EPEAT Program
Continuous Monitoring Outcomes Report
Photovoltaic Modules and Inverters
PV-2023-01
April 20, 2023

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 PV-2023-01 conducted
for the Photovoltaic Modules and Inverters category.

2.0 Overview of Continuous Monitoring Round PV-2023-01
2.1

Investigation Activities

As per the published Round Plan, Continuous Monitoring Round PV-2023-01 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.

Global Electronics Council

Outcomes Report – Level 0 Investigations (P41C Issue1 Rev0)

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2.2

April 20, 2023

Criteria InvestigatedContinuous Monitoring Round PV-2023-01 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 is instead on Criteria which have requirements tomake information publicly available.
Participating Manufacturers received up to three investigations: two of the Criteria selected for investigation
are Required Criteria, and one is an Optional Criterion. As a result, all Participating Manufacturers received atleast two investigations, and a third investigation was assigned if the manufacturer had selected the OptionalCriterion. Products for investigation were selected randomly using a random number generator.
Table 1: Criteria Investigated in Round PV-2023-01
Criteria NumberCriterion Title

5.2.1

Disclosure of substances on the EU REACH Regulation Candidate List of Substances of Very High Concern

7.1.2

Public disclosure of LCA results

11.4.1

Public disclosure of the use of conflict minerals in product3.0 Summary of Investigations and Final Decisions on Conformity for PV-2023-01
Highlights from this Continuous Monitoring Round are:•3 investigations completed•3 decisions of Conformance

4.0 Further Details on Nonconformances for PV-2023-01
No nonconformances or minor errors were identified in Continuous Monitoring Round PV-2023-01.
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. All nonconformances that do not meet the definition of minor errors are categorized asnonconformances (unless they are due to CAB inaction or delay).
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).

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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
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”).
Since there were no nonconformances identified in Continuous Monitoring Round PV-2023-01, no corrective
actions were taken.

6.0 Key Findings
6.1

Annual Disclosure for Criterion 11.4.1

Participating Manufacturers are reminded that Required Criterion 11.4.1 (public disclosure of use of conflictminerals in products) is based on Rule 13p-1 under the US Securities Exchange Act of 1934, which requires anannual disclosure of conflict minerals found. Participating Manufacturers are reminded to ensure their URL
declared in the Registry is accurate year-over-year.
6.2Criterion 5.2.1 - Disclosure of Substances on the EU Reach Regulation Candidate List of SVHC

Participating Manufacturers are reminded that this Criterion requires a link to the list be placed on the productspecification or documentation web page. The manufacturer shall declare the URL of the public disclosure.

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Document Control and Change History
Issue1Revision0

Owner
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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