 Apr 23

Effective Date
19 Apr 23

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