EPEAT Program
Continuous Monitoring Outcomes ReportServers
SV-2022-04
March 20, 2023

1.0 Background
EPEAT® is a comprehensive voluntary sustainability Type 1 ecolabel that helps purchasers identify sustainable
technology products and services. Central to EPEAT are conformity assurance activities that meet the technicalrigor and credibility needs of the institutional purchasers who rely upon EPEAT. The EPEAT Program ensures
the ongoing conformance of EPEAT-registered products through an ongoing surveillance process known asContinuous Monitoring. Continuous Monitoring activities occur throughout the year and test the ability ofParticipating Manufacturers to prove conformance with EPEAT Criteria on an ongoing basis.
Some Continuous Monitoring activities require that Investigations be conducted in discrete timeframes calledRounds. The EPEAT Program develops an individual plan for each Continuous Monitoring Round, which
specifies the EPEAT Criteria to be investigated, the method of investigation that GEC-approved Conformity
Assurance Bodies (CABs) must use and the specific dates when the Investigation activities must be completed.
The EPEAT Program also selects the Participating Manufacturers and EPEAT-registered products and assigns
Investigations to CABs, which must fully participate in and are responsible for implementing Continuous
Monitoring Round activities with their Participating Manufacturer clients. Participating Manufacturers arerequired to cooperate fully with their GEC-approved CAB during Round activities.
To maintain the level of transparency relied on by purchasers, the EPEAT Program publishes an Outcomes
Report at the conclusion of each Round to summarize the activities conducted and to identify the products andParticipating Manufacturers that received nonconformances and the actions taken to restore accuracy of theEPEAT Registry.
This document summarizes the activities and results of Continuous Monitoring Round SV-2022-04 conductedfor the Servers category.

2.0 Overview of Continuous Monitoring Round SV-2022-04
2.1

Investigation Activities

As per the published Round Plan, Continuous Monitoring Round SV-2022-04 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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2.2

March 20, 2023

Criteria InvestigatedContinuous Monitoring Round SV-2022-04 focused on corporate Criteria with annual disclosure requirements,
to confirm that Participating Manufacturers are fulfilling annual reporting requirements for the Criteria
investigated. Since one Criterion is required, and one is optional, Participating Manufacturers received up totwo investigations. If a Participating Manufacturer was investigated for any of the selected Criteria in another2022 Continuous Monitoring Round, the Criterion was not assigned again in this Round, given the annual
disclosure requirements. The products for investigation were selected randomly using a random number
generator.
Table 1: Criteria Investigated in Round SV-2022-04
Criteria Number

Criterion Title

12.3.1Public disclosure of use of conflict materials in products (corporate)

12.5.3

Environmental impact of product transportation (corporate)

3.0 Summary of Investigations and Final Decisions on Conformity for SV-2022-04
Highlights from this Continuous Monitoring Round are:•6 investigations completed•

4 decisions of Conformance•

2 decisions of Nonconformance

Further details provided in Section 4. All nonconformanceswere due to CAB inaction or delay not attributable to theParticipating Manufacturer.

Figure 1: Final Conformity Decisions for SV-2022-04(shown as percentage of total investigations)4.0 Further Details on Nonconformances for SV-2022-04
Table 2 below provides a further breakdown of the nonconformances by Criterion. All nonconformances must
be categorized as either a minor error, nonconformance, or nonconformance due to CAB inaction or delay not
attributable to the Participating Manufacturer.

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Table 2: Breakdown of Nonconformances by Criterion for SV-2022-04
Criteria NumberCriterion Title

12.3.1

Public disclosure of use of conflict materials in products (corporate)

4.1

Total Nonconformances
2

Minor Errors Versus Nonconformances

All nonconformances must be categorized as either a minor error, nonconformance, or nonconformance due
to CAB inaction or delay not attributable to the Participating Manufacturer. Minor errors are non-critical or
clerical in nature and do not materially affect the validity of conformance with EPEAT Criteria. Allnonconformances that do not meet the definition of minor errors are categorized as nonconformances (unlessthey are due to CAB inaction or delay).
All nonconformances in Continuous Monitoring Round SV-2022-04 were nonconformances due to CAB inaction
or delay not attributable to the Participating Manufacturer.
4.2

Minor Errors

For Level 1 Investigations, nonconformances may be categorized as minor errors 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 errors found in Round SV-2022-04.
4.3

Nonconformances

All nonconformances in Continuous Monitoring Round SV-2022-04 were nonconformances due to CAB inaction
or delay not attributable to the Participating Manufacturer, because the CAB failed to submit the Investigation
Report.

5.0 Actions to Restore Conformance
Where the final conformity decision is nonconformance (including minor errors and those due to CAB inaction
or delay), Participating Manufacturers must make corrections to restore the accuracy of the EPEAT Registryduring the Corrective Action Phase. These activities may include providing additional evidence to demonstrate
conformance with the criterion or unselecting the criteria in the EPEAT Registry. Where the product was foundnonconformant and is no longer available in the marketplace, the product must be archived.
During the Corrective Action Phase, Participating Manufacturers must also develop Corrective Action Plans forother EPEAT-registered products that may be affected by the same underlying issue causing thenonconformance but were not the subject of investigation (called “similarly affected products”).
The following actions were taken to restore accuracy to the EPEAT Registry as a result of Continuous
Monitoring Round SV-2022-04:

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CAB reviewed evidence originally submitted by Participating Manufacturers,
which demonstrated conformance

Table 3 in Section 7 identifies the Participating Manufacturers and products that received nonconformances inContinuous Monitoring Round SV-2022-04.

6.0 Key Findings
6.1

Conflict Minerals Disclosures in Conformance with Rule 13p-1

Participating Manufacturers are reminded that disclosures on use and sources of conflict minerals, per theCriterion, must be conformant with Rule 13p-1 under the US Securities Exchange Act of 1934. Per Rule 13p-1
and the Form SD, if due diligence is necessary, Participating Manufacturers “must exercise due diligence on thesource and chain of custody of its conflict mineral, as discussed in paragraph (c)(1) of this item, that conforms
to a nationally or internationally recognized due diligence framework, if such a framework is available for theconflict mineral.” Participating Manufacturers should identify the framework used.
6.2

12.5.3 Environmental Impact of Product Transportation — Multiple Elements

Participating Manufacturers are reminded to ensure they address all elements of optional Criterion 12.5.3 –Environmental impact of product transportation (corporate). This includes the scope of the criterion,
specifically, that it covers greenhouse gas (GHG) emissions from supply chain transportation activities for
products declared to conform to this category, from the point of final product assembly to the customer, ortransfer of product ownership and that it includes well-to-wheel GHG emissions from all modes of freight
movement utilized. Participating Manufacturers must confirm the scope in the evidence provided.
When third-party verification applies, documentation of both the credentials and contact information of thethird-party verifier must be provided.

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7.0 Identification of Nonconformances and Corrections Made by Participating Manufacturers
In the interest of transparency, the EPEAT Program identifies the Participating Manufacturers and products that received nonconformances and the actions taken to restore accuracy of the EPEAT Registry.
Minor errors are generally clerical in nature and do not materially affect the validity of products in the EPEAT Registry. As such, these are not identified in the table below.
Table 3: Summary of Nonconformances and Corrections Made by Participating Manufacturers
Participating Manufacturer

ProductProduct TypeCountry

Criterion Number

Criterion Title

Required or Optional

Underlying Reason for NonconformanceCorrective Action Taken

Cisco

UCSC- C220 M5

Rack-mounted server

United States

12.3.1

Public disclosure of use of
conflict materials in products(corporate)

Required

CAB inaction or delay not attributableto Participating Manufacturer

LenovoLenovoThinkSystem
SR670 V2

Rack-mounted server

Canada12.3.1

Public disclosure of use of
conflict materials in products(corporate)

Required

CAB inaction or delay not attributableto Participating Manufacturer

CAB reviewed evidence originallysubmitted by Participating
Manufacturers, which
demonstrated conformance
CAB reviewed evidence originallysubmitted by Participating
Manufacturers, which
demonstrated conformance

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Document Control and Change History
Issue
1Revision
0Owner
EPEAT Conformity
Assurance Manager
EPEAT Conformity
Assurance Manager
Senior Manager,
Ecolabels andResources

112021Senior Manager,
Ecolabels andResources

22Senior Manager,
Ecolabels andResources

Global Electronics Council

ApproverDirector, EPEAT
ProgramDirector, EPEAT
Program
Senior Director,
Ecolabels andManufacturer
ResourcesVice President,
Ecolabels andManufacturer
Resources
Vice President,
Ecolabels andManufacturer
Resources

Description
Initial release

Approval Date

Effective Date2018 Dec 112018 Dec 11

Reformatting of document. Addition ofstandardized text.

2021 Mar 25

2021 Mar 30

Updated terminology fornonconformances to include“nonconformances” and “minor errors”,
in alignment with revisions to P66.
Updated to reflect new nonconformance
category for CAB inaction or delay

2022 Sep 152022 Sep 30

2023 Mar 92022 Mar 13

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