EPEAT Program
Continuous Monitoring Outcomes Report
Imaging Equipment
IE-2022-01
May 23, 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 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 theEPEAT Registry.
This document summarizes the activities and results of Continuous Monitoring Round IE-2022-01 conducted
for the Imaging Equipment category.

2.0 Overview of Continuous Monitoring Round IE-2022-01
2.1

Investigation Activities

As per the published Round Plan, Continuous Monitoring Round IE-2022-01 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 without
involvement 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 onconformity, and sent the reports to the EPEAT Program. The EPEAT Program made the final decisions on
conformity for the Investigations.

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2.2

May 23, 2023

Criteria InvestigatedContinuous Monitoring Round IE-2022-01 focused on circularity and the sustainable use of resources. The
unsustainable use of resources has triggered raw material scarcities, contributed to climate change, andcaused widespread environmental degradation, while also negatively impacting human health.
Sustainable use of resources to enable a circular economy is increasingly a priority for governments,
institutional purchasers, and manufacturers around the globe. Institutional purchasers in both the public andprivate sectors are interested in procuring products and services that further sustainable consumption andproduction, and for these reasons, GEC identified Criteria which contribute to these goals for laboratory
investigation in 2022. Products were randomly selected (using a random number generator) from a list ofParticipating Manufacturers. Each product was investigated for the Criteria identified in the table below,
however if a product had not selected a Criterion, that Criterion was not investigated.
Table 1: Criteria Investigated in Round IE-2022-01
Criteria Number

Criterion Title

4.3.1.1

Ease of disassembly of product4.3.1.2

Ease of disassembly of consumer products

4.3.2.1

Use of single recyclable plastic type per plastic

4.3.2.2

Restriction on materials not compatible with reuse and recycling

4.3.2.3

Manual separation of marking of plastics

4.3.3.1

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

4.8.2.3

3.0 Summary of Investigations and Final Decisions on Conformity for IE-2022-01
Highlights from this Continuous Monitoring Round are:•18 investigations completed•9 decisions of Conformance•1 decision of Inconclusive•

8 decisions of Nonconformance

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Figure 1: Final Conformity Decisions for IE-2022-01(shown as percentage of total investigations)

4.0 Further Details on Nonconformances for IE-2022-01
Table 2 below provides a breakdown of the nonconformances by Criterion. All nonconformances must becategorized 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-2022-01
Criteria Number

Criterion Title

4.3.1.1

Ease of disassembly of 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 handlingneeds
Plastics marked in packaging materials

4.8.2.3

Completed
Investigations
31

Nonconformance
Rate33%

33

100%

3

3

100%

3

133%

Nonconformances

All nonconformances were demonstrated nonconformances, which means evidence definitively showed thatEPEAT Criteria were not met.
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. For Level 2 Investigations,nonconformances may be categorized as minor errors if a GEC-approved CAB is unable to obtain a productfrom the market and the Participating Manufacturer indicated the product has reached end-of-life and is nolonger available on the market. All nonconformances that do not meet the definition of minor errors arecategorized as nonconformances (unless they are due to CAB inaction or delay).
No minor errors were identified in Continuous Monitoring Round IE-2022-01.

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4.2

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Nonconformances

All eight nonconformances were demonstrated nonconformances, which means evidence definitively showedthat EPEAT Criteria were 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
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-2022-01:•3 investigations

Additional data provided by Participating Manufacturers, bringing the products
into conformance with the Criterion•5 investigations

Product archived by Participating Manufacturer

Table 3 in Section 7 identifies the Participating Manufacturers and products that received nonconformances inContinuous Monitoring Round IE-2022-01.

6.0 Key Findings
6.1

4.3.2.1 Required—Use of single recyclable plastic type per plastic part

Required Criterion 4.3.2.1—Use of single recyclable plastic type per plastic part, requires each plastic part>100 g to consist of only one recyclable plastic type. Unlike other product categories, such as Computers andDisplays, the Imaging Equipment category does not reference Annex C in ECMA-341 Design Considerations forICT and CE Products, 4th Edition / December 2010. Therefore, several investigations for Criterion 4.3.2.1 weredetermined to be inconclusive as opposed to either conformant or nonconformant, following ECMA-341. TheEPEAT Program reserves the right to follow up on these inconclusive investigations at a later date.
6.2

Reminder to Check Plastic Marking Codes

Participating Manufacturers are reminded to ensure all discrete plastic parts >100g in the product (that are notexempted in Criterion 4.3.2.3 (Required — Manual separation and marking of plastics) are clearly marked withmaterial type in accordance with ISO 11469/1043. This includes ensuring accurate marking codes for fillers,
plasticizers and flame retardants, and that all marking nomenclature is followed. Similarly, Participating
Manufacturers are reminded to ensure all plastic packaging components that are not exempt in Criterion
4.8.2.3—(Plastics marked in packaging materials), are marked by a protocol for resin identification.

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Review EU WEEE Directive Annex VII Components Applicable to Registered Products Participating
Manufacturers are reminded to ensure that information made available to reuse and recycling facilities
identifies the presence and location of all materials and components requiring selective treatment listed inAnnex VII of the European WEEE Directive, Directive 2012/19/EU of the European Parliament and of theCouncil on waste electrical and electronic equipment (WEEE) and subsequent updates.

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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
NumberEpson

Epson WF-C17590

United States

4.3.2.3

Epson

Epson WF-C17590

Multifunction
DeviceMultifunction
DeviceUnited States

4.3.3.1

Epson

Epson WF-C17590

United States

4.8.2.3

Konica Minolta

Konica Minolta bizhub 4402P

Multifunction
DevicePrinter

United States

4.3.2.3

Konica Minolta

Konica Minolta bizhub 4402P

Printer

United States

4.3.3.1

Sharp

SHARP MX-B467F

United States

4.3.1.1

Sharp

SHARP MX-B467F

United States

4.3.2.3

Sharp

SHARP MX-B467F

Multifunction
DeviceMultifunction
DeviceMultifunction
DeviceUnited States

4.3.3.1

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Required orOptional

Underlying Reason for Nonconformance

Corrective Action Taken

Manual separation and marking ofplastics
Notification regarding theidentification of both materials andcomponents that have hazardous
characteristics or special handlingneeds
Plastics marked in packaging
materials
Manual separation and marking ofplastics
Notification regarding theidentification of both materials andcomponents that have hazardous
characteristics or special handlingneeds
Ease of disassembly of productRequired

Demonstrated nonconformance

Manufacturer archived the productRequired

Demonstrated nonconformance

Manufacturer archived the productRequired

Demonstrated nonconformance

Manufacturer archived the productRequired

Demonstrated nonconformance

Manufacturer archived the productRequired

Demonstrated nonconformance

Manufacturer archived the productRequired

Demonstrated nonconformance

Manual separation and marking ofplastics
Notification regarding theidentification of both materials andcomponents that have hazardous
characteristics or special handlingneeds

Required

Demonstrated nonconformance

Required

Demonstrated nonconformance

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

Criterion Title

Outcomes Report – Level 2 Investigations (P41A Issue2 Rev2)

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

11202

1Senior Manager,
Ecolabels andResources

22Senior 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 24

2023 Mar 24

Outcomes Report – Level 2 Investigations (P41A Issue2 Rev2)

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