EPEAT Program
Continuous Monitoring Outcomes Report
Imaging Equipment
IE-2020-01
January 11, 2022

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 major nonconformances and the actions taken to restore accuracyof the EPEAT Registry.
This document summarizes the activities and results of Continuous Monitoring Round IE-2020-01 conducted
for the Imaging Equipment category.

2.0 Overview of Continuous Monitoring Round IE-2020-01
2.1

Investigation Activities

As per the published Round Plan, Continuous Monitoring Round IE-2020-01 used Level 2 Investigations(laboratory evaluation of products to determine the products’ conformance with specific EPEAT Criteria). GECapproved CABs obtained the products, as identified by the EPEAT Program, from the open market withoutinvolvement of the Participating Manufacturers, where possible, and sent them for laboratory evaluation. The
laboratories evaluated the products against the specified Criteria and produced reports summarizing theactivities conducted and the results. GEC-approved CABs reviewed the reports, made recommendations on
conformity, and sent the reports to the EPEAT Program. The EPEAT Program made the final decisions on
conformity for the Investigations.

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2.2January 11, 2022

Criteria InvestigatedContinuous Monitoring Round IE-2020-01 focused on Criteria related to the sustainable use of resources.
Products are randomly selected (using a random number generator) from a list of Participating Manufacturers.
Each product was investigated for the Criteria identified in the table below, however if a product had notselected a Criterion, that Criterion was not investigated.
Table 1: Criteria Investigated in Round IE-2020-01
Criteria Number

Criterion Title

4.3.1.1

Ease of disassembly of product4.3.1.2

Ease of disassembly of consumer products

4.3.2.2

Restriction on materials not compatible with reuse and recycling

4.3.2.3

Manual separation and marking of plastics

4.3.3.1
4.8.2.1

Notification regarding the identification of both materials and components that have hazardous
characteristics or special handling needs
Separable packaging materials

4.8.2.2

Packaging 90% compostable / recyclable

4.8.2.3

Plastics marked in packaging materials

3.0 Summary of Investigations and Final Decisions on Conformity for IE-2020-01
Highlights from this Continuous Monitoring Round are:
•20 investigations completed•

15 decisions of Conformance•

5 decisions of Nonconformance

Further details provided in Section 4Figure 1: Final Conformity Decisions for IE-2020-01(shown as percentage of total investigations)Global Electronics Council

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4.0 Further Details on Nonconformances for IE-2020-01
Table 2 below provides a breakdown of the nonconformances by Criterion.
Table 2: Breakdown of Nonconformances by Criterion for IE-2020-01
Criteria Number

Criterion Title

4.3.1.1

Ease of disassembly of a product4.3.2.3

Manual separation and marking of plastics

4.3.3.1

Notification regarding the identification ofboth materials and components that havehazardous characteristics or special handlingneedsCompleted
Investigations
31

Nonconformance
Rate
33%

3267%

3267%

Nonconformances

All nonconformances in this Round were major, demonstrated nonconformances, meaning evidence
submitted definitively showed that the Criterion was not met.
4.1

Major Versus Minor Nonconformances

All nonconformances must be categorized as either major or minor. For Level 2 Investigations,nonconformances may be categorized as minor only if a GEC-approved CAB is unable to obtain a product fromthe market and the Participating Manufacturer indicates the product has reached end-of-life and is no longer
available on the market. All nonconformances that do not meet the definition of minor are categorized asmajor.
All nonconformances in Continuous Monitoring Round IE-2020-01 were major nonconformances, and all werecategorized as demonstrated nonconformances because the evidence submitted definitively showed that theCriterion was not met.
4.2

Major Nonconformances

In this Round, major nonconformances pertaining to the following three Criteria were identified:
Criterion 4.3.1.1 Ease of disassembly of a product requires the laboratory to disassemble and evaluate theproduct to ensure it provides ease of access to materials with special handling needs. This includes ensuringexternal enclosures, chassis, and electronic subassemblies are removable by hand or with commonly available
tools; that the product utilizes commonly used fasteners; and that non-separable connections are avoided. TheCriterion also requires all disassembly for recycling purposes to be able to be done exclusively with commonly
available tools or by hand with sufficient access to points of connection and clearance and for electrical andcommunication wiring and cables and whole external power supplies to be removable by hand or with
commonly available tools. The Criterion does allow for exemptions for some of the requirements due to safety,legal, technical and/or anti-theft reasons. All of these items must be met to demonstrate conformance.
Criterion 4.3.2.3 Manual separation and marking of plastics requires plastic parts >100 g to be manuallyseparable into recyclable plastic streams with commonly available tools and for those parts to be marked witha material code in accordance with ISO 11469. The marking codes must meet all requirements of ISO 11469 orthe product is nonconformant.

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4.3.3.1 Notification regarding the identification of both materials and components that have hazardous
characteristics or special handling needs requires manufacturers to make information identifying thepresence and location of all materials and components exhibiting hazardous characteristics or requiring special
handling (defined as those identified in the EU WEEE Directive) available to reuse and recycling facilities, andto ensure these materials are safely and easily identifiable. In Level 2 Rounds which involve laboratory testing,the documentation provided to reuse and recycling facilities is reviewed. All applicable materials in the productmust be identified in the documentation and be easily identifiable.

5.0 Actions to Restore Conformance
Where the final conformity decision is nonconformance (whether major or minor), Participating Manufacturers
must make corrections to restore the accuracy of the EPEAT Registry during the Corrective Action Phase. Theseactivities may include providing additional evidence to demonstrate conformance with the criterion or
unselecting the criteria in the EPEAT Registry. Where the product was found nonconformant 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-2020-01:•2 investigations

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

3 investigations

Product archived by Participating Manufacturer

Table 3 in Section 7 identifies the Participating Manufacturers and products that received major
nonconformances in Continuous Monitoring Round IE-2020-01.

6.0 Key Findings
6.1

Conformity Against All Elements of 4.3.1.1

Participating Manufacturers must ensure that all Criterion elements are met, including ease of access toidentified components and use of common fasteners, and avoidance of non-separable connections unlessrequired for safety, legal, technical and/or anti-theft reasons.
6.2

Review Plastic Material Codes on Plastics >100g

Participating Manufacturers are reminded to check applicable plastic parts to ensure they are marked
according to ISO 11469.

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6.3

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Ensure Presence and Location of all Materials and Components Exhibiting Hazardous
Characteristics or Requiring Special Handling is Easily Identifiable

Participating Manufacturers are reminded to review all materials and components listed in Annex VII of theEuropean WEEE Directive 2012/19/EU and ensure documentation provided to reuse and recycling facilities
identifies all materials and components present in the product.

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

ProductProduct Type

Criterion Number

Criterion Title

Required orOptional

Underlying Reason for
Nonconformance

Corrective Action Taken

Canon

WG7250Z

Multifunction device

4.3.1.1

Ease of disassembly of productRequired

Demonstrated nonconformance

Manufacturer archived product

Canon

WG7250Z

Multifunction device

4.3.2.3

Manual separation and marking of plastics

Required

Demonstrated nonconformance

Manufacturer archived product

Canon

WG7250Z

Multifunction device

4.3.3.1

Required

Demonstrated nonconformance

Manufacturer archived product

RicohRICOH IM 430Fb TLMultifunction device

4.3.3.1

Required

Demonstrated nonconformance

Manufacturer provided evidence
demonstrating conformance

Xerox

Xerox B210 PrinterPrinter

4.3.2.3

Notification regarding the identification of both materials andcomponents that have hazardous characteristics or special
handling needs
Notification regarding the identification of both materials andcomponents that have hazardous characteristics or special
handling needs
Manual separation and marking of plastics

Required

Demonstrated nonconformance

Manufacturer provided evidence
demonstrating conformance

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Document Control and Change History
Issue
1Revision01120

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

Global Electronics Council

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

Description
Initial release

Reformatting of document. Addition ofstandardized text.

Outcomes Report – Level 2 Investigations (P41A Issue2 Rev0)

Approval Date

Effective Date2018 Dec 112018 Dec 112021 Mar 25

2021 Mar 30

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