EPEAT Program
Stakeholder Comment Report
October 17, 2022 – December 31, 2022 Comment Period
Proposed Revisions to EPEAT Policy Manual (P65) and
EPEAT Conformity Assurance Implementation Manual (P66)

Introduction
The Global Electronics Council (GEC) released draft revised versions of the EPEAT Policy Manual (P65)
and EPEAT Conformity Assurance Implementation Manual (P66) to seek public comment on these
documents from October 17 through December 31, 2022. Stakeholder consultation in the form of apublic comment period is a crucial element of Type 1 ecolabels, and an important component of the
EPEAT Program. Stakeholders were invited to submit written feedback on both documents using the
GEC provided stakeholder comment form. GEC also held a series of virtual information sessions forstakeholders to highlight and provide clarity on key proposed revisions.
GEC thanks all stakeholders for the constructive and thoughtful feedback provided during the publiccomment period, and appreciates the time and effort stakeholders took to review the documents andprovide comments.
GEC believes that transparency strengthens the EPEAT Program in an important way. GEC received over
100 written comments from different stakeholder groups which have been compiled into thisStakeholder Comment Report. The comments are first listed alphabetically by the last name of theindividual providing comments, and then grouped by document and listed numerically by section in the
document.
GEC reviewed and considered all stakeholder comments when making final revisions to EPEAT Policy
Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66).

Overview of Comments Received
CAB Responsibilities in Continuous Monitoring
Stakeholders expressed a strong desire to ensure Participating Manufacturers are not unfairly maligned
in Continuous Monitoring investigations where a GEC-approved Conformity Assurance Body (CAB) fails
to submit an Investigation Report by the deadline. To this end, GEC created a new nonconformance
category for situations where a CAB fails to submit an Investigation Report on time, called“nonconformance due to CAB inaction or delay not attributable to Participating Manufacturer”. The
EPEAT Program also revised EPEAT Conformity Assurance Implementation Manual (P66) to clarify that
Participating Manufacturers will be notified directly if an Investigation Report is overdue. In the interestof full transparency, Outcomes Reports will identify products and Participating Manufacturers thatreceive nonconformances due to CAB inaction or delay. Note: this new nonconformance category willtake effect on February 15, 2023.

Global Electronics Council

Published February 15, 2023

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EPEAT Program Stakeholder Comment Report
Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)

Conformity Assurance Processes
Commenters sought clarification on the differences and similarities between the two conformity
assurance pathways. Several of the questions raised in the comments are answered further in EPEAT
Conformity Assurance Implementation Manual (P66). Section 6.2.1 includes requirements for CABs tohave sampling and/or certification product grouping procedures. The removal of the Priority Criteria
concept means that all selected Criteria are reviewed at the onset for both pathways. Section 6.2.4
outlines the process for Participating Manufacturers to add additional products during Initial
Documentation Review for both pathways and Section 6.3 outlines the process for adding additional
products, Criteria and/or locations of use for both pathways after Initial Documentation Review iscomplete.
Based on stakeholder comments, the EPEAT Program provided additional information in EPEAT
Conformity Assurance Implementation Manual (P66) to further define what makes products “similar”
when Participating Manufacturers wish to add additional products during both Initial Documentation
Review and Ongoing Documentation Review and are required to confirm in the EPEAT Registry if the
new product(s) is similar to an existing product.
The EPEAT Program also provided examples of how Participating Manufacturers can demonstratecompetence of a Corporate Criterion with annual requirements when they are in between annual
reporting cycles, in Section 6.3.1 of EPEAT Conformity Assurance Implementation Manual (P66).
Suggestions Requiring Additional Consideration by GEC
Some stakeholder suggestions received require further evaluation by GEC. For instance, commenterssuggested that GEC should attempt to reduce the amount of overlapping text across the key policy
documents, by removing similar text that appears in all of the documents and compiling it into one
EPEAT Program reference document. Some of the topics cited include EPEAT Program Terms,
Complaints and Appeals, and Technical Guidance.
Stakeholders also made a series of other suggestions including the recommendation that GEC publish
CAB Performance Metrics and EPEAT Audit of CAB findings. Some stakeholders also expressed a desire
for GEC to reconsider how it develops technical guidance and clarifications. Implementing any of thesesuggested changes could have a significant impact on the EPEAT Program and its stakeholders, and forthis reason, GEC plans to evaluate the suggestions in 2023, and solicit stakeholder feedback where
necessary before reaching a decision on these proposals.
Lastly, although the EPEAT Program is introducing a new nonconformance category to reflect CAB
inaction or delay (based on stakeholder feedback), GEC plans to evaluate and refine existing Continuous
Monitoring procedures in 2023 to account for this new nonconformance category.

Publication of Revised Documents
GEC published the revised versions of EPEAT Policy Manual (P65) and EPEAT Conformity Assurance
Implementation Manual (P66) on February 15, 2023. These documents are available through either the
EPEAT Registry, an EPEAT Registry account under “Resources” or upon request. New requirements takeeffect on July 1, 2023. Participating Manufacturers and GEC-approved Conformity Assurance Bodies
must operate in accordance with both of these documents as of this effective date to fulfill EPEAT

Global Electronics Council

Published February 15, 2023

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EPEAT Program Stakeholder Comment Report
Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)

Program requirements. The EPEAT Program will develop training resources to identify new requirements
for CABs and Manufacturers.
Please direct any questions on this Stakeholder Comment Report to EPEAT@GEC.org.

Global Electronics Council

Published February 15, 2023

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EPEAT Program Stakeholder Comment Report
Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)
Comments are first listed alphabetically by the last name of the individual providing comments, and then grouped by document and listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Topic

Comment

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P65

N/A

Overarching

There is a lot of overlap between the documents P66, P74 and P65. To avoid confusion and thepotential for conflicting policies, ITI suggests that sections of similar topics (such as technicalguidance) be maintained in one document and referenced in the others.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P65

N/A

GeneralThe EPEAT Program is planning to implement an Early Adopter status for the Climate Module.
However, it is not clear how this is allowed under the EPEAT Policy Manual.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P65

1.0

Introduction

As noted in our comments to P74, ITI does not believe that EPEAT criteria are “developed in a multistakeholder, voluntary, consensus process.” ITI is suggesting specific revisions to P74 to address
both the spirit and letter of OMB Circular A-119 and ISO 14024. ITI would also welcome a return toan ANSI-accredited standards development process, as advocated by several stakeholders in theprevious comments to P65 (See ITI and EPA comments on EPEAT Stakeholder Comment report
dated February 15, 2021).

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P65

1.0

Participation

Participation is not voluntary for any manufacturer or brand owner who wishes to sell products to
the U.S. Government (see48 CFR §23.704).
Suggested change:
Participation in the EPEAT Program is voluntary, and open to any manufacturer or brand owner of
products in a product category for which EPEAT Criteria exist. However, participation in the EPEAT
program is required for sales to the U.S. Government per 48 CFR §23.704).

Global Electronics Council

Published February 15, 2023

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EPEAT Program Stakeholder Comment Report
Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)
Comments are first listed alphabetically by the last name of the individual providing comments, and then grouped by document and listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P65

2.3

Topic

Comment

Program Transparency

This section needs to be more detailed. It should reflect a transparency commitment to specificareas of operation and stakeholder engagement, including: budget, finances, and spending;proactive engagement and feedback gathering via stakeholder email distribution lists, the AC, theCAC, and other relevant GEC/EPEAT committees. The GEC should also provide an annual (or otherspecified period) fiscal report.
Suggested Changes:
GEC, is committed to transparency in its administration of the EPEAT Program. As such, GEC will, iscommitted to ensure ing that EPEAT Program documents are freely available to stakeholders.
Information is made available to interested parties regarding the following aspects of the EPEAT
Program: the selection of product categories; the selection, development, and revision of EPEAT
Criteria; EPEAT Criteria including the identification of methods used for product evaluation; andconformity assurance requirements and processes; and records of stakeholder engagement (suchas Advisory Council or other group minutes). Interested parties may obtain this information
by...[process or contact].
The activities of the Global Electronics Council are funded through a mix of trademark fees from ourecolabels, fees from CABs to support their training and auditing, in-kind support from partnerorganizations and grants/research funding. GEC will provide a detailed financial report annually toinclude income, budget, cash flows and functional expenses.
GEC will communicate changes to governance documents, announcements of criteria development
processes and other information of interest to stakeholders via…[insert process here]

Global Electronics Council

Published February 15, 2023

Page 5 of 27

EPEAT Program Stakeholder Comment Report
Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)
Comments are first listed alphabetically by the last name of the individual providing comments, and then grouped by document and listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P65

2.4

Topic

Comment

Confidentiality

GEC confidentiality protections have been reviewed by industry legal experts and found to not berobust or adequate for most CBI submissions. It is not clear who GEC is sharing data with (or not).
Suggest adding a specific section to this governance document (P65) or specifically noting where
the “internal policies and procedures” can be obtained and providing audits or other means toensure the adequacy of these processes.
Suggested Changes:
As the owner of the EPEAT Trademarks and managers of the EPEAT Program, GEC has a robust
framework of internal policies and procedures in place to prevent the disclosure of any confidential
information in its possession. These polices and procedures may be obtained by…[process].
Participating Manufacturers provide the EPEAT Program with proprietary, commercially sensitive
data. GEC ensures that all levels of the organization are in full compliance with applicable laws tosafeguard the confidentiality of this information. Because of this, GEC will periodically review thesepolicies and procedures with Participating Manufacturers and their representatives.

Global Electronics Council

Published February 15, 2023

Page 6 of 27

EPEAT Program Stakeholder Comment Report
Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)
Comments are first listed alphabetically by the last name of the individual providing comments, and then grouped by document and listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P65

2.5

Topic

Comment

Type 1 Ecolabel

The GEC Criteria Development Process (P74), the document which outlines how the EPEAT program
conforms with ISO 14020 and ISO 14024, does not conform with all parts of these standards,
especially in areas of openness and due process. ITI has provided specific recommendations to P74
to bring the GEC Criteria Development Process in conformity with the spirit and letter of ISO 14020
and ISO 14024. Below are areas where we have found the GEC process not in alignment with theType 1 Ecolabel standards:---

Global Electronics Council

Published February 15, 2023

ISO 14020 Principle 4: Information concerning the procedure, methodology, and any
criteria used to support environmental labels and declarations shall be available andprovided upon request to all interested parties.
o Several aspects, including the selection process for ad-hocs and the TechnicalCommittee, the decision-making process of the ad-hocs, and the process fordrafting and finalizing the criteria have not been described by the GEC
o The documents provided, including P74 and the NSF International Criteria development
and maintenance procedures, lack meaningful and necessary detail todetermine how theprocess is managed
ISO 14020 section 4.9.2: “The process for developing standards and criteria shall be open to allinterested parties”
ISO 14024 section 5.9: “A process of formal open participation among interested parties shallbe established at the outset for the purpose of selecting and reviewing product categories,
product environmental criteria and product function characteristics.” andISO 14024 Section 5.12: “A Type I environmental labelling programme should be able todemonstrate transparency through all stages of its development and operation.”o The entire criteria development process is not open to all interested and affectedparties, and the only time all stakeholders are engaged is at the SOSR and Final Draft
Criteria public comment periods, which do not meet the spirit nor letter of “formal
open participation” All stages of the process, including the selection and developmentof criteria, should be open to interested parties; this is currently by invitation-only tothe ad-hocs and Technical Committee

Page 7 of 27

EPEAT Program Stakeholder Comment Report
Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)
Comments are first listed alphabetically by the last name of the individual providing comments, and then grouped by document and listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P65

3.0

Topic

Comment

EPEAT-Registered
Products

The scope of each of the standards is defined in the standard or criteria document, including themodels and configurations. The EPEAT Policy Manual should not define “product” or other EPEAT
Program Terms.
Suggest removing the second and third paragraphs of this section and creating an “EPEAT Program
Terms” document that should be sent out for public comment.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P65

4.1

Innovation Points

The EPEAT Program has not implemented a process for innovation points despite their existence forseveral years. ITI requests that the EPEAT Program develop a process for these.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P65

4.2.1

Selection of ProductCategories

ITI has concerns with the new Policy Document GEC Selectin of Product Categories (P75) and has
submitted these comments to GEC.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P65

4.2.2.1

State of Sustainability
Research

As mentioned in our comments to P74, the SOSR represents the input of a single stakeholder in thedevelopment process. As such, it may only be used as a resource for further discussion of criteria
development.
Suggested changes:
GEC publishes State of Sustainability Research as an important the initial step in the development
or revision of criteria. The research identifies science-based social and environmental impacts
across the life cycle of technology products and services, and strategies to reduce the identified
sustainability impacts. The research also identifies best practices, existing regulations, and existing
voluntary leadership programs designed to reduce sustainability impacts. The data and analyses inState of Sustainability Research serves as the scientific basis a resource for the development orrevision of criteria, as well as identification of opportunities for harmonization. GEC releases Stateof Sustainability Research for public consultation for a minimum of 60 days.

Cleet, Chris

Information Technology Industry
Council (ITI)

Global Electronics Council

December 30, 2022

P65

4.2.2.2 and4.2.2.3

Not provided

Published February 15, 2023

As we have noted in our comments to P74, GEC does not run a Voluntary Consensus Process as
defined by OMB Circular A-119. We have provided specific suggestions to amend the process toensure that it meets the key characteristics as defined by the Circular. If the GEC decides to keep
its existing process, they cannot claim that it aligns with the characteristics of a voluntary consensus
process and this section must be amended to reflect this.

Page 8 of 27

EPEAT Program Stakeholder Comment Report
Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)
Comments are first listed alphabetically by the last name of the individual providing comments, and then grouped by document and listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Topic

Comment

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P65

4.2.3

Criteria Update andRevision

Revising some criteria or substantive changes to criteria annually is too often considering thedevelopment cycle of registered products. The document should also reflect stakeholder concerns
on impacts of product availability on the registry. Suggest full revisions to be done every 5 years.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P65

4.2.4

Adopting Criteria

The criteria requirements should also be analyzed to ensure that the incremental cost of obtaining
the required documents properly balances against the benefit of the criteria objectives.
Suggested change (add under first bullet on page 12):
Ensure that the criteria are achievable in a reasonable amount of time without excessive costs

Cleet, Chris

Information Technology Industry
Council (ITI)

Global Electronics Council

December 30, 2022

P65

5.3

Continuous monitoringroundsAn additional category for final decision on conformity should be added to account for the situation
when a CAB fails to implement the Continuous Monitoring activity with the participating
manufacturer or fails to complete the round by not submitting documentation on investigations to
the EPEAT program. Suggest adding a category like “CAB inaction or delay not attributable tomanufacturer”. These outcomes should not be included in the outcomes report as they are notconclusive and could be misleading if reported in the Outcomes Report. Or if they are included in
the Outcomes Report, the manufacturer’s name should not be displayed in instances when the
manufacturer had nothing to do with the action or inaction that results in the Nonconformance.

Published February 15, 2023

Page 9 of 27

EPEAT Program Stakeholder Comment Report
Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)
Comments are first listed alphabetically by the last name of the individual providing comments, and then grouped by document and listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P65

5.6

Topic

Comment

EPEAT Technical
Guidance and Authority

The GEC does not have the necessary expertise to make technical interpretations of criteria, andthere is no process in ISO 14024 for technical interpretations or guidance, so it is not clear how or
why this section is referencing the Type 1 environmental labeling standard. In every standard orlabel that ITI works with, except for EPEAT, when conflicting or disparate understandings criteria orverification requirements arise, temporary guidance is provided by the criteria development
Technical Committees, or if those have been sunset, via another expert consensus group. These
guidance documents then sunset upon revision of the applicable criterion. ITI suggests that EPEAT
adopt a similar approach to bring it in alignment with commonly accepted international approaches
to technical guidance.
Suggested changes:
Remove first and second paragraphs of this section.
During their ongoing interactions with Participating Manufacturer clients, GEC-approved CABs may
identify that there is a conflicting or disparate understanding of EPEAT Criteria and/or the
associated conformity assurance requirements, or ambiguity in the requirements or verification. In
such situations and where they are unable to resolve the conflict with the Participating
Manufacturer, CABs must inform the EPEAT Program. Stakeholders may also inform the EPEAT
Program of a conflict in understanding or ambiguity. The EPEAT Program will then refer this issue
to the appropriate expert committee (the Technical Committee of jurisdiction, or if that has beensunset, the EPEAT Advisory Committee, the EPEAT Conformity Guidance Group or another ad-hoc
expert committee) to make a definitive technical interpretation and share it with all GEC-approved
CABs and Participating Manufacturers.

Cleet, Chris

Information Technology Industry
Council (ITI)

Global Electronics Council

December 30, 2022

P65

5.6

Technical Guidance

Published February 15, 2023

The terms and applications of “guidance,” “interpretations” and “clarifications” are all different
however often used interchangeably in this section. Only the term “clarification" is defined in
section 13 of this document. ITI suggests if P66 is going to use all three terms, it must provide
commonly available definitions for each of the terms and separate out parts on “guidance”(informative) and “clarifications” and “interpretations” (normative).

Page 10 of 27

EPEAT Program Stakeholder Comment Report
Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)
Comments are first listed alphabetically by the last name of the individual providing comments, and then grouped by document and listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Topic

Comment

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P65

5.6.1

Not provided

As with technical interpretations for criteria, GEC does not have the expertise or the authority (via
ISO 14024) to unilaterally provide clarifications if a criterion is found to be ambiguous. ITI suggests
removing section 5.6.1 and combining it with the suggested text from section 5.6

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P65

5.6.1

Clarifications

When the EPEAT Program provides clarifications, the clarifications should be published in the
documentation resources of the EPEAT website for future references. It’s not clear in this section
how these clarifications are communicated.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P65

5.6.2

Conformity
Requirements andGuidance

Guidance materials cannot place additional requirements not in the criteria on the Participating
Manufacturers. This includes testing types and timelines. In most cases, the acceptable evidence
is listed in the verification requirements of the criterion.
Suggested change:
The EPEAT Program publishes Conformity Requirements and Guidance Materials to help
Participating Manufacturers and GEC-approved CABs further understand EPEAT Criteria
requirements, provide supplementary information and where necessary, provide further details
regarding demonstration of conformance with EPEAT Criteria. Where content in these Materials is
specifically identified as “guidance”, EPEAT Criteria take precedence over that content. Further,guidance cannot impose further requirements not found in the EPEAT Criteria.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P65

5.6.3

Calibration meetings

Outcomes, decisions, and clarifications that result from calibration meetings should be shared withparticipating manufacturers to ensure common understanding of criteria and verification
requirements.
Suggested change:
Calibration Meeting materials are made available to all GEC-approved CABs and Participating
Manufacturers.

Cleet, Chris

Information Technology Industry
Council (ITI)

Global Electronics Council

December 30, 2022

P65

6.1

CAB Eligibility

Published February 15, 2023

In all other standards and labels that ITI and our members participate in, the Standards org or label
owner does not have any requirements for participation in the program other than accreditation toapplicable programs. It is not clear what benefit Sections 6.2 and 6.4 provide.

Page 11 of 27

EPEAT Program Stakeholder Comment Report
Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)
Comments are first listed alphabetically by the last name of the individual providing comments, and then grouped by document and listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Topic

Comment

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P65

6.4.3

Performance Metrics

CABs performance metrics should be shared with the manufacturers who rely on that particular
CAB to ensure that their CAB is in good standing.
Suggested change:
The EPEAT Program evaluates the performance of all GEC-approved CABs against a series ofconformity assurance and service provision metrics at least annually and shares the results with
CABs and that CAB’s Participating Manufacturers during their annual EPEAT Audit.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P65

6.5

Suspension or
Termination

Once terminated, the time for a CAB to work with existing manufacturing clients for only 6 months
may not provide enough time for manufacturing clients to finish criteria in process and find a new
CAB. Suggest reverting this to 12 months.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P65

7.2

Ongoing Requirements

Participating Manufacturers may need time to conform with criteria based on changes to the EPEAT
policy manuals. Suggest providing a time to conform to potential changes.
Suggested change:
Participating Manufacturers must also unselect inform the GEC if they are unable to meet EPEAT
Criteria immediately if they are no longer able to meet the Criteria due to a change in EPEAT Policy.
Manufacturers must inform GEC of which criteria they are unable to meet and the time necessary
to come back into conformity with the criteria. If the time to conform to the criteria is longer thansix months, the Participating Manufacturer will unselect those optional criteria and remove thedevice from the registry if there are required criteria.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P65

7.4

Termination

If the specific grounds and provisions for Participating Manufacturer termination are in the GEC
EPEAT License and Participating Manufacturer Agreement (P26) then a summary in bullet form does
not need to be listed here. Suggest removing the bullets.
Additionally, inclusion of P26 in the Policy Manual suggests that this document should also be open
for public review and comment.

Global Electronics Council

Published February 15, 2023

Page 12 of 27

EPEAT Program Stakeholder Comment Report
Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)
Comments are first listed alphabetically by the last name of the individual providing comments, and then grouped by document and listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P65

7.4

Topic

Comment

Termination

There should be a provision that Participating Manufacturers may appeal the CAB recommendation
or GEC decision to terminate.
Suggested change:
GEC may terminate a Participating Manufacturer according to the provisions in GEC EPEAT Licenseand Participating Manufacturer Agreement (P26). Participating Manufacturers may appeal adecision to terminate using the process in Section 9.0

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P65

8.0

Managing Impartiality
and Conflicts of Interest

This section is vague and does not explain the safeguards in place to avoid a conflict of interest. It
also does not explain how GEC being a CAB competing with and managing independent CABs is nota conflict of interest, although it is recognized in Section 8.2 that this is a potential conflict ofinterest. ITI refers GEC to our comments on Section 2.3 for suggestions of actions that will increasetransparency and manage potential conflicts of interest.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P65

8.2

GEC CAB andIndependence

ITI continues to wonder how the GEC can maintain a CAB that competes with other CABs andmaintain that it does not have a conflict of interest. No other standards organization globally
operates in this way. Ultimately, as long as GEC maintains its own CAB, appearances of conflict ofinterest will exist.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P65

9.0

Complaints and Appeals

Similar to our comments on Complaints and Appeals in P74, ITI recommends a process by which an
appeal is reviewed by an external, volunteer group. This removes the conflict of interest of GEC
staff ruling on an appeal of a GEC action or inaction. ITI suggests that GEC add a section here either
about an external Complaints Appeals Committee, which is comprised of individuals outside of GEC,
or a two-tier process where there is a “GEC appeal” and then an “external appeal.” The decisionsof the external appeal would be final.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P65

13.3

Definition of “Conformity
Requirements andGuidance Materials”

Per our comments on Section 5.6, suggest removing this new definition and providing comments
for the three terms as used in the Policy Manual

Global Electronics Council

Published February 15, 2023

Page 13 of 27

EPEAT Program Stakeholder Comment Report
Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)
Comments are first listed alphabetically by the last name of the individual providing comments, and then grouped by document and listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P65

11.0

Topic

Comment

Force Majeure Events

Several criteria in the existing standards have built-in force majeure events provisions, but it seems
that the EPEAT Program is no longer allowing for this. Absent specific provisions in the criteria, the
EPEAT Policy Manual should note that temporary exemptions to conformity of criteria may be
granted. Additional specificity on this would help.
Suggested change:
The EPEAT Program may also issue temporary exemptions to conformity to criteria during
Documentation Review and Continuous Monitoring activities due to force majeure events.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

N/A

Overarching

There is a lot of overlap between the documents P66, P74 and P65. To avoid confusion and thepotential for conflicting policies, ITI suggests that sections of similar topics (such as technicalguidance) be maintained in one document and referenced in the others.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

2.1

Adding additional
products or criteria

it is not clear why or how these pathways have different lengths of validity. What is the length ofvalidity based on? This should be specified.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

2.1

Ongoing documentation
review

It is not clear the difference between major and minor revisions. This needs to be clarified with
examplesCleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

2.1

Ongoing documentation
review

What other kinds of "Ongoing Documentation Review" are there and why would another review
need to be done if no significant product/program changes have occurred to warrant it? Any
criteria revision happening outside of a full revision should be taken through the Conformance
Guidance Group for vetting and mfr awareness and/or weighing in.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

2.1

Continuous monitoring
non conformance

If in the continuous monitoring activity, the CAB fails to provide the investigation report, then the
CAB’s performance metric should reflect this, and the participating manufacturer will not be
penalized with a non conformance due to this. Instead, a corrective action report will need to besubmitted by the CAB along with the investigation report within 30 calendar days.

Global Electronics Council

Published February 15, 2023

Page 14 of 27

EPEAT Program Stakeholder Comment Report
Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)
Comments are first listed alphabetically by the last name of the individual providing comments, and then grouped by document and listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Topic

Comment

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

2.2.1

Clarifications

Any change to the requirement should also warrant a Conformity Guidance Group review with
manufactures. This is critical for mfrs to have awareness and time to respond.
Suggested change:
If the EPEAT Program determines that a Clarification is warranted, feedback may be sought fromthe Conformity Guidance Group and GEC’s criteria development staff. The EPEAT Program thendrafts the proposed Clarification and releases it for a 30-calendar day public comment period
and/or 30-calendar day Conformity Guidance Group comment period, per Section 2.2.4.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

2.2.1

Clarifications

ITI has provided comments on the EPEAT Policy Manual Section 5.6 on Technical Guidance. All
Clarifications must go through this process
Suggested Change:
The EPEAT Program evaluates all requests and determines if a formal Clarification is needed. If the
EPEAT Program determines that a Clarification is warranted, feedback may be sought from the
Conformity Guidance Group and GEC’s criteria development staff. The EPEAT Program then drafts
the proposed Clarification and releases it for a 30-calendar day public comment period and/or 30calendar day Conformity Guidance Group comment period, per Section 2.2.4.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

2.2.1

Clarification

The text should be “and” as the proposed clarification should be routed for comment to both the
public AND the conformity guidance group to obtain the most feedback.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

2.2.1

Clarifications

Effective dates for clarifications should be 60 calendar days as depending on the time of the year,
30 might be too tight. Plus depending on the clarification, additional time is needed to compile theinformation and ensure CAB review if necessary.

Global Electronics Council

Published February 15, 2023

Page 15 of 27

EPEAT Program Stakeholder Comment Report
Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)
Comments are first listed alphabetically by the last name of the individual providing comments, and then grouped by document and listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Topic

Comment

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

2.2.2

Guidance Materials

Guidance materials must not override the criteria. This is stated in other EPEAT Policy Documents
and should be stated here.
Suggested change:
The EPEAT Program publishes Conformity Requirements and Guidance Materials for Required
Criteria two months before the launch of a new product category and take effect immediately
unless otherwise stated. Content in these Materials is specifically identified as “guidance.” EPEAT
criteria take precedence over that content. (See Page 16 of P65)

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

2.2.2

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

Global Electronics Council

Footnote 1

This footnote is overly long and complex. Recommend an attempt to simplify or put into some formof table or graphic to understand better.

2.2.2(pg 8 2nd
paragraph)

Conformity
Requirements &Guidance materials

Any change in these documents should be brought thru the CGG for mfr awareness and weighing
in. This should be stated for confirmation.

P66

2.2.2
(pg 8 para 3)

Revisions to Conf
requirements &Guidance materials

In addition to listing why guidance materials may be revised, the document should list a clear
timeline of when are these revisions be done and the justification for each revision. Additionally,adequate time should be allowed to implement any new changes. This process should be definedfor manufacturer awareness with adequate time beforehand to respond.

P66

2.2.3

Technical Questions

The EPEAT Policy Manual Section 5.6 contains policies on technical guidance, clarifications andconformity requirements. ITI suggests that GEC determine that one of these documents containthe policies for technical questions, clarifications and guidance and refer all stakeholders to thatsingle source. ITI also refers GEC to our comments on technical guidance in the EPEAT Policy
Manual.

Published February 15, 2023

Page 16 of 27

EPEAT Program Stakeholder Comment Report
Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)
Comments are first listed alphabetically by the last name of the individual providing comments, and then grouped by document and listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Topic

Comment

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

2.2.3

Technical Questions

The consensus body (in this case, the CGG) should make the determination of interpretation or if
further consultation, clarification or guidance is needed.
Suggested changes:
After receiving feedback from the CGG, the EPEAT Program may determine further consultation isneeded, issue a formal Clarification, integrate further details into Conformity Guidance Materials, orsend the topic to GEC’s Continuous Maintenance Process. The EPEAT Program communicates the
final decision to the CGG.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

2.2.3

Technical Questions

On page 11, the document notes the “EPEAT Program is solely responsible for making technicalinterpretations.” However, this does not note which parts of the EPEAT Program do this. ITI
suggests deleting the last paragraph of this section as it does not add any clarity to which parts ofthe program are performing which actions when.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

2.2.3

Technical questions

Please correct for new terminology and to include AND.
Suggested changes:“The EPEAT Program makes the definitive technical interpretation and shares it through discussion
at CAB Calibration Meetings, issuance of a formal Clarification, or and updates to Conformity
Requirements and Guidance Materials.”

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

2.2.4

Conformity GuidanceGroup

The GEC/EPEAT Program should not independently or unilaterally resolve any technical issue orneed for clarity in the EPEAT Criteria. The CGG may serve as the expert group to perform thesefunctions. The last paragraph on page 10 (starting with “For other topics” should be deleted andthe bullet points moved up topics brought to the GCC for discussion and feedback.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

4.0

Qualified Auditor
Proficiency and Training

In this section about auditors, there is no mention of being evaluated for good communications
skills. Lots of mentioning of technical knowledge etc, but nothing about good organizational skills toclearly outline their feedback or define what is required for compliance vs. opinions, etc.. This
causes serious misalignments in audits and has led to appeals that waste a lot of mfr and GEC's
time. This should be a new requirement/training implemented in 2023.

Global Electronics Council

Published February 15, 2023

Page 17 of 27

EPEAT Program Stakeholder Comment Report
Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)
Comments are first listed alphabetically by the last name of the individual providing comments, and then grouped by document and listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Topic

Comment

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

4.2.2

Annual EPEAT Auditor
Proficiency Exam

Most professional qualifications or accreditation programs make the development of exams apublic process similar to criteria development. ITI suggests that these exams should be madeavailable for review and comment, and that GEC should solicit questions from multiple EPEAT
stakeholders. ITI suggests a new section prior to the Annual EPEAT Auditor Proficiency Exam be
added to address development of the EPEAT Auditor Proficiency Exam.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

4.2.4

Calibration Meetings

Update language: “Any resulting changes to conformity assurance processes, policies orinterpretations are available to Participating Manufacturers in the Conformity Guidance Materials
and in the Conformity Requirements and Guidance Materials.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

5.2.1

Annual CAB Audits

Manufacturers pay considerable fees for adequate services rendered by CABs. Additionally,
Manufacturer performances to criteria are made publicly available. The CAB audit report or asummary should be made publicly available.
Suggested change (at end of page 25)
Within 14 calendar days of completion of the audit, GEC provides the CAB with an audit reportsummarizing the activities conducted and, where applicable, opportunities for improvement andnonconformances. Audit reports are provided electronically. Results of the Annual EPEAT Audit of
CABs are not made publicly available or a summary of results, including nonconformities, will be
posted on the GEC website.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

5.2.2.1

Nonconformances
Related to Conformity
Decisions

Parts 2 and 3 note that a manufacturer whose conformity status may be changed due tononconformance by the CAB “may be given up to three months” to make corrections. How is thistime determined? For simplicity and ease of implementation, ITI suggests that Participating
Manufacturers be given three months from the date notified to make corrections or provide the
CAB with additional documentation.
Suggested change:
The Participating Manufacturer must provide may be given up to three months from the date
notified to make necessary corrections and provide the CAB with additional documentation within
three months of notification from the CAB.

Global Electronics Council

Published February 15, 2023

Page 18 of 27

EPEAT Program Stakeholder Comment Report
Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)
Comments are first listed alphabetically by the last name of the individual providing comments, and then grouped by document and listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Topic

Comment

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

5.2.2.1

Non Conformances andcorrective action

A section needs to be included to address what is the process when a CAB does not submit aninvestigation report for a participating manufacturer and the participating manufacturer has
submitted all the requested information.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

5.3

CAB Performance
Metrics

Participating Manufacturers’ compliance results are made public and the CABs play a significant rolein that outcome. There is no reason to why CAB's aren’t held to the same level of expectation forthe program's accuracy. Suggest deletion of the

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

Metric 11

Incomplete investigation
report

It is not clear why CABs are allowed to submit any reports with missing required entries. In
particular, CABs should be prohibited from prematurely submitting reports to GEC - especially if
mfrs state that more evidence is forthcoming.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

6.1.4.2

Types of Evidence

As noted in our comments on P65, the CAB and the EPEAT Program cannot place additional
requirements not in the criteria on the Participating Manufacturers. This includes testing types andtimelines. In most cases, the acceptable evidence is listed in the verification requirements of thecriterion.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

6.1.4.2

Types of Evidence

Guidance is not (as noted) normative and cannot be listed in a set of normative requirements CABs
are using. Suggest removing the third bullet on the top of page 38.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

6.1.4.2

Types of Evidence andEnsuring Integrity of
Evidence

Most suppliers send supplier declarations of conformity by email. In the emails, addresses of theorganization are rarely included and so shouldn’t be required in the declaration. In addition, theplace of issue is not included. Signatures are also not included and as such a digital signature suchas that included by an email address such suffice as evidence.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

6.1.5

Assessing Competence

It is not clear why EPEAT created a new term, “competence” to show conformity to EPEAT criteria
when the term “competence” is simply defined as “demonstrating conformance” in this section andnot defined in Section 12. Further, if a Participating Manufacturer is showing conformity to acriterion, it can be assumed that the manufacturer understands that criterion, or a manufacturer
may be highly competent, yet a CAB may disagree with how the manufacturer is showing
conformity. A separate, novel term is not necessary. No other standards conformity process uses
this term. ITI suggests that this section be deleted and any relevant information be moved into
Section 6.1.4 Assessing Conformity, as this is the ultimate goal of the program.

Published February 15, 2023

Page 19 of 27

Global Electronics Council

EPEAT Program Stakeholder Comment Report
Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)
Comments are first listed alphabetically by the last name of the individual providing comments, and then grouped by document and listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Topic

Comment

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

6.1.5

Assessing Competence

Assuming the intent of this section (per our previous comment) is to show how a CAB will verify
that a Participating Manufacturer is conforming to the criteria in the EPEAT Program, this whole
section is very subjective and poorly defined. The need to update evidence and documentation is
not an indicator of nonconformity. While ITI agrees that the length of time to review evidence is
not an indicator of anything, we still struggle with the need for this concept in the EPEAT Program.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

6.2.1

Initial Doc Review

Some of this section sounds new and overly extensive. almost sounds like the DR itself - A list of
products and their basic description should be enough for the plan. This should be distilled down tomake the process efficient.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

6.2.2 and
6.2.3

Assessing Conformanceand Competence

These sections are redundant to Section 6.1.4 and 6.1.5. We suggest removal of these sections andthe relevant parts moved to 6.2.1. Section 6.2.1 can refer back to the relevant sections in 6.1.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

6.2.4
(1st bullet)

Activating Products

The term "electronic means" is not defined. This should be clarified.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

6.2.4

Activating Products

There is a new requirement in this manual for participating manufacturers to conform if a new
product is “similar” to another one in the registry but there is no clear definition as to what EPEAT
considers to be a “similar” product. The EPEAT Program needs to provide a clear definition on how
to measure “similarity” between products. In addition, it’s not clear what happens if a productbeing added to the registry via the priority verification method is not similar to any other product in
the registry.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

6.3.1

New Products

3rd bullet in on page 47: As above, it is not clear what is meant by “electronic means.” There needs
to be a defined process or action here. Further as we note above, the term “competence” ismerely defined as “showing conformity” and should be removed.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

6.3.1
(4th bullet)

Not provided

As we mention, there is no clear differentiation between “conformance” and “competence.” As
written, this puts a Participating Manufacturer in a potentially never-ending cycle of review by the
CAB. It is not clear how a manufacturer can verify compliance to a criterion without demonstrating"understanding.” It is also not clear how a CAB can subjectively determine that a manufacturer“understands” a criterion; they only have the evidence of conformity. This bullet should be
reworked or deleted.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

6.3.1

New Products

The EPEAT Program needs to provide a clear definition on how to measure “similarity” between
products

Global Electronics Council

Published February 15, 2023

Page 20 of 27

EPEAT Program Stakeholder Comment Report
Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)
Comments are first listed alphabetically by the last name of the individual providing comments, and then grouped by document and listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Topic

Comment

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

6.3.2

Demonstrating
Compliance/Competence

Demonstrating conformity should accepted to add new optional criteria. It is not clear (asmentioned above) what the value add for showing “competence” is. With this approach,manufacturers may be required to continue to provide the same evidence in whatever approachpossible and still be able to register.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

6.3.3

Location of Use

As above, it is not clear what value “competence” adds. If a Participating Manufacturer shows
conformity to a criterion, it should be able to list the product in the desired country.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

6.3.4

Loss of confidence

Loss of confidence should be defined with clear examples. However, the term “competence” (asnoted above) should be deleted. ITI suggests that the EPEAT Program develop a “high and low risk”(as noted in several EPEAT corporate criteria) Participating Manufacturer program. Manufacturersthat for reasons listed are determined by the CABs to be “high risk” will face additional review andinspections. Lower risk manufacturers may be subject to less stringent review.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

7.1

Annual Reviews

In some cases, the production of evidence may be out of the manufacturer’s control. It should be
noted there is a process for limited allowances for evidence after the deadline.
Suggested change (page 57 2nd bullet):Compiling documentation and submitting it to the GEC-approved CAB in an organized and timely
manner by the deadlines provided. For Continuous Monitoring Rounds, evidence must be
submitted before the end of the investigation phase. For Annual Renewals, evidence must be
submitted before the Annual Renewal deadline. For instances out of the Participating
Manufacturers’ control, an extension may be requested as noted in sections 7.2 and 7.3.
(note: our comment on section 7.3 below notes that a force majeure clause similar to 7.2 should be
added to 7.3)

Global Electronics Council

Published February 15, 2023

Page 21 of 27

EPEAT Program Stakeholder Comment Report
Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)
Comments are first listed alphabetically by the last name of the individual providing comments, and then grouped by document and listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Topic

Comment

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

7.2.2

Investigation Rounds

If the CAB is unable to submit one or more draft Investigation Reports before the submission
deadline, CABs must inform the EPEAT Program at least 24 hours before the deadline and theyshould inform the participating manufacturer. The EPEAT program actions should be notifying theparticipating manufacturer, providing the CAB and extension if applicable, and if no extension is
granted, then include in the outcomes report a category for “CAB inaction or delay not attributableto manufacturer”. A non conformance is not justifiable when the participating manufacturer is at
no fault in this situation. A high-level reason for the result of the investigation must include theoption of “CAB inaction or delay not attributable to manufacturer”.

Table 7
Table 8
Table 9Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

7.2.2

Obtaining products

It is possible (or probable) that the person contacted by the CAB to obtain a new product may haveno authority to obtain a product for EPEAT. The EPEAT Program should develop a process by which
they can obtain products for testing. It is also not clear who would pay for the product in this case.
Manufacturers typically do not budget for this situation.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

7.2.2

Test sample for Level 2
investigation

Disagree with adding the change in 7.2.2 regarding the prohibition on the use of "returned,
repaired, or refurbished products and products not in the original packaging" in the Level 2
investigation.
Especially for the high-priced models, it is quite difficult for a manufacturer to pay the full cost ofobtaining test model in terms of budgeting since the testing models are randomly selected. EPEAT
should allow CABs manufacturer flexible ways for sampling including the use of "returned, repaired,or refurbished products and products not in the original packaging", as long as CABs can verify the
conformance with selected criteria

Cleet, Chris

Information Technology Industry
Council (ITI)

Global Electronics Council

December 30, 2022

P66

7.2.2 (3rdpara)

CAB submittals

Published February 15, 2023

It is not clear who (top of page 60) automatically receives a nonconformance in the case where the
CAB is unable to submit one or more Investigation Reports before the submission deadline. The
Participating Manufacturer should not receive a nonconformance for failed submission by the CAB.

Page 22 of 27

EPEAT Program Stakeholder Comment Report
Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)
Comments are first listed alphabetically by the last name of the individual providing comments, and then grouped by document and listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Topic

Comment

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

7.2.2 and
7.2.3

CAB submittals

Language states that CABs are encouraged to submit IRs as soon as possible after they are received.
This should be reworded to include a stipulation that closing the IR should only be completed after
the manufacturer has had an opportunity to use the entire allotted time of the investigation. If the
manufacturer indicates additional information will be made, the CAB must allow additional
evidence to be provided. Premature report closures of this type have occurred and createssignificant confusion. This also may encourage wrong behavior by auditors and CABs. Prematureconclusions can and have occurred and could lead to appeals.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

7.2.2
(pg 61 – topof page)

Minor errors

Another instance where a minor error should be identified is when a CAB cannot find public
information but a Particpating Manufactuer can show it exists.
Suggested change (to Minor Error table on top of page 61) add bullet:
Where a complaint or a CAB or EPEAT cannot find public disclosures for a criterion but the
manufacturer can prove it was there.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

7.2.2

Test sample for Level 2
investigation

Disagree with adding the change in 7.2.2 regarding the prohibition on the use of "returned,
repaired, or refurbished products and products not in the original packaging" in the Level 2
investigation.
Especially for the high price model, it is quite difficult for manufacturer to pay full cost of obtaining
test model in terms of budgeting since the testing models are randomly selected. EPEAT should
allow CABs manufacturer the flexible ways for sampling including the use of "returned, repaired, or
refurbished products and products not in the original packaging" as far as CABs can verify the
conformance with selected criteria.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

Not
provided

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

7.2.3

Global Electronics Council

Investigation Phase –Minor Error – last bullet

Language should be added that stipulates “when product cannot be shipped from country ofregistration due to manufacturer sales/trade compliance policies” – there should be no NC in thiscase.

Deliberations Phase

If a CAB contacts a manufacturer during this time for additional information, there should be
additional time granted to respond that is not part of the 5 day requirement of the CAB. The CAB's
limits should not be imposed on the manufacturer.

Published February 15, 2023

Page 23 of 27

EPEAT Program Stakeholder Comment Report
Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)
Comments are first listed alphabetically by the last name of the individual providing comments, and then grouped by document and listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Topic

Comment

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

7.2.3

Deliberations Phase

It is not clear who (third bullet of page 66) automatically receives a nonconformance in the casewhere the CAB is unable to submit one or more Investigation Reports before the submission
deadline. The Participating Manufacturer should not receive a nonconformance for failed
submission by the CAB.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

7.2.3

Deliberations Phase

If a CAB is unable to complete the update within the five business days, CABs must inform the
EPEAT Program and they should inform the participating manufacturer. The EPEAT program actions
should be notifying the participating manufacturer, providing the CAB and extension if applicable,
and if no extension is granted, then include in the outcomes report a category for “CAB inaction ordelay not attributable to manufacturer”.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

7.2.4.1

Investigated Products

In a global business, deadlines are tracked via business days rather than calendar days. Further, allshort term timelines should be in business Days and should not span Major holidays . This impacts
all parts of the program (CABs, EPEAT and Mfrs).
Suggested change:
For both minor errors and nonconformances, Participating Manufacturers have 30 calendar
business days to make corrections.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

7.2.4.1(pg 67 – topof page)

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

Cleet, Chris

Information Technology Industry
Council (ITI)

Cleet, Chris

Information Technology Industry
Council (ITI)

Global Electronics Council

Further clarifications

Manufacturers should be given an equal amount of time as the CAB to respond; an additional 5business days should be inserted (10 business days total)

7.2.5

Reporting Phase

Since outcomes of “CAB inaction or delay not attributable to manufacturer” do not materially affectthe validity of products in the EPEAT Registry, these should not be disclosed in the Outcomes
Report. Purchasers will be confused if this is included in the report.

P66

Pg 68

Corrective action phase

Suggest (as above) that this should be 30 Business days.

December 30, 2022

P66

Pg 69

Table 11As above, all small-term timelines should be in Business days

December 30, 2022

P66

Not
provided

Table 11This list should include other online documentation like service manuals that can be updated withno significant loss to compliance. Please add.

Published February 15, 2023

Page 24 of 27

EPEAT Program Stakeholder Comment Report
Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)
Comments are first listed alphabetically by the last name of the individual providing comments, and then grouped by document and listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Topic

Comment

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

9.1.1

Complaints

There is no legitimate benefit to limiting the time for filing a complaint. It may take time for thecritical aspects to be proven out and/or constructed over very complex periods of information
submittals, review, etc.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

9.2.1.1

Appeals

As with complaints, there is no benefit to set a time limit on filing an appeal. If a legitimate reason isdetermined, it should be justifiably applicable.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

9.3

EPEAT Program
Complaints and Appeals
process

The make up of the Complaints/Appeals Committee should be defined in the manual. The titles of
who is to be included should be disclosed and made transparent in these procedures.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

12.3

Definitions –Competence

It is not clear what benefit the term “competence” provides. As noted in our comments to Section
6, this term should be deleted.

Cleet, Chris

Information Technology Industry
Council (ITI)

December 30, 2022

P66

12.3

Definitions – Conformity
Requirements andGuidance Materials

Per our comments on the EPEAT Policy Manual, the terms “guidance” and “conformity
requirements” (and “clarifications”) are not interchangeable, nor should they be combined.
Suggest reverting to the original definition of “Guidance Materials” and provide additional
definitions.

Elwood, Holly

Environmental Protection Agency

December 12, 2022

P65

4.0

EPEAT Criteria

Much of the content of this section is repetitive to what is in the EPEAT Criteria Development
Process document. Suggest considering whether to retain this information in this document. If a
separate stand alone document covering this topic is helpful for sharing with stakeholders, thensuggest mirroring the exact text in both places to ensure full alignment. At a minimum, a reference
to the EPEAT Criteria Development process document should be added to the beginning of thissection so stakeholders can read it for further details.

Elwood, Holly

Environmental Protection Agency

December 12, 2022

P65

4.0

EPEAT Criteria –Innovation Point

The document references the continued use of innovation points for some product categories.
Criteria for innovation only exist in the mobile phones UL110 standard. Once the new Sustainability
Impact Modules are adopted, our understanding was that the standards currently used under the
EPEAT system for mobile phones, computers, servers, imaging equipment, and TVs would no longer
be used, meaning that all criteria in these standards would no longer be used. If that is the case,please make a note to remove this paragraph as soon as the new criteria are completed and in use
in the EPEAT Product Registry – in the FY25 update to this document.

Global Electronics Council

Published February 15, 2023

Page 25 of 27

EPEAT Program Stakeholder Comment Report
Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)
Comments are first listed alphabetically by the last name of the individual providing comments, and then grouped by document and listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

Section

Topic

Comment

Elwood, Holly

Environmental Protection Agency

December 12, 2022

P65

4.2.1 andthroughout
thedocument

Selection of ProductCategories

Recommend including direct links to other reference GEC documents in this and all EPEAT policy
documents to further simplify the reader’s efforts.

Elwood, Holly

Environmental Protection Agency

December 12, 2022

P65

5.2

Documentation Review

Similar comment to one made on EPEAT Conformity Assessment Implementation Manual regarding
this sentence: “In both pathways, the Initial Documentation Review is completed immediately andrequires Participating Manufacturers to demonstrate conformance with all selected EPEAT Criteria
at the outset.” Not clear on whether both the Certification Pathway and the Priority Verification
Pathway require conformance with every criterion in the set which apply to a product prior to
posting on the EPEAT Product Registry. Understood that the Priority Verification Pathway allowed
manufacturers to have their initial products go through desk review, and then once they pass, theOEM can post as many other products as they would like on the EPEAT Registry.

Elwood, Holly

Environmental Protection Agency

December 12, 2022

P65

5.2

Documentation Review

This section seems to be saying that both the Priority Verification Pathway and the Certification
Pathway verifications are valid for three years ( “In the Priority Verification Pathway, the Initial
Documentation Review is staggered over several months for up to one year and the results are valid
until the EPEAT Program implements Criteria resulting from a Full Product Category Revision.”.
Does this mean that GEC is no longer conducting snapshots of the Registry and doing spotchecks ofsubsets of criteria for the Priority Verification Pathway products via verification rounds? If both
pathways allow certification to be good for three years, what is the real difference between thetwo?

Elwood, Holly

Environmental Protection Agency

December 12, 2022

P65

8.1

Recognized Potential
Conflicts of Interest

For sources of income for GEC, please add the others cited at the beginning of this document –grants for research, etc.

Elwood, Holly

Environmental Protection Agency

December 12, 2022

P65

8.1

GEC CAB andIndependence

To reduce conflicts of interest, it has been noted several times previously that it may make sense
for GEC to cease their work as a CAB, due to their work as a manager of all CABs.

Elwood, Holly

Environmental Protection Agency

December 12, 2022

P66

6.3.1

New Products

Not supportive of clarification that participating manufacturer and/or CAB may develop analternative way to demonstrate competence for Corporate Criteria with annual performancerequirements. All verification requirements should be developed by Technical Committees toensure voluntary consensus-based processes are used and there is transparency and multistakeholder input into the crafting process.

Global Electronics Council

Published February 15, 2023

Page 26 of 27

EPEAT Program Stakeholder Comment Report
Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)

EPEAT PROGRAM STAKEHOLDER COMMENT REPORT
Comments received during the October 17 through December 31, 2022 Stakeholder Comment Period
on Proposed Revisions to EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66)
Comments are first listed alphabetically by the last name of the individual providing comments, and then grouped by document and listed numerically by section in the document.
Commenter

Organization

Date Submitted

Document

SectionElwood, Holly

Environmental Protection Agency

December 12, 2022

P66

Elwood, Holly

Environmental Protection Agency

December 12, 2022

Elwood, Holly

Environmental Protection Agency

Elwood, Holly

Environmental Protection Agency

Global Electronics Council

Topic

Comment

2.1

Overview – Priority
Verification Pathway

The following statement is confusing: “In both pathways, the Initial Documentation Review iscompleted immediately and requires Participating Manufacturers to demonstrate conformance withall selected EPEAT Criteria at the outset”. My understanding was that there is a full review anddetermination of conformance against all the criteria for each product prior to being posted on the
EPEAT Registry under ONLY the Certification Pathway. Please clarify. Also, what is the difference
between “product sampling”, stated as used under the Priority Verification Pathway, and “productbatching” stated as used under the Certification Pathway?

P66

2.1

Overview

The document states: “For both Pathways, Participating Manufacturers follow the same process toparticipate in the EPEAT Program…..: “Prior to the first products becoming EPEAT-registered for a
product category, a Participating Manufacturer must complete Initial Documentation Review.
During this process, the GECapproved CAB assesses documentation provided by the Participating
Manufacturer to determine if the evidence supports conformance with EPEAT Criteria and if theParticipating Manufacturer understands the obligations of the Criteria. Once Initial Documentation
Review is complete, the Participating Manufacturer’s products are EPEAT-registered”. So undereither pathway a manufacturer can add as many products as they want following completion ofdesk review? I thought that under the Certification Pathway a product had to be tested and provento meet every single criterion before it is allowed to be added to the EPEAT Registry?

December 12, 2022

P66

2.2.1

Clarifications

Suggest adding the following: “All clarifications are shared with the GEC criteria development team
to be addressed in the continuous maintenance process for the relevant criteria”.

December 12, 2022

P66

4.2.1

Annual Auditor
Refresher Training

Some text is missing from this sentence – please correct: Auditors returning from a leave are only
required to review the most recent Annual EPEAT Auditor Refresher Training, even if they were on
leave for more than Annual EPEAT Auditor Refresher Training session, as long as the leave wascontinuous (e.g., a two-year parental leave). Ditto with this sentence: Auditors returning from aleave are only required to successfully pass the most Annual EPEAT Auditor Proficiency Exam, even if
they have missed more than one Annual EPEAT Auditor Proficiency Exam, as long as the leave wascontinuous (e.g., a two-year parental leave).

Published February 15, 2023

Page 27 of 27