EPEAT Program
Continuous Monitoring Outcomes Report
Imaging Equipment
IE-2023-01
November 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 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 IE-2023-01 conductedfor the Imaging Equipment category.

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

Investigation Activities

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

Global Electronics Council

Outcomes Report – Level 2 Investigations (P41A Issue2 Rev2)

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IE-2023-01 Outcomes Report2.2November 21, 2023

Criteria InvestigatedContinuous Monitoring Round IE-2023-01 focused on chemicals of concern. The production of electronics
often involves over 500 chemicals, while electronic devices potentially contain up to 84% of all known stablechemical elements. Chemicals in electronic products and processes serve important technical functions,however they are sometimes used without full knowledge of their environmental or human health hazards.
These chemicals can present risks of exposure throughout the product’s life cycle—and toxic chemicals used increating electronics can cause serious health issues, including cancer, nerve damage, and reproductive issues.
Once released into the environment, hazardous chemicals can also change soil or water, ultimately leading to
the loss of plant or animal life.
In the electronics industry, chemicals of concern remain an on-going challenge as the industry seeks safer andmore sustainable alternatives for hazardous chemical substances. Manufacturers can better prepare for andlessen their risk of supply chain interruptions and high switching costs associated with regulatory restrictions
by having greater clarity into the contents of their devices. Minimizing the use of hazardous chemicals inelectronics and embracing safer alternatives is critical to achieving sustainable consumption and production.
Given the global nature of electronics value chains and the potential reach of problematic chemicals, the socialand economic burden of chemicals of concern in electronics is not confined to certain people or places related
to manufacturing or use—their potential impact can be global in scale, and for this reason, the EPEAT Program
selected criteria which address chemicals of concern for investigation in this Round.
Products were 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 aproduct had not selected a criterion, that criterion was not investigated.
Table 1: Criteria Investigated in Round IE-2023-01
Criteria NumberCriterion Title

4.1.1.1

Compliance with provisions of European RoHS Directive upon its effective date

4.1.2.1
4.1.5.1

Further reduction of the use of European Union RoHS Directive hazardous
substances (cadmium)Compliance with provisions of European Union Battery Directive

4.1.6.1

Reducing BFR/CFR/PVC content of external plastic casings

4.8.1.1

Elimination of intentionally added heavy metals in packaging

3.0 Summary of Investigations and Final Decisions on Conformity for IE-2023-01
Highlights from this Continuous Monitoring Round are:•15 investigations completed•

14 decisions of Conformance•1 decision of Nonconformance

Global Electronics Council

Further details provided in Section 4Outcomes Report – Level 2 Investigations (P41A Issue2 Rev2)

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IE-2023-01 Outcomes Report

November 21, 2023Figure 1: Final Conformity Decisions for IE-2023-01(shown as percentage of total investigations)

4.0 Further Details on Nonconformances for IE-2023-01
Table 2 below provides a 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.
Table 2: Breakdown of Nonconformances by Criterion for IE-2023-01
Criteria Number

Criterion Title

4.1.1.1

Compliance with provisions of European
RoHS Directive upon its effective dateCompleted
Investigations
3Nonconformances
1

Nonconformance
Rate
33%

There was only one non-conformance in Continuous Monitoring Round IE-2023-01, and it was a demonstrated
nonconformance.
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 are
categorized as nonconformances (unless they are due to CAB inaction or delay).
In Continuous Monitoring Round IE-2023-01 there were no minor errors or nonconformances.

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

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IE-2023-01 Outcomes Report

November 21, 2023

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 action was taken to restore accuracy to the EPEAT Registry as a result of Continuous Monitoring
Round IE-2023-01:•1 investigation

Product archived by the CAB or by the EPEAT Program

Table 3 in Section 7 identifies the Participating Manufacturers and products that received nonconformances inContinuous Monitoring Round IE-2023-01.

6.0 Key Findings
6.1

Requirement for Optional Criterion 4.1.2.1— Further reduction of the use of EU RoHS Directive
hazardous substances (Cadmium)Participating Manufacturers and CABs are reminded that Criterion 4.1.2.1 restricts the use of RoHS cadmium
exemptions. Evidence and/or testing must demonstrate that RoHS-allowable cadmium exemptions are notused.
6.2

Required Criterion 4.8.1.1— Elimination of intentionally added heavy metals in packaging

Participating Manufacturers and CABs are reminded that for incidental presence, the sum of theconcentrations of lead, cadmium, mercury, and hexavalent chromium present in any packaging component
shall not exceed 100 ppm by weight. This means the combined total must be less than 100 ppm. Therefore,
when testing to this criterion, the detection limit must be low enough to ensure the combined total is less than100 ppm.

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Outcomes Report – Level 2 Investigations (P41A Issue2 Rev2)

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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 Number

Criterion Title

Required or Optional

Underlying Reason for Nonconformance

Corrective Action Taken

Riso Kagaku Corporation

RISO ComColor FT1430

Printer

United States

4.1.1.1

Compliance with provisions of EuropeanRoHS Directive upon its effective dateRequired

Demonstrated nonconformance

CAB archived product

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Outcomes Report – Level 2 Investigations (P41A Issue2 Rev2)

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IE-2023-01 Outcomes Report

November 21, 2023

Document Control and Change HistoryIssue
1Revision
0Owner
EPEAT Conformity
Assurance Manager
EPEAT Conformity
Assurance Manager
Senior Manager,
Ecolabels andResources11202

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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