EPEAT Program
Continuous Monitoring Outcomes Report
Computers and Displays
CD-2021-02
November 17, 2021

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 major nonconformances and the actions taken to restore accuracyof the EPEAT Registry.
This document summarizes the activities and results of Continuous Monitoring Round CD-2021-02 conducted
for the Computers and Displays product category.

2.0 Overview of Continuous Monitoring Round CD-2021-02
2.1

Investigation Activities

As per the published Round Plan, Continuous Monitoring Round CD-2021-02 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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Criteria Investigated

The products and Criteria selected for investigation in Continuous Monitoring Round CD-2021-02 wereselected randomly using a random number generator.
Table 1: Criteria Investigated in Round CD-2021-02
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

4.1.6.2

Reduction of substances on the EU REACH Candidate List of SVHCs

4.1.7.1

Compliance with provisions of EU Battery Directive

4.1.9.1

IEC 62474 declarable substances

4.1.9.3

Acquiring substance inventory

4.1.10.2

Reduce fluorinated greenhouse gas emissions from semiconductor production

4.10.2.1

Public disclosure regarding conflict minerals in products

4.10.2.2

4.3.1.1

Participation in an in-region program that advances responsible sourcing of conflict minerals
Minimum post-consumer recycled plastic, ITE-derived post-consumer recycled plastic or bio based plastic
content
Identification of materials and components requiring selective treatment

4.3.2.2

Plastic parts separable for recycling

4.4.1.1

Service support

4.4.2.1

Removal of external enclosure

4.4.2.3

Spare parts

4.4.2.4

Battery replacement information

4.5.1.1

Conformance to current ENERGY STAR® program requirements

4.5.1.2

Lowest power mode 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

4.7.1.1

Elimination of intentionally added heavy metals in packaging

4.7.1.2

Elimination of elemental chlorine as a bleaching agent in packaging material

4.7.2.1

Separable packaging material

4.8.1.1

Product lifecycle assessment and public disclosure of analysis

4.8.1.2

Product specific greenhouse gas emissions - product carbon footprint

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

4.9.1.2

Third party certified environmental management system (EMS) for supplier manufacturing facilities

4.9.2.1

Corporate environmental performance reporting by manufacturer

4.9.2.2

Corporate environmental performance reporting by suppliers

4.9.3.1

Energy management system/energy performance improvement - manufacturers

4.2.1.1

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Table 1: Criteria Investigated in Round CD-2021-02
Criteria Number

Criterion Title

4.9.3.2

Energy management system/energy performance improvement for suppliers

3.0 Summary of Investigations and Final Decisions on Conformity for CD-2021-02
Highlights from this Continuous Monitoring Round are:•61 investigations completed•

52 decisions of Conformance•

9 decisions of Nonconformance

Further details provided in Section 4•

7 investigations cancelled[Due to CAB transfers, or product archival before start of Round]Figure 1: Final Conformity Decisions for CD-2021-02(shown as percentage of total investigations)

4.0 Further Details on Nonconformances for CD-2021-02
Table 2 below provides a further breakdown of the nonconformances by Criterion.
Table 2: Breakdown of Nonconformances by Criterion for CD-2021-02
Criteria Number

Criterion Title

Total Nonconformances

4.1.1.1

Conformance with European Union RoHS Directive substance restrictions

1

4.1.3.1

Elimination of intentionally added mercury in light sources1

4.1.5.2

Further reduction of bromine and chlorine content of plastic materials

1

4.1.6.2

Reduction of substances on the EU REACH Candidate List of SVHC’s

1

4.6.3.1

End-of-life processing

1

4.8.1.2

Product specific greenhouse gas emissions- product carbon footprint

1

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Table 2: Breakdown of Nonconformances by Criterion for CD-2021-02
Criteria Number

Criterion Title

Total Nonconformances

4.8.2.2

Greenhouse gas emissions from product transport

1

4.9.3.2

Energy management system/energy performance improvement for suppliers

1

4.10.2.2

Participation in an in-region program that advances responsible sourcing ofconflict minerals

1

Figure 2 provides a further breakdown by the underlying reason for the nonconformances.
Figure 2: Underlying Reason for Nonconformances in CD-2021-02(shown as a percentage of total nonconformances)

4.1

Major Versus Minor Nonconformances

All nonconformances must be categorized as either major or minor. Minor nonconformances are non-criticalor clerical in nature and do not materially affect the validity of conformance with EPEAT Criteria. Allnonconformances that do not meet the definition of minor are categorized as major.
All nonconformances for Continuous Monitoring Round CD-2021-02 were major nonconformances.
4.2

Minor Nonconformances

For Level 1 Investigations, nonconformances may be categorized as minor 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.

There were no minor nonconformances found in Continuous Monitoring Round CD-2021-02.

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Major Nonconformances

Major nonconformances may be due to a demonstrated nonconformance, insufficient evidence provided todemonstrate conformance, or because no documentation was provided. All nine nonconformances found in
this Round were major nonconformances. Four of the major nonconformances were due to no documentation
being provided; three of the major nonconformances were due to insufficient evidence provided; and two of
the major nonconformances were demonstrated nonconformances. Due to the fact that this was a Continuous
Monitoring Round where Criteria were randomly selected, the nonconformances were all for different Criteria.
During Continuous Monitoring Rounds, Participating Manufacturers are responsible for compilingdocumentation and submitting it to their CAB in an organized and timely manner. Evidence must be submitted
before the end of the Investigation Phase. If a Participating Manufacturer does not provide documentation
during the Investigation Period, this will always result in a major nonconformance due to no documentation
provided, unless the product is end-of-life and no longer available on the market.
The remaining nonconformances in this Round were due to a demonstrated nonconformance or insufficientevidence provided.
Criterion 4.1.1.1 (Conformance with European Union ROHS Directive substance restrictions) requires
Participating Manufacturers to provide evidence of the implementation of their conformance assurance
process or technical documentation that is used ensure the investigated product complies with the substance
restriction requirements of the European Union (EU) RoHS Directive and its amendments.
Criterion 4.1.3.1 (Elimination of intentionally added mercury in light sources) requires Participating
Manufacturers to provide evidence that all light sources in the investigated product do not containintentionally added mercury.
Criterion 4.6.3.1 (End-of-life processing) requires manufacturers to ensure all equipment collected as part oftheir take-back program pursuant to 4.6.1.1 is recycled by recyclers meeting all requirements outlined in the
Criterion and that products returned through the following programs meet transboundary requirements andare processed by a recycler meeting all Criterion requirements:•••

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.

Criterion 4.8.2.2 (Greenhouse gas emissions from product transport) requires the Participating Manufacturer
to conduct an annual assessment of greenhouse gas emissions resulting from product transport and make asummary of the results and their goals and progress publicly available.
Criterion 4.10.2.2 requires Participating Manufacturers to support and/or participate in a responsible sourcing
program that meets all objectives identified in the Criterion.
Figure 3 provides a breakdown of the major nonconformances found in Round CD-2021-02.

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Figure 3: Reasons for Major Nonconformances for CD-2021-02(shown as a percentage of total major nonconformances)

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. 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 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 CD-2021-02:•

4 investigations

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

5 investigations

Criterion unselected by Participating Manufacturer

Table 3 in Section 7 identifies the Participating Manufacturers and products that received major
nonconformances in Continuous Monitoring Round CD-2021-02.

6.0 Key Findings
6.1

Conformity Against All Elements of a Criterion (4.6.3.1)

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.

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•
•

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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.
Conformity Against All Elements of a Criterion (4.10.2.2)

Criterion 4.10.2.2 requires Participating Manufacturers to support and/or participate in an in-region conflictminerals responsible sourcing program in a covered country or conflict-affected and high-risk regions. The
responsible sourcing program must include, at the mine level, one or more of the following objectives:
improved governance, capacity building, traceability, and/or conflict and human rights risks. A description of
the program’s commitment to engage local stakeholders must also be provided and the program must identify
and address risks or gaps according to the program scope.
6.3

Implementation of Procedures for Reduction of Use of Hazardous Substances

For criteria that require conformance assurance processes, technical documentation, or other reductions ofuse of hazardous substances, Participating Manufacturers must show implementation of their procedures forthe investigated product.
6.4

Evidence for Accreditation Requirements

Several Criteria in the Computers and Displays category, (e.g., 4.9.1.1 Required - Third party certified
environmental management system (EMS) for design and manufacturing organizations), require the EMS
certification to come from a certification body accredited by an accreditation body that is a signatory to the IAF
MLA with the appropriate scope of accreditation. Participating Manufacturers are reminded to submit
information alongside other evidence.
6.5

Annual Reporting

Several corporate Criteria in the Computers and Displays category have annual reporting requirements (e.g.,
4.10.2.1 Required—Public disclosure regarding conflict minerals in products). Annual reporting means that
updated data is released once every 12-month period. The 12-month period itself can vary, for example, it may
be disclosed on a calendar year or a fiscal year. The 12-month reporting period can be changed, but there
cannot be a gap in the disclosure, (e.g., cannot skip reporting for a period of time). In these cases, we expect
manufacturers to inform their CABs of changes to reporting schedules.
6.6

Auditor Credentials

Several corporate Criteria in the Computers and Displays category require third party verification of theassessment (e.g., 4.8.2.2 Optional — Greenhouse gas emissions from product transport). Often these criteria
require the third-party verification documentation to include contact information, credentials, andqualifications of the third-party verifier. Participating Manufacturers are reminded to ensure these third-party
verification documents contain all necessary information.

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Selecting Criteria in EPEAT Registry

Participating Manufacturers are reminded they are responsible for only selecting EPEAT Criteria to which they
can prove conformance.

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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

Product

Product TypeCountry

Criterion
Number

Ace Computers

Ace Mustang W640

Notebook

United States

4.1.1.1

Algoritmos Procesos yDisenos, S.A.
Ciara TECHAPD ALDA PRO

DesktopSpain

4.8.1.2

Kronos 540

Desktop

Canada4.1.5.2

IGEL Technology GmbH

UD3 M350C

Thin client

United States

4.6.3.1

Positivo Tecnologia S.A.

MASTER A2200

Brazil

4.1.6.2

TRANSOURCE SERVICES
CORP.
ViewSonic

SCORCH 1050

Integrated
Desktop
Desktop

United States

4.1.3.1

ViewSonic / VS16503 / VP2771

MonitorCanada4.8.2.2

Zebra Technologies

Zebra ET51 Enterprise Rugged
Tablet WLAN (8”)
Zebra L10 Rugged Tablets (XPAD,XSLATE, XBOOK)

Tablet/Slate

United States

4.10.2.2

Tablet/Slate

United States

4.9.3.2

Zebra Technologies

Global Electronics Council

Required or
Optional

Underlying Reason for
Nonconformance

Conformance with European Union RoHS Directive
substances restrictions
Product specific greenhouse gas emissions –product carbon footprint
Further reduction of bromine and chlorine content
of plastic partsEnd-of-life processing

Required
Optional

Demonstrated
nonconformance
No documentation provided

Optional

No documentation provided

Required

Reduction of substances on the EU REACH
Candidate List of SVHCs
Elimination of intentionally added mercury in lightsources
Greenhouse gas emissions from product transport

Optional

Insufficient evidence todemonstrate conformance
No documentation provided

Participation in an in-region program that advances
responsible sourcing of conflict minerals
Energy management system/energy performance
improvement for suppliers

Optional

Criterion Title

Outcomes Report – Level 1 Investigations (P41B Issue2 Rev0)

Required
Optional

Optional

Insufficient evidence todemonstrate conformance
Demonstrated
nonconformance
Insufficient evidence todemonstrate conformance
No documentation provided

Corrective Action Taken

Manufacturer provided evidence
demonstrating conformance
Manufacturer unselected theCriterion
Manufacturer unselected theCriterion
Manufacturer provided evidence
demonstrating conformance
Manufacturer unselected theCriterion
Manufacturer provided evidence
demonstrating conformance
Manufacturer provided evidence
demonstrating conformance
Manufacturer unselected theCriterion
Manufacturer unselected theCriterion

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Document Control and Change History
Issue
1

Revision
0

1

1

2

0

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 1 Investigations (P41B Issue2 Rev0)

Approval Date

Effective Date2018 Dec 112018 Dec 112021 Mar 25

2021 Mar 30

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