EPEAT Program
Continuous Monitoring Outcomes Report
Computers and Displays
CD-2022-03
March 21, 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 called
Rounds. 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 are
required 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 the
EPEAT Registry.
This document summarizes the activities and results of Continuous Monitoring Round CD-2022-03 conducted
for the Computers and Displays category.

2.0 Overview of Continuous Monitoring Round CD-2022-03
2.1

Investigation Activities

As per the published Round Plan, Continuous Monitoring Round CD-2022-03 used Level 1 Investigations(documentation review activities to determine Participating Manufacturers’ conformance with specific EPEAT
Criteria). Participating Manufacturers had a discrete time period to provide their CABs with evidence
supporting conformance with the selected EPEAT Criteria. GEC-approved CABs reviewed the documentation,
made recommendations on conformity based solely on the evidence provided by Participating Manufacturers,
and sent Investigation Reports to the EPEAT Program. The EPEAT Program made the final decisions on
conformity for the Investigations.

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2.2

March 21, 2023

Criteria InvestigatedBoth the products and Criteria for investigation in Continuous Monitoring Round CD-2022-03 were selected
randomly using a random number generator. Each Participating Manufacturer was assigned two investigations,and any manufacturer who received a nonconformance in a 2021 Continuous Monitoring Round were assigned
one additional investigation.
Table 1: Criteria Investigated in Round CD-2022-03
Criteria Number

Criterion Title

4.1.1.1

Conformance with European Union RoHS Directive substance restrictions

4.1.3.1

Elimination of intentionally added mercury in light sources

4.1.4.1

Restriction of the use of beryllium

4.1.5.1

Reduction of bromine and chlorine content in plastic parts >25 g

4.1.5.2

Further reduction of bromine and chlorine content of plastic materials

4.1.6.1

Avoidance or elimination of substances on EU REACH Annex XIV (authorization list)

4.1.7.1

Compliance with provisions of EU Battery Directive

4.1.9.1

IEC 62474 declarable substances

4.1.9.2

Requesting substance inventor

4.1.10.1

Reduce fluorinated gas emissions from flat panel display manufacturing

4.1.10.2

4.3.2.1

Reduce fluorinated greenhouse gas emissions from semiconductor production
Minimum post-consumer recycled plastic, ITE-derived post-consumer recycled plastic or bio based plastic
content
Plastic parts compatible with recycling

4.3.2.2

Plastic parts separable for recycling

4.4.1.1

Service support

4.4.2.1

Removal of external enclosure

4.4.2.4

Battery replacement and information

4.4.2.6

Removal of lithium-ion batteries

4.5.1.1

Conformance to current ENERGY STAR® program requirements

4.5.1.2

4.5.1.5

Lowest power mode limit
Energy efficiency for external power supplies exceeding International External Power Supply Efficiency Level
VI
Product energy consumption less than the ENERGY STAR® Maximum energy limit

4.6.1.1

Provision of product take-back services

4.6.2.1

Provision of a removable rechargeable battery take-back program

4.6.3.1

End-of-life processing

4.7.1.2

Elimination of elemental chlorine as a bleaching agent in packaging material

4.7.2.1

Separable packaging material

4.7.2.2

Plastics marked in packaging materials

4.7.3.1

Recycled content in wood-based fiber packaging

4.8.2.1

Corporate carbon footprint

4.8.2.2

Greenhouse gas emissions from product transport

4.9.1.1

Third party certified environmental management system (EMS) for design and manufacturing organizations

4.9.2.1

Corporate environmental performance reporting by manufacturer

4.9.3.1

Energy management system/energy performance improvement - manufacturers

4.2.1.1

4.5.1.4

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Table 1: Criteria Investigated in Round CD-2022-03
Criteria Number

Criterion Title

4.9.3.2

Energy management system/energy performance improvement - manufacturers

4.10.2.1

Public disclosure regarding conflict minerals in products

3.0 Summary of Investigations and Final Decisions on Conformity for CD-2022-03
Highlights from this Continuous Monitoring Round are:•90 investigations completed•

65 decisions of Conformance•

25 decisions of Nonconformance

Further details provided in Section 4. Of these 25
nonconformances, 19 were due to CAB failure to submit
the Investigation Report.

Figure 1: Final Conformity Decisions for CD-2022-03(shown as percentage of total investigations)

4.0 Further Details on Nonconformances for CD-2022-03
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.

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Table 2: Breakdown of Nonconformances by Criterion for CD-2022-03
Criteria Number

Criterion Title

Total Nonconformances

4.1.1.1

Conformance with European Union RoHS Directive substance restrictions1

4.1.10.1

Reduce fluorinated gas emissions from flat panel display manufacturing1

4.1.10.2

1

4.1.4.1

Reduce fluorinated greenhouse gas emissions from semiconductor
production
Restriction of the use of beryllium

4.1.5.1

Reduction of bromine and chlorine content in plastic parts >25 g2

4.1.7.1

Compliance with provisions of EU Battery Directive1

4.1.9.1

IEC 62474 declarable substances1

4.4.2.4

Battery replacement and information1

4.5.1.1

Conformance to current ENERGY STAR® program requirements1

4.5.1.2

Lowest power mode limit

2

4.5.1.42

4.6.2.1

Energy efficiency for external power supplies exceeding International ExternalPower Supply Efficiency Level VI
Provision of a removable rechargeable battery take-back program

4.6.3.1

End-of-life processing

3

4.7.1.1

Elimination of intentionally added heavy metals in packaging

2

4.8.2.2

Greenhouse gas emissions from product transport1

4.9.1.1

Third party certified environmental management system (EMS) for design andmanufacturing organizations
Corporate environmental performance reporting by manufacturer

2

Energy management system/energy performance improvement manufacturers

1

4.9.2.1
4.9.3.11

11Figure 2 provides a further breakdown by the underlying reason for the nonconformances.
Figure 2: Underlying Reason for Nonconformances in CD-2022-03(shown as a percentage of total 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

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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). One minor error was identified in Continuous Monitoring Round CD2022-03.
4.2

Minor Errors

For Level 1 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 documentation provided by a Participating Manufacturer where the Participating Manufacturer
indicated the product has reached end-of-life and is no longer available on the market.

One minor error was identified in Continuous Monitoring Round CD-2022-03, and it was a demonstrated
nonconformance.
4.3

Nonconformances

Nonconformances may be due to a demonstrated nonconformance, insufficient evidence provided todemonstrate conformance, because no documentation was provided, or due to CAB inaction. All but one
nonconformance in CD-2022-03 were nonconformances, as opposed to minor errors. 19 of thenonconformances were due to CAB inaction or delay not attributable to the Participating Manufacturer.
Since this was a random Round, the Criteria found nonconformant varied. Demonstrated nonconformanceswere found for 4.4.2.4 Battery replacement and information, 4.8.2.2 Greenhouse gas emissions from producttransport, and 4.9.2.1 Corporate environmental performance reporting by manufacturer. Nonconformances
due to insufficient evidence were found for 4.6.3.1 End-of-life processing and 4.7.1.1 Elimination of
intentionally added heavy metals in packaging. No documentation was provided for one 4.5.1.4 Energy
efficiency for external power supplies exceeding International External Power Supply Efficiency Level VI
investigation.
See Section 6 for more information on key findings identified in this Round.
Figure 3 provides a breakdown of the nonconformances found in Round CD-2022-03.

Figure 3: Reasons for Nonconformances for CD-2022-03(shown as a percentage of total nonconformances)

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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”).
The following actions were taken to restore accuracy to the EPEAT Registry as a result of Continuous
Monitoring Round CD-2022-03:•

3 investigations

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

1 investigation

Criterion unselected by the CAB or by the EPEAT Program•

1 investigation

Product archived by the CAB or by the EPEAT Program•

19 investigations

CAB reviewed evidence originally submitted by Participating Manufacturers,
which demonstrated conformance

Table 3 in Section 7 identifies the Participating Manufacturers and products that received nonconformances inContinuous Monitoring Round CD-2022-03.

6.0 Key Findings
6.1

Required Information in Test Reports

All laboratory reports, including those from internal laboratories and accredited third-party laboratories must
contain the following information: laboratory name and location; date testing; identification of product,
component or material evaluated; test method(s) used and if applicable, detection limits; evaluation results;

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sign off from an appropriate party at the laboratory; and if applicable, identification of relevant laboratory
accreditations.
6.2

Criterion 4.1.5.1—Reduction of bromine and chlorine content in plastic parts > 25 g

Criterion 4.1.5.1 excludes printed circuit boards, cables and wiring, fans, and electronic components. Opticalcomponents are not excluded by the criterion and are in scope.
6.3

Conformance with all Elements of a Conformance Assurance Process

A conformance assurance process is defined as:
Process used by the manufacturer to manage compliance of the product to a restricted substancerequirement. The process includes:a) A description of how suppliers, materials, parts, and/or subassemblies risk factors are evaluated andallocated.
b) The utilization of risk rating (or high-risk status) to determine what evidence is required for suppliers,
materials, parts, and/or subassemblies, as determined to be applicable by the manufacturer.
c) The collection and evaluation of the evidence determined necessary for applicability, quality andaccuracy, and associated action taken for a negative result.
d) A procedure to refresh the evidence as appropriate based on the manufacturer’s evaluation of risk.
Participating Manufacturers are reminded to provide evidence for all four elements of a CAP.
6.4

Criterion 4.6.3.1—Conformity Against all Elements of a Criterion

Criterion 4.6.3.1 has multiple elements against which conformance must be shown, including verification
requirement d), which applies to the following programs operated by the manufacturer (or their contractual
agent):•••

Management of leased products where the manufacturer (or their contractual agent) retains legal
ownership.
Trade-in/exchange programs where the customer surrenders the product to the manufacturer (ortheir contractual agent) in return for compensation or replacement product.
Product servicing and/or warranty programs, operated by the manufacturer, or their contractual
agent, where a product (or similar product) is returned to a customer.

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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

Product

Product TypeCountry

Criterion
Number

Ace Computers

Ace Vision X4B560STM

Desktop

United States

4.7.1.1

Positivo Tecnologia S.A.

MASTER C6300 MINIPRO

Desktop

Brazil

4.9.2.1

ASUSTeK Computer Inc.

Notebook

India

4.8.2.2

BenQ

ASUS
B3302FE(Series:B5302FE)
BL2780 (GW2780-T)

MonitorUnited States

4.6.3.1

Acer

B277

MonitorUnited States

4.1.10.2

Acer

Veriton Z4870G

Integrated Desktop
Computer

Italy

4.5.1.2

Acer

VS4680G

Desktop

TaiwanApple

Apple 24-inch iMac

Integrated Desktop
ComputerApple

Apple iPad mini Wi-Fi +Cellular

GoogleGoogleGlobal Electronics Council

Required or
Optional

Underlying Reason for
Nonconformance

Elimination of intentionally added
heavy metals in packaging
Corporate environmental
performance reporting by
manufacturer
Greenhouse gas emissions fromproduct transport
End-of-life processing

Required
RequiredInsufficient evidence todemonstrate conformance
Demonstrated nonconformance

Participating Manufacturer provided
evidence demonstrating conformance
Participating Manufacturer provided
evidence demonstrating conformance

Optional

Demonstrated nonconformance

EPEAT unselected the Criterion

Required

EPEAT archived all products

Reduce fluorinated greenhouse gas
emissions from semiconductor
production
Lowest power mode limit

Optional

4.1.5.1

Reduction of bromine and chlorine
content in plastic parts >25 g

Required

Canada4.5.1.4

Optional

Tablet / Slate

United States

4.1.4.1

Energy efficiency for external power
supplies exceeding International
External Power Supply Efficiency
Level VI
Restriction of the use of beryllium

Insufficient evidence todemonstrate conformance
CAB inaction or delay not
attributable to the Participating
Manufacturer
CAB inaction or delay not
attributable to the Participating
Manufacturer
CAB inaction or delay not
attributable to the Participating
Manufacturer
CAB inaction or delay not
attributable to the Participating
Manufacturer

Google Pixelbook Go Model
G021A

Notebook

United States

4.1.10.1

Reduce fluorinated gas emissions
from flat panel display manufacturing

Optional

Google Pixelbook Go Model
G021A

Notebook

United States

4.1.7.1

Compliance with provisions of EU
Battery Directive

Required

CAB inaction or delay not
attributable to the Participating
Manufacturer
CAB inaction or delay not
attributable to the Participating
Manufacturer
CAB inaction or delay not
attributable to the Participating
Manufacturer

CAB reviewed evidence originallysubmitted by Participating Manufacturers,
which demonstrated conformance
CAB reviewed evidence originallysubmitted by Participating Manufacturers,
which demonstrated conformance
CAB reviewed evidence originallysubmitted by Participating Manufacturers,
which demonstrated conformance

Criterion Title

Required

Optional

Outcomes Report – Level 1 Investigations (P41B Issue2 Rev2)

Corrective Action Taken

CAB reviewed evidence originallysubmitted by Participating Manufacturers,
which demonstrated conformance
CAB reviewed evidence originallysubmitted by Participating Manufacturers,
which demonstrated conformance
CAB reviewed evidence originallysubmitted by Participating Manufacturers,
which demonstrated conformance
CAB reviewed evidence originallysubmitted by Participating Manufacturers,
which demonstrated conformance

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LenovoThinkCentre M80q (CTO
EPEAT Gold Model)

Desktop

Canada4.9.1.1

Third party certified environmental
management system (EMS) for
design and manufacturingorganizations
IEC 62474 declarable substances

Required

CAB inaction or delay not
attributable to the Participating
Manufacturer

CAB reviewed evidence originallysubmitted by Participating Manufacturers,
which demonstrated conformance

LenovoThinkStation P340 SFF

Workstation

United States

4.1.9.1

Optional

4.1.1.1

Conformance with European Union
RoHS Directive substance restrictions

Required

Sweden4.6.3.1

End-of-life processing

Required

Notebook

Croatia

4.9.3.1

Optional

Surface Pro X (model 1876,
2010)

Tablet / slate

Latvia4.9.1.1

CAB reviewed evidence originallysubmitted by Participating Manufacturers,
which demonstrated conformance
CAB reviewed evidence originallysubmitted by Participating Manufacturers,
which demonstrated conformance
CAB reviewed evidence originallysubmitted by Participating Manufacturers,
which demonstrated conformance
CAB reviewed evidence originallysubmitted by Participating Manufacturers,
which demonstrated conformance
CAB reviewed evidence originallysubmitted by Participating Manufacturers,
which demonstrated conformance

Panasonic

TOUGHBOOK 33

Notebook

United States

4.5.1.2

Energy management system/energy
performance improvement manufacturers
Third party certified environmental
management system (EMS) for
design and manufacturingorganizations
Lowest power mode limit

CAB inaction or delay not
attributable to the Participating
Manufacturer
CAB inaction or delay not
attributable to the Participating
Manufacturer
CAB inaction or delay not
attributable to the Participating
Manufacturer
CAB inaction or delay not
attributable to the Participating
Manufacturer
CAB inaction or delay not
attributable to the Participating
Manufacturer

LenovoThinkVision T23i-20

MonitorCanadaMicrosoft

Surface Go 2 (model 1901,
1926, 1927)

Tablet / slate

Microsoft

Surface Laptop Go (model
1943)

Microsoft

Panasonic

TOUGHBOOK A3

Tablet / slate

United States

4.1.5.1

Reduction of bromine and chlorine
content in plastic parts >25 g

RequiredPanasonic

TOUGHPAD M1

Tablet / slate

United States

4.6.3.1

End-of-life processing

Required

Samsung

F24T454GY*

MonitorAustralia

4.7.1.1

Elimination of intentionally added
heavy metals in packaging

Required

Samsung

S22E450D

MonitorUnitedKingdom

4.6.2.1

Required

Samsung

S24A608NWN

MonitorSwitzerland

4.5.1.1

Provision of a removable
rechargeable battery take-backprogram
Conformance to current ENERGYSTAR® program requirements

IGEL Technology GmbH

UD3 M350C

Thin Client

United States

4.5.1.4

Energy efficiency for external power
supplies exceeding International
External Power Supply Efficiency
Level VI

Optional

CAB inaction or delay not
attributable to the Participating
Manufacturer
CAB inaction or delay not
attributable to the Participating
Manufacturer
CAB inaction or delay not
attributable to the Participating
Manufacturer
CAB inaction or delay not
attributable to the Participating
Manufacturer
CAB inaction or delay not
attributable to the Participating
Manufacturer
CAB inaction or delay not
attributable to the Participating
Manufacturer
No documentation provided

CAB reviewed evidence originallysubmitted by Participating Manufacturers,
which demonstrated conformance
CAB reviewed evidence originallysubmitted by Participating Manufacturers,
which demonstrated conformance
CAB reviewed evidence originallysubmitted by Participating Manufacturers,
which demonstrated conformance
CAB reviewed evidence originallysubmitted by Participating Manufacturers,
which demonstrated conformance
CAB reviewed evidence originallysubmitted by Participating Manufacturers,
which demonstrated conformance
CAB reviewed evidence originallysubmitted by Participating Manufacturers,
which demonstrated conformance
Participating Manufacturer unselected
the Criterion

Global Electronics Council

Required

Required

Required

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Document Control and Change History
Issue
1

Revision0

Owner
EPEAT Conformity
Assurance Manager
EPEAT Conformity
Assurance Manager
Senior Manager,
Ecolabels andResources

1

1

2

0

2

1

Senior Manager,
Ecolabels andResources2

2

Senior Manager,
Ecolabels andResources

Global Electronics Council

ApproverDirector, EPEAT
ProgramDirector, EPEAT
Program
Senior Director,
Ecolabels andManufacturer
Resources
Vice President,
Ecolabels andManufacturer
Resources
Vice President,
Ecolabels andManufacturer
Resources

Description
Initial release

Approval Date

Effective Date2018 Dec 112018 Dec 11

Reformatting of document. Addition ofstandardized text.

2021 Mar 25

2021 Mar 30

Updated terminology fornonconformances to include“nonconformances” and “minor errors”,
in alignment with revisions to P66.
Updated to reflect new nonconformance
category for CAB inaction or delay

2022 Sep 152022 Sep 30

2023 Mar 92022 Mar 13

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