Green Electronics Council
227 SW Pine Street, Suite 300 • Portland, OR 97204 • V: (503) 279-9382 • F: (503) 279-9381 • www.epeat.net

OUTCOMES REPORT - UPDATEDEPEAT VERIFICATION ROUND IE-2017-02
1. Overview of Verification Round
Verification Round IE-2017-02 for the IEEE 1680.2TM Standard for the Environment Assessment ofImaging Equipment investigated the following 12 criteria:•4.1.1.1 - Required – Compliance with provisions of European Union RoHS Directive•

4.1.2.1 - Optional – Further reduction of the use of EU RoHS Directive hazardous substances(cadmium)•4.1.4.1 - Optional – Reduction of substances on the EU REACH Candidate List of SVHCs•

4.1.6.1 - Required – Reducing BFR/CFR/CDP content of external plastic casings•

4.3.1.1 - Required – Ease of disassembly of product•4.3.1.2 - Optional – Ease of disassembly of consumer products•

4.3.2.1 - Required – Use of single recyclable plastic type per plastic part•4.3.2.2 - Required – Restriction on materials not compatible with reuse and recycling•

4.8.1.1 - Required – Elimination of intentionally added heavy metals in packaging•

4.8.2.1 - Required – Separable packing materials•

4.8.2.2 - Optional – Packaging 90% compostable/recyclable•

4.8.2.3 - Required – Plastics marked in packaging materials

This Round was intended to assure conformance for Imaging Equipment. This Round involved lab
evaluation of 3 randomly chosen Imaging Equipment products from Manufacturers who had not yet
had full Level 2 / 3 lab testing. The Round planned for no more than 36 investigations and finally
included 32 Level 1, Level 2, and 3 investigations. Some chosen products didn’t claim one or more of
the optional criteria, so the total number of investigations completed was fewer than planned. In
Level 2 and 3 investigations a lab chosen by the Conformity Assurance Body (CAB) acquires products
without the Manufacturer’s knowledge, if possible, disassembles them, and conducts detailed
analytical testing, as needed.
CABs with active Imaging Equipment products and with Manufacturers whose products had not yet
been involved in Level 2 and 3 investigations to date were eligible for inclusion in this Round. Eachchosen CAB had lab testing completed on no more than 2 products. Each chosen Manufacturer hadlab testing completed for no more than 1 product. Products were chosen from a list of activeproducts.

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EPEAT Verification Round IE-2017-02

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The Investigations were chosen as follows:• The nine required criteria were investigated for the chosen products.
•For the four optional criteria, each chosen product was investigated for each optional
criterion declared.

During this Verification Round, some of the chosen products cost more than $10,000. Per GEC’s
policy, the scheme worked with the CABs to determine how to verify the product. Ten of theinvestigations in this round were changed to Level 1 due to the high cost of the chosen products.

2. Summary of Outcomes
Highlights from this Verification Round:• 32 investigations completed•

23 decisions of Conformance•

9 decisions of Non-Conformance

Overall Conformance Status for IE-2017-02

28%

72%

Conformance

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EPEAT Verification Round IE-2017-02

Non-Conformance

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Number of each type of investigation

1022

Level 2/3

Level 1

Reasons for Non-Conformances

No documentation
provided35Insufficient
documentation to prove
conformance
Demonstrated nonconformance1

Table 1 below summarizes the number of investigations that were planned and which investigations
resulted in a decision of Non-Conformance.

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May 2018

TABLE 1: Summary of Non-Conformance Findings
Criterion
4.1.1.1
4.1.2.1

4.1.4.1
4.1.6.1

Description
Required
Optional

Optional
RequiredInvestigations

Non-Conformant

Compliance with provisions ofEuropean Union RoHS Directive31

Further reduction of the use of EU
RoHS Directive hazardous
substances (cadmium)31

Reduction of substances on the EU
REACH Candidate List of SVHCs

21

Reducing BFR/CFR/CDP content of
external plastic casings31

4.3.1.1

RequiredEase of disassembly of product31

4.3.1.2

Optional

Ease of disassembly of consumer
products

30

Use of single recyclable plastic type
per plastic part3

1

Restriction on materials notcompatible with reuse
and recycling

31

Elimination of intentionally added
heavy metals in packaging

31

4.3.2.1
4.3.2.2

4.8.1.1

Required
Required

Required

4.8.2.1

Required

Separable packing materials

31

4.8.2.2

Optional

Packaging 90%
compostable/recyclable

30

Plastics marked in packaging
materials

30

4.8.2.3

Required

3. Key Lessons
Criterion 4.1.4.1: Reduction of substances on the EU REACH Candidate List of SVHCs
Due to the controversy regarding the definition of an “article” in EU REACH, Manufacturers andSuppliers should err on the conservative side regarding what part they are claiming as an “article”.
Failure to choose an article at the right level (assembly versus sub-assembly) may lead to a NonConformance.
Acquiring Products for Lab Testing
In one case, a product and / or spare parts were unable to be obtained by the Auditor / Lab which
resulted in six Non-Conformances. If a product is chosen from the EPEAT Registry to be Level 2 / 3tested, the Auditor and / or Manufacturer must make every effort to procure the product and / orspare parts for testing. Failure to do so will result in Non-Conformances for all criteria planned forinvestigation and removal of the product from the EPEAT Registry.
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New Labs should be educated regarding EPEAT
For one product, a new lab found two investigations to be Non-Conformant. However, upon further
examination of the evidence and lab report, it was established that the product was not actually
Non-Conformant to the two criteria. While lab testing is different than a desk review or averification investigation, it is helpful to share information such as Conformity Guidance Packets
with the labs, so they have the information needed to make informed decisions.

4. General Message to Manufacturers
Understanding documentation requirements for Verification Rounds:
You can find more guidance and examples of conformance documents in the Conformity Guidance
Packets located in “Key Documents” under My Account. Go to epeat.net to log in.
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 beprepared 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:
A full Auditor Training will be held in Portland, Oregon during the first half of July 2018. If you areinterested in attending, please contact Rebecca Hawkins at rhawkins@greenelectronicscouncil.org.
Conformity Guidance Packets:
This and all future Verification Rounds have and will be conducted according to the guidance
provided in the Conformity Sample Packets posted on www.epeat.net under “Key Documents” inMy Account.

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6. Investigation Table – Summary of Non-Conformance Findings
TABLE 2: Specific Non-Conformance Findings and Corrective Action Taken
Participating
Manufacturer

ProductCountry

Product Type

Criterion

Requiredor Optional

Criterion Description

NC Finding Description

Corrective Action Taken

ToshibaeStudio6570cparts chosen byEPEAT

UnitedStates

Multifunction
Device (MFD)

4.1.1.1Required

ToshibaeStudio6570c
parts chosen byEPEAT

UnitedStatesMultifunction
Device (MFD)

4.1.2.1

Optional

Required – Compliance with
provisions of European
Union RoHS Directive
Optional – Further
reduction of the use of EU
RoHS Directive hazardous
substances (cadmium)ToshibaeStudio6570c
case parts
chosen by EPEAT

UnitedStatesMultifunction
Device (MFD)

Required

Required – Reducing
BFR/CFR/CDP content of
external plastic casingsNo
documentation
provided / No
product acquiredNo
documentation
provided / No
product acquiredNo
documentation
provided / No
product acquired

ToshibaeStudio6570c
parts over 100 gchosen by EPEAT

Required

Required – Use of single
recyclable plastic type perplastic partNo
documentation
provided / No
product acquired

Product archived by
Manufacturer.

ToshibaeStudio6570c
case parts
chosen by EPEAT

Required

Required – Restriction onmaterials not compatible
with reuse and recyclingNo
documentation
provided / No
product acquired

Product archived by
Manufacturer.

Required – Elimination ofintentionally added heavy
metals in packaging

Insufficient
documentation
to prove
conformance

Product archived byManufacturer.

ToshibaeStudio6570ccase parts
chosen by EPEAT

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EPEAT Verification Round IE-2017-02

UnitedStatesUnitedStatesUnitedStatesMultifunction
Device (MFD)

Multifunction
Device (MFD)

Multifunction
Device (MFD)

4.1.6.1

4.3.2.1

4.3.2.2

4.8.1.1

Required

Product archived by
Manufacturer.

Product archived by
Manufacturer.

Product archived by
Manufacturer.

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TABLE 2: Specific Non-Conformance Findings and Corrective Action Taken
Participating
Manufacturer

KonicaMinolta

Sharp

Sharp

Product

bizhub C754e
parts chosen byEPEAT

MX-M266N

MX-M266N

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EPEAT Verification Round IE-2017-02

CountryAustralia

UnitedStatesUnitedStates

Product TypeMultifunction
Device (MFD)

Multifunction
Device (MFD)

Multifunction
Device (MFD)

Criterion

4.1.4.1

4.3.1.1

4.8.2.1

Requiredor Optional

Optional

Required

Required

Criterion Description

NC Finding Description

Corrective Action Taken

Optional – Reduction ofsubstances on the EU
REACH Candidate List ofSVHCs

Demonstrated
nonconformance

Criterion undeclared by
Manufacturer.

Demonstrated
nonconformance

If NC due todemonstrated nonconformance,
Manufacturer provided
evidence of changes
made resulting inconformance.

Demonstrated
nonconformance

If NC due todemonstrated nonconformance,Manufacturer provided
evidence of changes
made resulting inconformance.

Required – Ease ofdisassembly of productRequired – Separable
packing materials

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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 aregiven 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 on
evidence 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 theManufacturer’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 theManufacturer’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.

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