EPEAT™ Conformity Assurance
Implementation Manual
Proposed Revisions to EPEAT Conformity Assurance
Implementation Manual
Public Comment Period
October 17, 2022 through December 16, 2022
The EPEAT Program makes policy and procedural updates on an annual basis and is proposing revisions
to the EPEAT Policy Manual and the EPEAT Conformity Assurance Implementation Manual.
The EPEAT Policy Manual identifies policies that govern and support EPEAT programmatic activities. The
companion document, EPEAT Conformity Assurance Implementation Manual, defines the specificrequirements and expectations of manufacturers or brands that have active EPEAT-registered products
or are in the process of confirming that their products conform with EPEAT criteria (Participating
Manufacturers) and of EPEAT-approved Conformity Assurance Bodies (CABs).

Stakeholder feedback and insights are an essential part of the Global Electronics Council’s(GEC) management of the EPEAT Program. As such, GEC is holding a 60-day comment period
and welcomes stakeholder feedback on the October 2022 proposed revisions to the EPEAT
Policy Manual and the EPEAT Conformity Assurance Implementation Manual. The comment
period is open from October 17 through December 16, 2022. Comments must be provided in
the EPEAT Public Comment Form and submitted electronically to EPEAT@GEC.org.
GEC reserves the right to not consider comments received after 11:59 pm North America
Pacific Time on December 16, 2022.
All comments will be thoughtfully considered before either document is finalized and published. GEC
intends to publish a stakeholder comment report summarizing comments received and attributing thecomments to the submitting party.
GEC proposes to publish the revised documents on February 15, 2023. Unless otherwise identified in the
document, new policy changes are proposed to become effective as of July 1, 2023. Participating
Manufacturers and EPEAT-approved CABs will be responsible for conforming with the new requirements
as of this date.

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EPEAT Conformity Assurance Implementation Manual – Proposed Revisions
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Summary of Proposed Changes
Throughout this document, proposed revisions to EPEAT Conformity Assurance Manual (P66) are
identified using tracked changes, with the exception of correcting typos or grammatical errors, minorchanges to sentence structure, and minor formatting changes. Table A below provides a summary of the
key proposed clarifications (additional clarity on existing requirements), changes (changes to an existing
requirement), and additions (new requirements).
Table A: Summary of Key Proposed Clarifications, Changes, and Additions in P66
Topic

SectionSummary

Overview

2.1

Change: Removal of Priority Criteria to further clarify that EPEATaligns with ISO 14024.

Clarifications

2.2.1

Addition: Clarifications may also be released for 30-day
Conformity Guidance Group review period.

Conformity Requirements andGuidance

2.2.2

Change: Section renamed to “Conformity Requirements andGuidance Materials” and Materials will also provide further
details regarding demonstration of conformance with EPEAT
Criteria.

Conformity Assurance Where
Equivalent Regulatory
Requirements Exist

2.2.5

Change: Section deleted as the conformity option no longer
available (lack of uptake).

CAB Eligibility Requirements

3.1

Addition: Footnote to address Auditor training requirements forrevised Criteria from Sustainability Impact Modules.

Qualifying Auditors

3.3.1

Addition: Footnote to address Auditor training requirements forrevised Criteria from Sustainability Impact Modules.

CAB Mentored Work Phase

3.5

Addition: Footnote to clarify process for review of revised Criteria
from Sustainability Impact Modules.

Initial EPEAT Training
Requirements

4.1

Addition: Description of training and footnote to address training
for revised Criteria from Sustainability Impact Modules.

Ongoing Training and Other
requirements

4.2

Clarification: If an Auditor loses qualifications, existing work must
be re-assigned.

Annual EPEAT Auditor
Refresher Training

4.2.1

Clarification: Process for Auditors returning from leave and for
new Auditors that qualify after annual training has occurred.

Annual EPEAT Auditor
Proficiency Exam

4.2.2

Clarification: Process for Auditors returning from leave and for
new Auditors that qualify after annual training has occurred.

Continuous Monitoring
Training

4.2.3

Clarification: Auditors are only required to attend the training orreview the recordings for specific Criteria they are investigating.
For Level 2, at least one CAB representative must attend.

Accreditation(Table 1, Records)

5.1

Clarification: Records must be retained for a minimum of three
years after the contract with a Participating Manufacturer ends.

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Table A: Summary of Key Proposed Clarifications, Changes, and Additions in P66
Topic

SectionSummary

Nonconformances andCorrective Actions

5.2.2

Change: Evidence of corrections must be provided duringcorrective action timeframe.

Nonconformances Related to
Conformity Decisions

5.2.2.1

Clarification: Deletes “within three business days” to clarify that if
CAB is unable to provide documentation demonstrating their
original conformity decision is accurate, within 30 calendar daysof receiving the audit report, they must notify the Participating
Manufacturer and obtain necessary evidence.

CAB Performance Metrics –Metric 1

5.3

Change: Deleted requirement for CABs to have a policy in placethat identifies customer service is measured and improved.

CAB Performance Metrics –Metric 3

5.3

Clarification: Auditors are only required to attend the training orreview the recordings for specific Criteria they are investigating.
For Level 2, at least one CAB representative must attend.

CAB Performance Metrics –Metric 4

5.3

Addition: CABs must notify EPEAT Program of any personnel
changes impacting Annual Auditor Refresher Training attendance.

CAB Performance Metrics –Metric 11

5.3

Addition: Requires CABs to follow correct format for completing
Investigation Reports.

CAB Performance Metrics –Metric 12

5.3

Change: Removes double counting in Metrics 10 and 12.

Priority Criteria

6.1.4.2

Change: Removal of Priority Criteria to further clarify that EPEATaligns with ISO 14024.

Types of Evidence and Ensuring
Integrity of Evidence

6.1.4.2

Addition: Adds requirement for declarations of conformity tofurther align with ISO 14024 (Section 7.4.4)

Assessing Competence

6.1.5

Clarification: Additional information and examples for whencompetence may or may not be demonstrated.

Assessing Conformance

6.2.2

Change: Removal of Priority Criteria to further clarify that EPEATaligns with ISO 14024.

Activating products

6.2.4

Change: Removal of Priority Criteria to further clarify that EPEATaligns with ISO 14024.
Addition: Requirement for Participating Manufacturer to confirm
in the EPEAT Registry that any new products registered are similar
to an existing product (for further alignment with ISO 14024).

Initial Documentation Review
of Non-Priority Optional
Criteria

6.3.1(previously)

Change: Section deleted to reflect removal of Priority Criteria tofurther clarify that EPEAT aligns with ISO 14024.

Adding New Products During
12-month Period

6.3.1.1(previously)

Change: Section deleted to reflect removal of Priority Criteria tofurther clarify that EPEAT aligns with ISO 14024.

Selecting New Non-Priority
Optional Criteria During 12month Period

6.3.1.2(previously)

Change: Section deleted to reflect removal of Priority Criteria tofurther clarify that EPEAT aligns with ISO 14024.

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Table A: Summary of Key Proposed Clarifications, Changes, and Additions in P66
Topic

SectionSummary

New Products

6.3.1

Change: Updated to reflect removal of Priority Criteria to further
clarify that EPEAT aligns with ISO 14024.
Addition: Requirement for Participating Manufacturer to confirm
in the EPEAT Registry that any new products registered are similar
to an existing product (for further alignment with ISO 14024).
Clarification: Participating Manufacturer and/or CAB may develop
an alternative way to demonstrate competence for Corporate
Criteria with annual performance requirements.

Continuous Monitoring –Overview

7.1

Clarification: Products for Level 2 Investigations must be new andreceived by lab in original packaging.

Continuous Monitoring Rounds

7.2

Change: Adds actions EPEAT may take under force majeurecircumstances.

Investigation Phase

7.2.2

Clarification: Products for Level 2 Investigations must be new andreceived by lab in original packaging.

Deliberation Phase

7.2.3

Clarification: EPEAT may provide CABs with five additional
business days to address questions or revise the Investigation
Report.

Investigated Products

7.2.4.1

Clarification: Timeframe for CABs to address questions or revise
the Corrective Action Investigation Report.

8.0

Change: Updated to reflect removal of Priority Criteria to further
clarify that EPEAT aligns with ISO 14024.

Continuous Monitoring

9.2.1.2

Clarification: Additional details on process and timeframes forappeals raised to CABs during Continuous Monitoring.

Force Majeure Events

10.0

Addition: Updated to address impacts of force majeure events on
ongoing conformity assurance activities.

Revisions and Effective Date

11.0

Addition: Section added to identify annual review and revisionschedule and indicate that revisions may become effective at an
earlier or later date than annual schedule.

Definitions

12.3

Change: Updated definitions – Certification Pathway, Conformity
Requirements and Guidance Materials, Priority Criteria, andPriority Verification Pathway.

Changing CABs

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EPEAT™
Conformity Assurance
Implementation
ManualThis document identifies the requirements of the EPEAT Conformity Assurance System and related
activities. As such, it defines the obligations and expectations of all manufacturers or brands that haveactive EPEAT-registered products or are in the process of confirming that their products conform with
EPEAT criteria (called Participating Manufacturers) and of all Conformity Assurance Bodies approved
to provide EPEAT conformity assurance services (called GEC-approved CABs).
A companion document, EPEAT Policy Manual (P65), defines the policies that govern all EPEAT
programmatic activities and forms the basis for this Implementation Manual. Participating
Manufacturers and GEC-approved CABs must operate in accordance with both Manuals as of theireffective date to fulfill EPEAT Program requirements.
The EPEAT Program reviews the EPEAT Policy Manual (P65) and EPEAT Conformity Assurance
Implementation Manual (P66) on an annual basis to determine if revisions are required.
The latest revisions to this document were published on February 15, 20232022. These revisions,
unless otherwise noted, are effective as of July 1, 20232022.
Please direct any questions on this document to EPEAT@GEC.orgGlobalElectronicsCouncil.org.

Proposed Revisions October 17, 2022

Contents
1.0

Introduction ................................................................................................................ 4

2.0

EPEAT Conformity Assurance System ........................................................................... 5
Overview............................................................................................................................... 5
EPEAT Technical Guidance and Authority ............................................................................ 7
2.2.1 Clarifications ............................................................................................................. 7
2.2.2 Conformity Requirements and Guidance Materials................................................. 7
2.2.3 Technical Questions ................................................................................................. 9
2.2.4 Conformity Guidance Group (CGG) .......................................................................... 9Contents

3.0

Approval of Conformity Assurance Bodies (CABs) ...................................................... 12
CAB Eligibility Requirements .............................................................................................. 12
Applicant Status .................................................................................................................. 13
Provisional Status ............................................................................................................... 13
3.3.1 Qualifying Auditors ................................................................................................. 13
3.3.2 Supporting Documentation .................................................................................... 14
3.3.3 Initial EPEAT Audit .................................................................................................. 14
Approved Status ................................................................................................................. 15
CAB Mentored Work Phase ................................................................................................ 15

4.0

Qualified Auditor Proficiency and Training ................................................................. 17
Initial EPEAT Training Requirements .................................................................................. 17
Ongoing Training and Other Requirements ....................................................................... 18
4.2.1 Annual EPEAT Auditor Refresher Training.............................................................. 19
4.2.2 Annual EPEAT Auditor Proficiency Exam ................................................................ 19
4.2.3 Continuous Monitoring Training ............................................................................ 20
4.2.4 Calibration Meetings .............................................................................................. 21

5.0

Ongoing Requirements of CABs ................................................................................. 22
Accreditation ...................................................................................................................... 22
Annual EPEAT Audit of CAB ................................................................................................ 24
5.2.1 Audit Methodology ................................................................................................ 24
5.2.2 Nonconformances and Corrective Actions............................................................. 26
CAB Performance Metrics .................................................................................................. 27
CAB Summit ........................................................................................................................ 30
Inappropriate Use of EPEAT Name and Marks ................................................................... 30
Performance Improvement, Suspension or Termination................................................... 31
5.6.1 Performance Improvement Assistance Plans......................................................... 31
5.6.2 Suspension and Termination .................................................................................. 32
Administration of Participating Manufacturer Clients ....................................................... 34

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6.0

Documentation Review ............................................................................................. 35

Contents

General Requirements........................................................................................................ 35
6.1.1 Overview................................................................................................................. 35
6.1.2 Documentation Review Process ............................................................................. 36
6.1.3 Documentation Review Plan .................................................................................. 37
6.1.4 Assessing Conformance .......................................................................................... 37
6.1.5 Assessing Competence ........................................................................................... 40
6.1.6 Activating Products and Criteria............................................................................. 41
6.1.7 Documentation Review Records ............................................................................ 41
Initial Documentation Review ............................................................................................ 42
6.2.1 Documentation Review Plan, Product Selection and Sampling ............................. 42
6.2.2 Assessing Conformance .......................................................................................... 43
6.2.3 Assessing Competence ........................................................................................... 43
6.2.4 Activating Products................................................................................................. 43
Ongoing Documentation Review ........................................................................................ 45
6.3.1 New Products ......................................................................................................... 47
6.3.2 New Optional Criterion .......................................................................................... 47
6.3.3 New Location of Use (Country) .............................................................................. 48
6.3.4 Loss of Confidence in Participating Manufacturer Competence ........................... 48
6.3.5 EPEAT Criteria Revisions ......................................................................................... 48
Rebranding of EPEAT-Registered Products ........................................................................ 50
Nonconformances Outside Continuous Monitoring .......................................................... 54
6.5.1 Nonconformances Identified by a CAB .................................................................. 54
6.5.2 Nonconformances Identified by EPEAT Program ................................................... 54

7.0

Continuous Monitoring ............................................................................................. 56
Overview............................................................................................................................. 56
Continuous Monitoring Rounds ......................................................................................... 57
7.2.1 Preparation Phase .................................................................................................. 58
7.2.2 Investigation Phase ................................................................................................ 59
7.2.3 Deliberation Phase ................................................................................................. 65
7.2.4 Corrective Action Phase ......................................................................................... 66
7.2.5 Reporting Phase ..................................................................................................... 69
Annual Renewal .................................................................................................................. 70
7.3.1 Criteria with Corporate Level Annual Reporting Requirements ............................ 70
7.3.2 Minor and Major Criteria Revisions........................................................................ 70
7.3.3 Product and Corporate Changes ............................................................................ 71
7.3.4 Updates to EPEAT Program Requirements and Guidance ..................................... 71
7.3.5 Nonconformances and Corrections........................................................................ 72

8.0

Changing CABs .......................................................................................................... 73

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9.0

Complaints and Appeals ............................................................................................ 75
Complaints .......................................................................................................................... 75
9.1.1 Complaints Raised to CABs ..................................................................................... 75
9.1.2 Complaints Raised to EPEAT Program .................................................................... 76
Appeals ............................................................................................................................... 76
9.2.1 Appeals Raised to CABs .......................................................................................... 76
9.2.2 Appeals Raised to EPEAT Program ......................................................................... 77
EPEAT Program Complaints and Appeals Process .............................................................. 78
Non-Conformity Assurance Related Complaints ................................................................ 79

10.0 Force Majeure Events ................................................................................................ 80
11.0 Revisions and Effective Date ...................................................................................... 81

Contents

12.0 Supplementary Information ...................................................................................... 82
Acronyms ............................................................................................................................ 82
References .......................................................................................................................... 82
Definitions .......................................................................................................................... 83
Annex 1: Nonconformances and Minor Errors ................................................................... 90
Annex 2: Level 0 Investigations .......................................................................................... 91
Annex 3: Level 1 Investigations .......................................................................................... 92
Annex 4: Level 2 Investigations .......................................................................................... 93
Document Change History.................................................................................................. 94

List of Tables
Table 1: EPEAT Requirements for CAB Quality Management Systems .................................................. 22
Table 2: CAB Performance Metrics and Annual Expectations ................................................................ 28
Table 3: Documentation Review Requirements for EPEAT Criteria Revisions ....................................... 49
Table 4: Responsibilities During Rebranding of EPEAT-Registered Products ......................................... 51
Table 5: Actions and Evaluation for Nonconformances Identified Outside Continuous Monitoring..... 55
Table 6: Continuous Monitoring Activities ............................................................................................. 56
Table 7: Level 0 Investigation Activities.................................................................................................. 62
Table 8: Level 1 Investigation Activities.................................................................................................. 63
Table 9: Level 2 Investigation Activities.................................................................................................. 64
Table 10: Corrections for Nonconformances (Level 0, 1 and 2 Investigations)...................................... 68
Table 11: Corrections for Minor Errors (Level 0, 1 and 2 Investigations) ............................................... 69

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1.0 Introduction
EPEAT™® is a comprehensive voluntary sustainability Type 1 ecolabel that helps purchasers identify
more sustainable technology products and services. Central to EPEAT are conformity assurance activities
that meet the technical rigor and credibility needs of the institutional purchasers who rely upon it. The
EPEAT Program is owned and operated by the Global Electronics Council (GEC), a mission driven nonprofit working to create a world of only sustainable technology products and services.

Introduction

EPEAT Criteria are developed in a multi-stakeholder, voluntary, consensus-based process and addressenvironmental and social impacts across the entire product lifecycle, from extraction of resources andmanufacturing, through to assembly, use and end of life.
EPEAT Criteria are designed to address both attributes of the product and corporate activities of the
Manufacturer and are identified as either Required or Optional. Required Criteria must be met for a
product to become EPEAT-registered. Optional Criteria represent a Participating Manufacturer’scommitment to innovation in environmental and social performance. Depending on the number of
Optional Criteria met, a product may achieve an EPEAT tier of EPEAT Bronze, EPEAT Silver or EPEAT
Gold.
Products that meet EPEAT Criteria are identified in the public facing website called the EPEAT Registry.
Before becoming EPEAT-registered, an independent GEC-approved Conformity Assurance Body (CAB)
must confirm the product’s conformance with EPEAT Criteria. To ensure consistent and objective
assessment of products, the EPEAT Program maintains a Conformity Assurance System, which identifies
the rules for conformity assurance activities and provides oversight and ongoing approval of all CABs.
This document identifies the requirements of the EPEAT Conformity Assurance System and related
activities. As such, it defines the obligations and expectations of all manufacturers or brands that haveactive EPEAT-registered products or are in the process of confirming that their products conform with
EPEAT criteria (called Participating Manufacturers), and of all CABs approved to provide EPEAT
conformity assurance services (called GEC-approved CABs). A companion document, EPEAT Policy
Manual (P65), defines the policies that govern all EPEAT programmatic activities and forms the basis for
EPEAT Conformity Assurance Implementation Manual (P66). Participating Manufacturers and GECapproved CABs must operate in accordance with both Manuals to fulfill EPEAT Program requirements.
The EPEAT Program reviews both this EPEAT Conformity Assurance Implementation Manual (P66) and
EPEAT Policy Manual (P65) on an annual basis to determine if revisions are required.

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2.0 EPEAT Conformity Assurance System
Overview

EPEAT Conformity Assurance System

The EPEAT Conformity Assurance System involves GEC oversight of both GEC-approved CABs and the
EPEAT Program conformity assurance processes and requirements.
GEC establishes CAB Eligibility Requirements and approves and oversees CABs in their provision ofconformity assurance services for the EPEAT Program. Organizations must undergo a robust approval
and audit process prior to becoming GEC-approved CABs. On an ongoing basis, GEC-approved CABs must
maintain third-party accreditations (to either ISO/IEC 17020 Conformity assessment – Requirements forthe operation of various types of bodies performing inspection or ISO/IEC 17065 Conformity assessment– Requirements for bodies certifying products, processes and services), implement EPEAT-specificelements in their quality management systems, maintain the proficiency and qualifications of their
Auditors and successfully participate in an annual EPEAT audit process.
Participating Manufacturers must engage a GEC-approved CAB for each product category prior to having
EPEAT-registered products. Participating Manufacturers may select different GEC-approved CABs fordifferent product categories but may only use a single CAB for each category. GEC-approved CABs are
responsible for assessing Participating Manufacturers’ initial and ongoing conformance with EPEAT
Criteria (Documentation Review) and for implementing surveillance activities (Continuous Monitoring).
Participating Manufacturers may select one of two conformity assurance pathways to demonstrate
initial and ongoing conformance with EPEAT Criteria – the Priority Verification Pathway and theCertification Pathway. Both Pathways require Participating Manufacturers to work with their GECapproved CABs for Documentation Review and Continuous Monitoring. The key differences include
product selection for review, process for adding additional products and/or selecting additional Optional
Criteria and the length of validity of results from Initial Documentation Review. is the pace of the Initial
Documentation Review process.
•In both pathways, the Initial Documentation Review is completed immediately and requires
Participating Manufacturers to demonstrate conformance with all selected EPEAT Criteria at
the outset.

•

In the Priority Verification Pathway, the Initial Documentation Review is staggered over several
months for up to one year. The Priority Verification Pathway relies on product sampling for
selecting products for review, and the evaluation of a Participating Manufacturer’s
competence. Results of Initial Documentation Review are valid until the EPEAT Program
implements the Criteria resulting from a Full Product Category Revision, after which Initial
Documentation Review against the revised Criteria must be performed again. (Any Minor
Criteria Revisions or Major Criteria Revisions must be addressed during Ongoing
Documentation Review.)•

In the Certification Pathway the Initial Documentation Review is completed immediately andrequires Participating Manufacturers to demonstrate conformance with all selected EPEAT

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EPEAT Conformity Assurance System

Criteria at the outset. The Certification Pathway relies on product batching and does not
require the evaluation of a Participating Manufacturer’s competence. Results of Initial
Documentation Review are valid for three years or until the EPEAT Program implements theCriteria resulting from a Full Product Category Revision, whichever is earlier, after which theInitial Documentation Review against the revised Criteriaprocess must be performed again.
(Any Minor Criteria Revisions or Major Criteria Revisions must be addressed during Ongoing
Documentation Review.)
EPEAT-registered products are not identified in the EPEAT Registry as being assessed through theCertification Pathway or the Priority Verification Pathway as both Pathways are equally robust, credible,
and valid.
For both Pathways, Participating Manufacturers follow the same process to participate in the EPEAT
Program:•A Participating Manufacturer executes GEC EPEAT License and Participating Manufacturer
Agreement (P26) with GEC and pays an annual EPEAT Participation Fee for each productcategory, which allows an unlimited number of products to be EPEAT-registered for a given
product category.

•

A Participating Manufacturer also establishes a contractual relationship with a GEC-approved
CAB for the provision of conformity assurance services for the EPEAT Program, which requiresthat the Participating Manufacturer report relevant product or corporate changes to the CAB
on an ongoing basis.

•

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 todetermine if the evidence supports conformance with EPEAT Criteria and if the Participating
Manufacturer understands the obligations of the Criteria. Once Initial Documentation Review
is complete, the Participating Manufacturer’s products are EPEAT-registered.

•

On an ongoing basis, a Participating Manufacturer may choose to select additional EPEAT
Optional Criteria or have new products become EPEAT-registered. In these cases, the GECapproved CAB performs Ongoing Documentation Review where required.

•

To ensure the ongoing conformance of EPEAT-registered products, the EPEAT Program
requires GEC-approved CABs to conduct Continuous Monitoring. These activities occur
throughout the year and test the ability of Participating Manufacturers to prove conformancewith EPEAT Criteria on an ongoing basis. All EPEAT-registered products in all productcategories are subject to Continuous Monitoring at any time, regardless of the conformity
assurance pathway chosen.

•

If any Continuous Monitoring activity results in a nonconformance, the Participating
Manufacturer must make corrections to address the identified nonconformance and restore
accuracy to the EPEAT Registry, as well as develop corrective action plans to address othersimilarly affected products. Should a Participating Manufacturer fail to make the necessary

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corrections, affected products will be removed from the Registry by either the Participating
Manufacturer’s CAB or the EPEAT Program.

EPEAT Technical Guidance and Authority

EPEAT Conformity Assurance System

2.2.1

Clarifications

The EPEAT Program may issue a formal Clarification if the wording in an EPEAT Criterion is ambiguous,or when requested to do so by a GEC-approved CAB or Participating Manufacturer. A request for
Clarification must be submitted electronically to the EPEAT Program and clearly identify the ambiguous
text. The request must also identify examples of how the ambiguity may result in different conformity
decisions and/or propose language to address the ambiguity.
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 30-calendar
day Conformity Guidance Group comment period, per Section 2.2.4.
The EPEAT Program approves and publishes the final Clarification with an effective date, which istypically 30 calendar days after publication but may be longer depending on the impact to conformity
assurance activities. Clarifications must be used in conformity assurance activities after the effective
date with one exception – if a Clarification is issued or becomes effective during a Continuous
Monitoring Round (see Section 7), it does not apply to those specific Continuous Monitoring activities.
Clarifications provide additional information on interpreting the criteria and how they should be
implemented and do not change the criterion text. Clarifications are made available to Participating
Manufacturers and CABs in the EPEAT Registry and are available upon request.

2.2.2

Conformity Requirements and Guidance Materials1

Conformity Guidance Materials contain supplemental information developed by the EPEAT Program that
may help Participating Manufacturers and GEC-approved CABs further understand EPEAT Criteria.
Conformity Guidance Materials Conformity Requirements and Guidance Materials are documents
developed by the EPEAT Program to help Participating Manufacturers and GEC-approved CABs further
understand EPEAT Criteria requirements, provide supplementary information and where necessary,

1Previously, these documents were identified as “Conformity Guidance Materials”. “Conformity GuidanceMaterials” apply to existing EPEAT Criteria and are solely intended to provide guidance and assist stakeholders inunderstanding the conformity assurance requirements. “Conformity Requirements and Guidance Materials”, whilestill providing guidance, also identify further details regarding demonstration of conformance with EPEAT Criteria
and will solely apply to the revised Criteria resulting from the Sustainability Impact Module criteria development
process. During the transition to the revised criteria from the Sustainability Impact Modules, “Conformity GuidanceMaterials” will apply to the existing EPEAT Criteria, while “Conformity Requirements and Guidance” will apply tothe revised Criteria from the Sustainability Impact Modules. Once the revised Criteria have been fully implemented
in the EPEAT Registry, the “Conformity Guidance Materials” will be retired and replaced by “Conformity
Requirements and Guidance Materials” for those product categories adopting the revised Criteria.
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EPEAT Conformity Assurance Systemprovide further details regarding demonstration of conformance with EPEAT Criteria. Conformity
Requirements and Guidance Materials are prepared for all EPEAT Criteria and, for each Criterion,
provide an overview of the EPEAT Criteria requirements, examples of supporting evidence and answers
to frequently asked questions.
The EPEAT Program publishes Conformity Requirements and Guidance Materials for RequiredPriority
Criteria two months before the launch of a new product category and take effect immediately unlessotherwise stated. Within six months after a new category launch or revision, Conformity Requirements
and Guidance Materials are available for all EPEAT Criteria. Necessary revisions are made as
neededmonthly thereafter and become effective at the time of publication. If revisions and/or changes
to the Materials are expected to significantly impact how Participating Manufacturers implement EPEAT
Criteria, the EPEAT Program identifies a later effective date. GEC-approved CABs and Participating
Manufacturers are notified when revisions and/or changes to Conformity Requirements and GuidanceMaterials are made.
Revisions to Conformity Requirements and Guidance Materials may be made for several reasons,
including but not limited to:•Providing links to recently published Outcomes Reports or updated reference materials.

•

Clarifying what constitutes sufficient evidence.

•

Adding information related to a Minor or Major Criteria Revision.

•

Including details on common conformity issues that have arisen in Continuous Monitoring
activities.

•

Addressing requests for clarification from CABs, Participating Manufacturers, or otherstakeholders.

GEC-approved CABs and Participating Manufacturers may submit suggestions or identify corrections or
areas of improvement in the Conformity Requirements and Guidance Materials in writing, at any time,to the EPEAT Program.
Because Conformity Guidance Materials are guidance documents intended only to assist Participating
Manufacturers and GEC-approved CABs further understand conformity assurance requirements, they
become effective at the time of publication. If the guidance or changes to the guidance are expected tosignificantly impact how Participating Manufacturers implement EPEAT Criteria, the EPEAT Program
identifies a later effective date.
The use of Conformity Requirements and Guidance Materials does not guarantee conformance to EPEAT
Criteria. All evidence provided during Documentation Review and Continuous Monitoring activities mustbe evaluated by GEC-approved CABs. Where content in these Materials are specifically identified as“guidance”, EPEAT Criteria take precedence over that content. In the event of a discrepancy between
the Conformity Requirements and Guidance Materials or Conformity Requirements and Guidance andthe applicable EPEAT Criterion, the Criterion takes precedence.

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2.2.3

Technical Questions

EPEAT Conformity Assurance System

The EPEAT Program recommends that Participating Manufacturers and GEC-approved CABs consult the
EPEAT Program for additional guidance in the following situations:•

A GEC-approved CAB is unable to obtain consensus amongst its Qualified Auditors on EPEAT
Criteria and/or the associated conformity assurance requirements.

•

There are differences between the language in EPEAT Criteria and the perceived intent.

•

There is a disagreement between a GEC-approved CAB and its Participating Manufacturer
client on EPEAT Criteria and/or the associated conformity assurance requirements that cannot
be resolved during Documentation Review or Continuous Monitoring activities.

•

A GEC-approved CAB is uncertain that a Participating Manufacturer’s documentation will
demonstrate conformance during Continuous Monitoring activities.

•

A GEC-approved CAB seeks additional guidance or detail on why evidence may or may not be
acceptable.

Due to ongoing interactions with Participating Manufacturer clients, GEC-approved CABs must informthe EPEAT Program of instances where there is conflicting or disparate understanding of EPEAT Criteria
and/or the associated conformity assurance requirements. In these situations, the EPEAT Program
makes the definitive technical interpretation and shares it through discussion at CAB Calibration
Meetings, issuance of a formal Clarification, or updates to Conformity Guidance Materials.
Suppliers may be contracted by or supply multiple Participating Manufacturers who engage different
GEC-approved CABs and may raise questions directly to the EPEAT Program to assist with
documentation preparation. When this occurs, the EPEAT Program will notify all GEC-approved CABs of
the question(s) raised by suppliers and the EPEAT Program’s response during the next scheduled
Calibration Meeting.

2.2.4

Conformity Guidance Group (CGG)

On an as-needed basis, the EPEAT Program seeks technical input and expertise from the Conformity
Guidance Group (CGG) on EPEAT conformity assurance processes, technical requirements in EPEAT
Criteria, and implementation of updated and amended EPEAT Criteria for all product categories. The
Conformity Guidance Group is open to all stakeholders including Participating Manufacturers, GECapproved CABs, and Purchasers. The CGG is not a standing committee and there are no standing
members.
Stakeholders wishing to participate in one or more CGG meetings must inform the EPEAT Program byemail, and they will be added to the CGG distribution list. Because participants must be prepared to
discuss and provide feedback on technical issues, the EPEAT Program requests that participants betechnical experts themselves or have access to relevant technical resources. Depending on the topic
discussed at a meeting, the EPEAT Program may invite individuals with expert knowledge of that topic toparticipate.

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EPEAT Conformity Assurance System

The CGG meets on an as-needed schedule and the EPEAT Program strives to hold these meetings nomore than once per month. The EPEAT Program communicates upcoming CGG meetings to stakeholders
using various GEC communication vehicles (such as newsletters and special announcements). For each
Conformity Guidance Group meeting, the EPEAT Program identifies agenda items, prepares discussion
topic materials, and facilitates discussions. Meetings are not held in person to allow for the broadest
number of participants. To the extent practical, the agenda and materials are provided in advance ofeach meeting to permit meaningful review.
All participants are encouraged to provide their expert advice, ask clarifying questions and be open andconsultative. As such, CGG meetings are governed by Chatham House Rule2. Meeting participants arefree to use information received but are not allowed to reveal the identity or affiliation of speakers. An
anti-trust statement is read at the beginning of each meeting. All participants are expected to abide by
Chatham House Rule and the anti-trust statement.
GEC-approved CABs and Participating Manufacturers may request that a topic be raised for discussion
by the CGG. Requests must be submitted electronically using the Conformity Guidance Group Issue
Paper and Feedback Form (P88), which is available on the EPEAT Registry and upon request.
Participating Manufacturers are strongly encouraged to bring topics forward through their GECapproved CAB. If a request is received directly from a Participating Manufacturer, the EPEAT Program
consults with the Participating Manufacturer’s CAB to ensure consistency in the guidance given to both
Participating Manufacturers and GEC-approved CABs.
The EPEAT Program brings the following topics to the CGG for discussion and feedback:•

Clarifications proposed for release by the EPEAT Program.

•

Requests to examine equivalents to test methods, protocols or other methodologies
specifically referenced in EPEAT Criteria.

For other topics, the EPEAT Program first takes steps to resolve the issue including but not limited to,outreach to technical experts, research into applicable conformity assurance protocols, review ofexisting guidance for other EPEAT product categories for applicability, and consultation with GEC’s
criteria development and maintenance personnel. If the EPEAT Program cannot reach an objective,
reasonable and defensible solution without further technical input, the topic will then be brought to the
Conformity Guidance Group for discussion and feedback. Possible topics include:2•

Language in EPEAT Criteria is not descriptive enough for consistent conformity decisions andmay lead to different decisions being made by different GEC-approved CABs.

•

Test methods, protocols, or other references in EPEAT Criteria no longer exist.

•

Uncertainty in the intention of EPEAT Criteria language.

•

New technical guidance that may contradict guidance previously provided.

https://www.chathamhouse.org/about-us/chatham-house-rule

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Adjudication of disagreements in interpretation of EPEAT Criteria and associated conformity
assurance requirements.

•

Overarching questions or suggestions regarding the EPEAT Conformity Assurance System andrequirements.

•

Transition timeframe for implementation of revised EPEAT Criteria.

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.
The EPEAT Program is solely responsible for making technical interpretations of EPEAT Criteria,
determining the necessary conformity assurance requirements for assessing conformance to EPEAT
Criteria, and adjudicating disagreements in the interpretation of Criteria and the associated conformity
assurance requirements. Careful consideration is given to the specific language used in EPEAT Criteria.

2.2.5

Conformity Assurance Where Equivalent Regulatory Requirements Exist

If there are regulations in effect in a location of use (country) where a product is identified as being
EPEAT-registered and those regulations address the requirements of an EPEAT Required Criterion,
Participating Manufacturers may provide a signed attestation to their GEC-approved CAB as the
supporting evidence for that Criterion in that specific location of use (country). This provision is only
applicable to specific EPEAT Required Criteria and location of use (country) combinations, which will beidentified by the EPEAT Program and made available to CABs and Participating Manufacturers on the
EPEAT Registry (and upon request) after it has been developed.
Participating Manufacturers must use one of the Attestation Templates provided by the EPEAT Program,which will be available on the EPEAT Registry and upon request. The EPEAT Program will develop andmaintain an Acceptable List of the Required Criteria and specific locations of use (countries) where thisattestation may be used as evidence. An attestation may only be used for those locations of use(countries) identified by the EPEAT Program. If a product is EPEAT-registered in other countries that are
not on the list of countries identified by the EPEAT Program, the Participating Manufacturer cannot use
the attestation for the Required Criterion in those countries and must provide documentation todemonstrate conformance to the Criterion.
When finalized, additional information and obligations associated with the use of an attestation for both
CABs and Participating Manufacturers will also be made available to CABs and Participating
Manufacturers on the EPEAT Registry and available to other stakeholders upon request.
The EPEAT Program may update the Acceptable List of Required Criteria and specific countries on an asneeded basis. Each Criterion is assessed on a country-by-country basis. Participating Manufacturers and
CABs may request that specific Required Criteria and countries be added; however, the EPEAT Program
makes the final determination as to which Required Criteria and countries are included, based on legal
advice.

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Approval of Conformity Assurance Bodies (CABs)

3.0 Approval of Conformity Assurance Bodies (CABs)
CABs play a key role in the EPEAT Program and are the gateway through which products are approved as
being EPEAT-registered. GEC establishes CAB Eligibility Requirements and approves and oversees theseorganizations, which provide conformity assurance services for the EPEAT Program. To become a GECapproved CAB, an organization progresses through a series of stages – applicant status, provisional
status, approved status, and mentored work phase.

CAB Eligibility Requirements
The following CAB Eligibility Requirements must be met initially and fulfilled on an ongoing basis for an
organization to maintain its status as a GEC-approved CAB, in addition to all requirements in EPEAT
Policy Manual (P65) and P66 EPEAT Conformity Assurance Implementation Manual (P66).
•••

Operate EPEAT-related conformity assurance services under a valid accreditation to one of thefollowing:o

ISO/IEC 17020 Conformity assessment – Requirements for the operation of various typesof bodies performing inspection from an accreditation body that is an ILAC Member andsignatory to the ILAC Mutual Recognition Agreement (MRA).

o

ISO/IEC 17065 Conformity assessment – Requirements for bodies certifying products,
processes and services from an accreditation body that is an IAF Member and signatory
to the IAF Multilateral Recognition Arrangement (MLA). This accreditation is required
for CABs offering EPEAT-related conformity assurance services under the Certification
Pathway.

Incorporate additional quality management system elements under the ISO/IEC 17020 or
ISO/IEC 17065 accreditation, as per Section 5.1, including:o

Execution of a legal agreement with Participating Manufacturer clients for the provisionof conformity assurance services for the EPEAT Program, which requires adherence toapplicable EPEAT Program policies and procedures.

oFormal processes or procedures for performing Documentation Review, implementing
Continuous Monitoring, and responding to Participating Manufacturer client andexternal stakeholder complaints.

Maintain at least two Qualified Auditors for each product category in which they offer
conformity assurance services for the EPEAT Program, as per Section 43.

3

When the revised Criteria from the Sustainability Impact Module criteria development process come into effect,
all impact area training modules, along with product-specific modules, where applicable, must be passed for an
Auditor to be considered qualified in those product categories adopting the revised Criteria.
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Approval of Conformity Assurance Bodies (CABs)•

Have in place a policy or procedure, which identifies that customer service for its Participating
Manufacturer clients will be measured and improved. Section 5.3 provides further information
on CAB customer service requirements.

To become a GEC-approved CAB, organizations must first submit an application and become an
Applicant CAB. Once the application is reviewed and approved, the CAB is granted Provisional CAB
status. A Provisional CAB must meet the CAB Eligibility Requirements, successfully complete an Initial
EPEAT Audit, and have personnel pass Initial EPEAT Auditor training requirements before being granted
status as a GEC-approved CAB.

Applicant Status
An organization that intends to become a CAB must electronically submit a CAB Application Form (P40)
to GEC. An organization can only submit an application once every 12-month period. After theapplication and all supporting documentation have been received by GEC, the organization is consideredan Applicant CAB.
GEC may ask clarifying questions and/or request an interview with the Applicant CAB as it evaluates theapplication. GEC to seeks to maintain a network of approved CABs to meet Participating Manufacturer
needs globally while also ensuring sufficient EPEAT Program capacity exists to support and oversee theentire CAB network. When reviewing CAB applications, GEC considers a variety of factors including
technical capabilities of the organization, as well as the diverse needs of Participating Manufacturers
regarding linguistic capabilities and the ability to provide conformity assurance services in regions of theworld required by Participating Manufacturers. If GEC determines that the applicant meets these needs
and the application and supporting documentation sufficiently demonstrates the organization’s ability
to perform conformity assurance activities, the organization may be granted Provisional CAB status.
GEC is solely responsible for the review and approval of all applications to become a GEC-approved CAB.

Provisional Status
A Provisional CAB must execute GEC Conformity Assurance Body Agreement (P33). Once executed,
Provisional CABs may begin soliciting business for EPEAT conformity assurance services but may notprovide these services until becoming a GEC-approved CAB. A Provisional CAB has 12-months to prove itmeets the CAB Eligibility Requirements and become a GEC-approved CAB. An organization must re-apply
and submit a new application if it is unable to fulfill the requirements within this 12-month period,
although GEC reserves the right not to accept an application from an organization that is re-applying.
Reasons that GEC may not accept a second application may include failure to meet CAB Eligibility
Requirements, unresponsiveness to EPEAT requests/inquiries, or because alternative CABs wereapproved in the interim to meet the needs of the CAB network (e.g., addressing specific technicalrequirements or number of existing GEC-approved CABs).

3.3.1

Qualifying Auditors

GEC-approved CABs must maintain at least two Qualified Auditors for each product category in which
they offer conformity assurance services for the EPEAT Program. Therefore, Provisional CABs must

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ensure that at least two individuals undergo Initial EPEAT Auditor Training and pass the associatedexams (see Section 4.1). Provisional CABs must pursue qualifications for Auditors in at least one productcategory; qualifications for additional product categories may be added at a later date. Only Qualified
Auditors can conduct EPEAT conformity assurance activities including performing Documentation
Review, removing Documentation Review Requirements, and implementing Continuous Monitoring
activities. Additionally, Qualified Auditors can only conduct EPEAT conformity assurance activities for
those EPEAT product categories for which they have been qualified4.

3.3.2

Supporting Documentation

Provisional CABs must submit to GEC all procedures, policies, and valid accreditation certificates related
to the provision of conformity assurance services for the EPEAT Program. These documents must
demonstrate that the additional quality management system elements outlined in Section 5.1 havebeen incorporated for the conformity assurance pathways the CAB will be using. GEC reviews thesubmitted documentation and may ask clarifying questions as needed prior to the Initial EPEAT Audit of
the Provisional CAB.

3.3.3

Initial EPEAT Audit

During Initial EPEAT Audits of Provisional CABs, Provisional CABs are responsible for:•

Coordinating with GEC to plan the Initial EPEAT Audit.

•

Making available the necessary personnel, documentation, and records.

•

Providing a knowledgeable “audit guide” who is fluent in English to act as a liaison and help
GEC staff obtain and interpret the necessary audit evidence.

•

Responding to all questions and requests during the audit process.

During the audit process, GEC evaluates the documentation provided to determine if:•

CAB Eligibility Requirements are being met.

•

The quality management system elements as per Section 5.1 are incorporated into the CAB’s
management system.

•

Procedures adequately reflect the conformity assurance pathway(s) for which it is seeking
approval as per requirements in Sections 6 and 7, including developing Initial Documentation
Review plans and selecting products, collecting, and evaluating evidence, removing
Documentation Review requirements, implementing Continuous Monitoring, and performing
Annual Renewals.

4

When the revised Criteria from the Sustainability Impact Module criteria development process come into effect,
all impact area training modules, along with product-specific modules, where applicable, must be passed for an
Auditor to be considered qualified in those product categories adopting the revised Criteria.

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Approval of Conformity Assurance Bodies (CABs)

GEC provides the Provisional CAB with an audit report summarizing the activities conducted and, whereapplicable, opportunities for improvement and nonconformances. Audit reports are provided
electronically. Within 30 calendar days, Provisional CABs must make corrections for identified
nonconformances and develop a corrective action plan to prevent reoccurrence5. Any corrective actionplans must be fully implemented prior to GEC granting the organization GEC-approved CAB status.

Approved Status
Upon fulfillment of the requirements in Section 3.3, the organization is identified as a GEC-approved
CAB for specific product categories and for one or more conformity assurance pathways. Onceapproved, the organization may provide conformity assurance services for Participating Manufacturer
clients. CABs are also required to pay an annual CAB Participation Fee to GEC to maintain their status asan approved conformity assurance body for the EPEAT Program.
CABs may become approved to provide conformity assurance services for the EPEAT Program for one ormore product categories, contingent upon the qualifications of the Auditors performing the conformity
assurance activities. A GEC-approved CAB may expand the product categories it is able to provide
conformity assurance services for by having at least two Qualified Auditors complete Product Category
Modules and pass the associated exams for each new product category (see Section 4.1). GEC-approved
CABs may also choose to become approved for an additional conformity assurance pathway and theaudit for this addition shall occur during the next scheduled Annual EPEAT Audit for the CAB.
Information regarding which product categories each CAB is approved to provide EPEAT-related
conformity assurance services for is made publicly available on the GEC website and/or the EPEAT
Registry.

CAB Mentored Work Phase
GEC supports and oversees newly approved CABs as they perform Documentation Review of their initial
Participating Manufacturer clients. This CAB Mentored Work Phase is designed to ensure that CABs:•

Understand the EPEAT Conformity Assurance System, nuances in the EPEAT Criteria, andconformity assurance requirements for the product categories in which they are approved.

•

Seek appropriate evidence of conformity from their Participating Manufacturer clients.

•

Appropriately evaluate that the evidence provided is consistent with EPEAT publishedguidance and the requirements in EPEAT Conformity Assurance Implementation Manual (P66).

•

Make appropriate judgments of conformity before products become EPEAT-registered.

5“Corrections” are the immediate actions that are taken by the CAB to correct nonconformances. Corrections
must be completed within the 30-calendar day period. “Corrective action plans” are the actions and timelines that
the CAB develops to address and eliminate the root cause(s) of a nonconformance so as to prevent reoccurrence.
The Corrective action plan must be developed in the 30-calendar day period; however, implementation of the plan
may take longer.
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Understand their responsibilities for approving products and selected EPEAT Criteria.

•

Can support their Participating Manufacturer clients.

During the CAB Mentored Work Phase, GEC evaluates and approves the CAB’s conformity decisions
made in the Initial Documentation Review for its initial Participating Manufacturer clients, including therationale for accepting or rejecting the evidence provided by the Participating Manufacturer. Where
applicable, the EPEAT Program may also review the actions and results of a CAB’s Continuous
Monitoring activities (Continuous Monitoring Investigations and Annual Renewals) as part of CAB
Mentored Work Phase. A CAB’s decisions on all EPEAT Required Criteria and 50% of the EPEAT Optional
Criteria in a product category are reviewed6.
A GEC-approved CAB may remain in the CAB Mentored Work Phase for some EPEAT Criteria, while able
to make conformity decisions independently for others because the CAB Mentored Work Phase iscompleted on a Criterion-by-Criterion basis.
If the CAB has Participating Manufacturers undergoing conformity assurance in more than one productcategory, GEC selects a cross section of EPEAT Criteria to review among the multiple product categories,
as opposed to reviewing every Criteria in every product category. In these cases, GEC ensures the EPEAT
Criteria selected for review across the product categories requires the CAB to demonstrate proficiency
in all methods of conformity assurance.
CABs cannot approve a selected EPEAT Criterion or remove the Documentation Review requirement for
the Criterion while still in the Mentored Work Phase for that Criterion. CABs are also unable to activate
products while in the Mentored Work Phase. If the EPEAT Program agrees with a CAB’s determinationthat a Participating Manufacturer has submitted sufficient evidence to demonstrate conformance andhas completed the Initial Documentation Review process, the EPEAT Program will activate the products
for the Participating Manufacturer, even if the CAB is still in the Mentored Work Phase. Products
activated by the EPEAT Program during this Phase are subject to Continuous Monitoring activities (asoutlined in Section 7).
If a CAB is unable to demonstrate an adequate understanding of specific EPEAT Criteria, it remains in
Mentored Work Phase for those Criteria until able to do so and is still subject to evaluation of its
decisions for the Criteria. This evaluation will involve reviewing documentation submitted by asubsequent Participating Manufacturer.

6

When the revised Criteria from the Sustainability Impact Module criteria development process come into effect,
50% of EPEAT Optional Criteria across those product categories adopting the revised criteria will be reviewed. For
those product categories not initially adopting the revised Criteria, 50% of the Optional Criteria for those productcategories will need to be reviewed.
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4.0 Qualified Auditor Proficiency and Training

Qualified Auditor Proficiency and Training

Initial EPEAT Training Requirements
GEC-approved CABs must maintain at least two Qualified Auditors for each product category in which it
provides conformity assurance services for the EPEAT Program. Auditors can only conduct EPEAT
conformity assurance activities (including performing Documentation Review, removing Documentation
Review Requirements, and implementing Continuous Monitoring activities) for those EPEAT productcategories and/or Criteria for which they have been qualified7.
To become qualified, Auditors must complete Initial EPEAT Auditor Training provided by the EPEAT
Program and pass the associated exams with a score of 75% or greater. Individuals completing any
EPEAT auditor exams may refer to EPEAT Criteria, Conformity Guidance Materials, and accessinformation available on the Internet but cannot consult with or seek guidance from other individuals.
The Initial EPEAT Auditor Training is comprised of an Overview Module and individual modules for eachproduct category and/or individual modules for each Sustainability Impact Area. Each module has an
associated exam. Auditors must complete and pass the Overview Module, at least one Product Category
Module and/or, where applicable, all modules for the Sustainability Impact Areas. and at least one
Product Category Module
Overview Module

Product Category Specific Modules

Sustainability Impact Area
Modules

The overview module provides
an overview of the EPEAT
Program, the productcategories, requirements of
GEC-approved CABs, the EPEAT
Conformity Assurance System,and the Documentation Review
and Continuous Monitoringprocesses. The exam for theoverview module evaluates the
Auditor’s knowledge of the
EPEAT Program, EPEAT’s
Conformity Assurance System
and requirements ofconformity assurance activities.

For product categories NOT adopting the revised
Criteria from the Sustainability Impact Modules, eEach
product category specific module provides details on
the EPEAT Criteria for that product category. For
product categories that ARE adopting the revised
Criteria from the Sustainability Impact Modules, eachproduct category specific module also provides details
on specific criteria, where applicable, such as productenergy efficiency and consumables that are unique tothat product category.
In both cases, the training modules address
conformity assurance requirements that may be
specific to those Criteria, existing Clarifications,guidance for making appropriate conformity
decisions, and expectations for details that must be
provided in the rationale for these decisions. The
exams for product category modules evaluate an
Auditor’s technical skills and applied knowledge of
EPEAT Criteria in that category.

Each Sustainability Impact
Module training reviews theCriteria specific to that impact
area and provides informationon the conformity assurance
requirements that may be
specific to those Criteria,
existing Clarifications, guidance
for making appropriate
conformity decisions, andexpectations for details thatmust be provided in therationale for these decisions.
The exams evaluate an
Auditor’s technical skills andapplied knowledge of EPEAT
Criteria in that Impact Module.

7

When the revised Criteria from the Sustainability Impact Module criteria development process come into effect,
all impact area training modules, along with product-specific modules, where applicable, must be passed for an
Auditor to be considered qualified in those product categories adopting the revised Criteria.
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Qualified Auditor Proficiency and Training

When the EPEAT Program launches a new product category, already Qqualified Auditors must take thetraining for the Product Category Module and if applicable, the Sustainability Impact Area Modules, andpass the associated exam(s) with a score of 75% or greater for that new category to be able to performthe associated conformity assurance activities.
If an Auditor does not achieve a passing score for any exam, GEC provides feedback on aspects of the
training and module that the Auditor should re-examine. The Auditor may revise the exam and resubmit
it up to two times. Any Auditor that has retaken the same exam three times and not received a score of
75% or greater must retake the training module and a new exam will be administered.
Initial EPEAT Auditor Training is available online but can also be arranged to be held in person uponrequest from a Provisional CAB or GEC-approved CAB. Participating Manufacturers are not required tocomplete the Initial EPEAT Auditor Training but are welcome to view any training modules. All Initial
EPEAT Auditor Training is subject to fees.

Ongoing Training and Other Requirements
To maintain their qualifications, Auditors must:•

Maintain employment on either a full-time, part-time, or contractual basis with a GECapproved CAB.

•

Attend training sessions on Minor Criteria Revisions to EPEAT Criteria for the productcategories for which they have been qualified, when such training is identified as necessary by
the EPEAT Program.

•

Attend training sessions on Major Criteria or Product Category Revisions to EPEAT Criteria forthe product categories for which they are qualified and pass the associated exam with a scoreof 75% or greater within the timeframe specified by the EPEAT Program.

•

Attend the Annual EPEAT Auditor Refresher Training course.

•

Pass the Annual EPEAT Auditor Proficiency Exam with a score of 75% or higher within thetimeframe specified by the EPEAT Program.

•

Attend all Continuous Monitoring training for the product categories for which they have been
qualified or confirm that a recording of these training sessions and/or the presentations wereviewed.

A Qualified Auditor may move from employment with one GEC-approved CAB to a different GECapproved CAB. However, if more than 12 months have lapsed in the interim period, the Auditor must retake the Initial Auditor Training, including the Overview Module and Product Category Modules, andpass the associated exams. GEC may make exceptions for Auditors that are absent due to illness,parental leave, sabbaticals, or other duties outside of EPEAT conformity assurance activities.
If an individual loses his/her EPEAT Auditor qualifications for any reason, GEC will notify the CAB. Uponthis notification, the Auditor can no longer conduct any EPEAT-related conformity assurance activities
and existing work must be re-assigned to a Qualified individual.

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4.2.1

Annual EPEAT Auditor Refresher Training

Qualified Auditor Proficiency and Training

Annual EPEAT Auditor Refresher Training includes interactive exercises to provide more immediate
feedback and summarizes new information from the previous 12-month period. This includes but is not
limited to:•Technical questions, responses, interpretations, and rationale behind decisions.

•

Conformity assurance related policy and procedural changes.

•

Additional EPEAT Program policy and procedural changes.

•

Common misunderstandings such as inappropriate selection of EPEAT Criteria, conformity
assurance requirements for specific EPEAT Criteria, and underlying reasons fornonconformances.

•

Investigation Report writing best practices and lessons learned.

If unable to attend the training at the time it is held, Auditors must watch the recording and confirm inwriting to the EPEAT Program that this is complete. In advance of the training, GEC-approved CABs must
notify the EPEAT Program of any Auditors that will be absent (e.g., due to illness, parental leave,
sabbaticals, or other duties outside of EPEAT conformity assurance activities), obtain EPEAT Programapproval for the absence and arrange for them to view the recording upon their return. 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 was continuous (e.g., a two-year parental leave).
Newly Qualified Auditors that complete the Initial EPEAT Auditor Training after the last Annual EPEAT
Auditor Refresher Training must attend the next scheduled annual training but are not required tocomplete any previous annual trainings that occurred prior to them becoming Qualified Auditors.

4.2.2

Annual EPEAT Auditor Proficiency ExamWithin three months of completing the Annual EPEAT Auditor Refresher Training, Qualified Auditors
must take the Annual EPEAT Auditor Proficiency Exam and pass with a score of 75% or greater. The
exam focuses on applied knowledge, looking at acceptability of evidence examples, conformity
assurance related policies and processes (in particular, changes made over the previous 12 months), andtechnical responses to questions. The Annual EPEAT Auditor Proficiency Exam also includes a section on
articulating the rationale for conformity decisions. The exam is designed to evaluate an auditor’s
technical skills and applied knowledge of the EPEAT Program. The Annual EPEAT Auditor Proficiency
Exam is not administered in person to enable access by Auditors in all geographic locations.
If an Auditor does not achieve a passing score on the Annual EPEAT Auditor Proficiency Exam, the EPEAT
Program provides feedback on aspects of the training that the Auditor should re-examine. The Auditor
may revise the exam and resubmit it up to two times. Any Auditor that has retaken the Annual EPEAT
Auditor Proficiency Exam three times and not received a score of 75% or greater must re-qualify as a
Qualified Auditor by repeating and passing the Initial Auditor Training again. (On a case-by-case basis,

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Qualified Auditor Proficiency and Training

the EPEAT Program may determine that specialized and focused training is required in place of repeating
the Initial Auditor Training.) Upon successful completion of Initial EPEAT Auditor Training, a new Annual
EPEAT Auditor Proficiency Exam will be administered and a score of 75% or greater must be achieved. In
these cases, Auditors are not permitted to conduct EPEAT conformity assurance activities until both theInitial Auditor Training and Annual EPEAT Auditor Proficiency exams are successfully passed.
In advance of the exam, GEC-approved CABs must notify the EPEAT Program of any Qualified Auditorsthat are unable to take the exam in the allotted timeframe (e.g., due to illness, parental leave,
sabbaticals, or other duties outside of EPEAT conformity assurance activities), obtain EPEAT Programapproval for taking the exam at a later date, and arrange for them take the exam upon their return.
Auditors returning from a leave 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, aslong as the leave was continuous (e.g., a two-year parental leave).
Newly Qualified Auditors that complete the Initial EPEAT Auditor Training and Exam(s) after the last
Annual EPEAT Auditor Refresher Training must successfully pass the next scheduled annual exam but are
not required to pass any exams that occurred prior to them becoming Qualified Auditors.

4.2.3

Continuous Monitoring Training

To ensure consistent and continued understanding of EPEAT Criteria and the associated conformity
assurance requirements, GEC conducts Continuous Monitoring Training prior to the launch of allContinuous Monitoring Rounds for Level 0, Level 1 and Level 2 Investigations. These training sessions
identify all aspects of the Criteria that must be addressed, explain what details must be documented in
Investigation Reports, provide examples of acceptable and unacceptable evidence, and highlightcommon mistakes and misunderstandings pertaining to the Criteria being investigated. GEC expects that
all Qualified Auditors prepare in advance for the training and come prepared with questions.
The Continuous Monitoring Training sessions are intended to be an opportunity for dialogue between
the EPEAT Program and GEC-approved CABs and provide Qualified Auditors an opportunity to sharespecific examples of issues they are encountering with their Participating Manufacturer clients andreceive feedback on any questions they have. To encourage more open discussion and maintainconfidentiality, GEC conducts an individual session for each GEC-approved CAB. These individual
sessions are recorded for additional viewing by the CAB’s Qualified Auditors. At least one CAB
representative must attend the training. If Auditors who are participating in the Continuous Monitoring
Round are unable to attend the training at the time it is held, they must watch the recording andconfirm in writing to the CAB that this is complete. The same materials are covered in all individual CAB
training sessions. Auditors are only required to attend the training or review the recordings for the
specific Criteria they are investigating in the Continuous Monitoring Round. For Level 2 Rounds, at least
one CAB representative must attend the training.
The EPEAT Program may occasionally provide optional training for Participating Manufacturers to clarify
EPEAT Criteria and outline evidence expectations to help Participating Manufacturers prepare forContinuous Monitoring. All Participating Manufacturers will be notified using various GEC

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communication vehicles (such as newsletters and special announcements) and have the opportunity toattend these trainings.

Qualified Auditor Proficiency and Training

4.2.4

Calibration Meetings

On a monthly basis, the EPEAT Program holds Calibration Meetings for Provisional and GEC-approved
CABs using an online platform. When the EPEAT Program releases Major Criteria Revisions, ProductCategory Revisions and/or adds new product categories, the frequency of Calibration Meetings may
increase. The goals of the meetings are to:•Promote uniform understanding of EPEAT Criteria and consistent application of conformity
assurance requirements.

•

Disseminate and receive feedback on EPEAT Program policy and procedural changes.

•

Encourage open discussion and sharing of conformity assurance questions and knowledge.

Calibration Meetings may be used to answer technical questions from GEC-approved CABs, highlightupcoming changes to EPEAT Program policies or procedures, and provide programmatic updates on
Criteria development and continuous maintenance activities.
Calibration Meetings are governed by Chatham House Rule8 and an anti-trust statement, both of which
all participants are expected to abide by. Meeting participants are free to use information received but
are not allowed to reveal the identity or affiliation of speakers.
Calibration Meeting materials and an index of the topics addressed at each meeting are made available
to all Provisional and GEC-approved CABs. These materials may be used by CABs to inform theirconformity assurance activities but may not be disseminated to Participating Manufacturers as official
EPEAT Program guidance. Any resulting changes to conformity assurance processes, policies orinterpretations are available to Participating Manufacturers in the Conformity Guidance Materials
At least one representative from each GEC-approved CAB must attend each Calibration Meeting.
Although not required to do so, Provisional CABs are strongly encouraged to attend all Calibration
Meetings. The CAB representative who attends each meeting may change due to vacation and holiday
schedules, illness, job description changes and CAB workloads. The EPEAT Program expects CAB
representatives to actively participate in Calibration Meetings to the best of their ability, providing
feedback and engaging in constructive dialogue where appropriate. Meeting attendees are also required
to disseminate information presented and discussed during the meeting to the CAB’s Qualified Auditors.
If the frequency of meetings increases, the EPEAT Program will reassess attendance requirements andmay hold meetings in multiple time zones to better accommodate Provisional and GEC-approved CABs.
Any changes will be communicated in writing to CABs.

8

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5.0 Ongoing Requirements of CABs
Accreditation

Ongoing Requirements of CABs

As per the Eligibility Requirements, Provisional and GEC-approved CABs must maintain valid
accreditations to ISO/IEC 17020 and/or ISO/IEC 17065. GEC requires that the quality management
systems under these accreditations incorporate the elements identified in Table 1 below.
GEC does not expect that every detail in EPEAT Conformity Assurance Implementation Manual (P66)
appears in a GEC-approved CAB’s policies, procedures and/or other quality management system
documentation. It may be appropriate for GEC-approved CABs to refer to EPEAT Conformity Assurance
Implementation Manual (P66) for specific requirements, for example, when referring to timelines anddeadlines of conformity assurance activities or definitions.
For example, instead of identifying the timeframes of Continuous Monitoring Rounds, a CAB’s
documentation may state “… as per the timeframes identified in EPEAT Conformity Assurance
Implementation Manual (P66).” However, the CAB must have specific procedures in place thatspecifically identify how their personnel must conduct Continuous Monitoring activities.
CABs must have procedures in place for performing Documentation Review and implementing
Continuous Monitoring, including at minimum, an overview of both processes. CAB’s procedures must
include CAB specific processes. Each CAB will determine their own processes, however, examples of CAB
specific processes include, but are not limited to, responsibilities of team members, assigning Auditors,
requirements for saving documentation (e.g., file locations), as well as identification of product family
and/or sampling procedures.
Table 1: EPEAT Requirements for CAB Quality Management Systems
Management System
and Accreditation
Scope

If accredited to ISO/IEC 17020, the CAB must be either a Type A or Type C inspection body and meet
the applicable requirements in Annex A (Independence requirements for inspection bodies) in
ISO/IEC 17020. If Type C, the CAB shall not be part of a company that has EPEAT-registeredproducts, and the CAB shall be or be part of the legal entity that signs the contractual agreement
between the CAB and GEC.
If accredited to ISO/IEC 17065, the CAB shall follow Option A as outlined in Section 8 in ISO/IEC
17065 (Management system requirements). ISO/IEC 17065 requires that certification
documentation must be provided that conveys the term or expiry date of certification. For the
EPEAT Program, this period of validity is three years. The EPEAT mark cannot be used on
certification documentation, including certificates and certification reports.
The EPEAT Program is not required to be included in the CAB’s accreditation scope for either ISO/IEC
17020 or ISO/IEC 17065.

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Table 1: EPEAT Requirements for CAB Quality Management Systems

Ongoing Requirements of CABs

Organization

The CAB’s quality management system must identify all personnel positions that:•

Perform Documentation Review, evaluate and approve conformity decisions, and review and/or
approve changes to Documentation Review status.

•

Implement, review and/or approve Continuous Monitoring activities and recommendations.

•Manage conformity assurance services for the EPEAT Program and/or the personnel
implementing these services.

Confidentiality

The CAB shall meet the confidentiality requirements in the contractual agreement between the CAB
and GEC. These requirements allow the CAB to share with the EPEAT Program information collectedfrom Participating Manufacturers during the provision of conformity assurance services for the
EPEAT Program but prevent other disclosures.

Contractual
Agreements

The CAB must execute a legal agreement with Participating Manufacturer clients for the provision ofconformity assurance services for the EPEAT Program. This contract must include a clause that
requires adherence to applicable EPEAT Program policies and procedures.

Management
Review

The CAB’s conformity assurance activities for the EPEAT Program must be included as part of the
CAB’s management review.

Internal Audits

The CAB’s conformity assurance activities for the EPEAT Program must be included as part of the
CAB’s internal audit.

Complaints

Process
Requirements

The CAB must have a process for responding to complaints from Participating Manufacturer clientsand external stakeholders, and to appeals from Participating Manufacturer clients on conformity
decisions and recommendations. The CAB must also have a process for passing on complaints
regarding EPEAT-registered products not meeting EPEAT Criteria to the EPEAT Program.
The CAB must have specific procedures in place for performing Documentation Review andimplementing Continuous Monitoring. These procedures must reflect the conformity assurance
pathways for which it is approved as per requirements in Sections 6 and 7 of EPEAT Conformity
Assurance Implementation Manual (P66).
If offering conformity assurance services via the Certification Pathway, the CAB must maintain aninternal list of products and the EPEAT Criteria met by each product using this Pathway. The EPEAT
Registry shall serve as the published directory of products assessed via this Pathway.

Records

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The CAB must retain records related to conformity assurance for the EPEAT Program for a minimumof three years after the contract with a Participating Manufacturer ends, including records
associated with the following:•

Documentation Review including all evidence and the rationale supporting decisions.

•

Evaluation of a Participating Manufacturer’s competence when demonstrating conformity.

•

Continuous Monitoring activities including all evidence, the review and approval processes, andfor laboratory evaluation of products, the visual/photographic record of the evaluation.

•

Qualification of personnel involved in providing conformity assurance services for the EPEAT
Program (records of completion EPEAT Auditor training requirements), which must be retained
for at least three years after the end of employment.

•

Other business records (contracts or agreements with Participating Manufacturer clients)
associated with provision of conformity assurance services for the EPEAT Program, which must
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Table 1: EPEAT Requirements for CAB Quality Management Systems
Personnel andResource
Requirements

All CAB personnel responsible for managing or implementing conformity assurance activities for the
EPEAT Program must maintain Auditor qualifications as per Section 4 of EPEAT Conformity
Assurance Implementation Manual (P66).
Due to the technical nature of EPEAT Criteria, the CAB must have personnel competence
requirements for performing conformity assurance activities for the EPEAT Program that includes
education, training, technical knowledge, skills, and experience.

Ongoing Requirements of CABs

The CAB must ensure all personnel performing conformity assurance work for the EPEAT Program
are provided with information discussed at Calibration Meetings and relevant Clarifications andConformity Guidance Materials published by the EPEAT Program.
Any laboratory evaluation of products for Continuous Monitoring must be performed by alaboratory with valid accreditation to ISO/IEC 17025 General requirements for the competence oftesting and calibration laboratories from a body that is an ILAC Member and signatory to the ILAC
Mutual Recognition Arrangement (ILAC MRA).
•CABs must confirm that the evaluation methods are covered by the laboratory’s accreditation
scope or, for non-standard methods of evaluation, by other mechanisms or best practices to
produce accurate and reliable results.

•

The laboratory must make best efforts to retain, appropriately identify and protect additional
samples from a part or component to enable re-testing in the event the original samples aremisplaced or there is a dispute or question about the evaluation results.

•

The laboratory must retain the disassembled product, including packaging, for at least six
months following filing of the related Investigation Report(s).

•The laboratory must retain the visual record of the disassembly process and results for at least
three years following filing of the related Investigation Report(s).

Annual EPEAT Audit of CAB
5.2.1

Audit Methodology

On an annual basis, GEC audits each GEC-approved CAB. If possible and unless other mutuallyacceptable arrangements are made, the first Annual Audit shall be on-site at the CAB’s primary location.
Additional audits may be on-site or performed remotely at GEC’s sole discretion. Annual EPEAT Audits of
CABs may be subject to fees.
GEC-approved CABs are responsible for:•

Coordinating with GEC to plan the Annual EPEAT Audit.

•

Making available the necessary personnel, documentation, and records.

•

Providing a knowledgeable “audit guide” who is fluent in English to act as a liaison and help
GEC staff obtain and interpret the necessary audit evidence.

•

Responding to all questions and requests during the audit process.

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On an annual basis, GEC evaluates the following during the audit process:•Documentation Review decisions and where applicable, and Annual Renewal decisions for theconformity assurance pathway(s) and product category(ies) for which the CAB is approved.
o Where applicable, assessment of Documentation Review will include rebranding of EPEATregistered products (as per Section 6.4), and nonconformances identified outside ofContinuous Monitoring (as per Section 6.5).

Ongoing Requirements of CABso

To ensure consistency of EPEAT Audits across all CABs, conformity decisions for four
Criteria for each product category the CAB has Participating Manufacturer clients will be
reviewed during each audit. The assessment may consist of a combination of Criteria
reviewed by the CAB during the last year, or activities from prior years.

•

Opportunities for improvement, nonconformances and implementation of corrections andcorrective action plans from previous EPEAT Audits.

•

Implementation of new EPEAT Program policies or requirements that became effective in theprevious 12-month period.

•

Review of annual Performance Metrics identified in Section 5.3.

•

If applicable, documentation supporting the addition of a new conformity assurance pathway.

•

If applicable, the CAB’s follow-up on Participating Manufacturer clients’ corrective action plans
for similarly affected products, which were a result of nonconformances in Continuous
Monitoring Investigations.

•If applicable, the CAB’s follow-up on nonconformances from previous annual audits related toconformity decisions (as per Section 5.2.2.1).

•

If applicable, activities conducted when accepting a new Participating Manufacturer client thathas transitioned from a different GEC-approved CAB.

In addition to the items identified above, on a bi-annual basis the Annual EPEAT Audit of the CAB shall
include GEC’s evaluation of the CAB’s implementation of and supporting records for quality
management system elements as per Section 5.1.
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.

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5.2.2

Nonconformances and Corrective Actions

Ongoing Requirements of CABs

Within 30 calendar days of receiving the audit report, GEC-approved CABs must make corrections for
identified nonconformances, provide evidence of these corrections, and develop a corrective action plan
to prevent re-occurrence, and submit this information to GEC9. Within 15 calendar days of receipt, the
EPEAT Program communicates to the CAB the acceptability of the corrections and proposed corrective
action plan. For nonconformances related to conformity decisions made during Documentation Review
or Annual Renewal processes, see section 5.2.2.1 below for details on the requirements and timeframe
to provide corrections and supporting evidence, and corrective action plans.
Depending on the nature of the nonconformance(s), CABs may be required to submit evidence of thecorrection, but the EPEAT Program typically evaluates evidence of correction at the next Annual EPEAT
Audit. The exception is nonconformances related to conformity decisions made during Documentation
Review processes, as identified below in Section 5.2.2.1. CABs are responsible for implementation andcompletion of all approved corrective action plans and the EPEAT Program may follow up with CABs to
track progress and ensure completion at the next annual audit.
If an Annual EPEAT Audit of CAB indicates that a CAB is not meeting multiple requirements in EPEAT
Policy Manual (P65) and/or EPEAT Conformity Assurance Manual (P66), the EPEAT Program may developa Performance Improvement Assistance Plan (see Section 5.6.1).
5.2.2.1

Nonconformances Related to Conformity Decisions

GEC-approved CABs may receive nonconformances related to conformity decisions made during
Documentation Review or Annual Renewals, which may subsequently result in a Participating
Manufacturer client being found nonconformant with one or more EPEAT Criteria. CABs must take thefollowing actions where nonconformances related to conformity decisions are identified for this:(1)

If applicable, provide additional documentation to demonstrate their original conformity
decision is accurate. This may occur when the GEC-approved CAB already had the evidence but
was not able to present it during the EPEAT Annual Audit.
Within 30 calendar days of receiving the audit report, the GEC-approved CAB may submit
evidence to support the original conformity decision (which was not presented during theAnnual EPEAT Audit). GEC will review this evidence to determine if it demonstrates theParticipating Manufacturer is conformant with the Criteria.

(2)

If unable to provide additional documentation as per item (1) above or if GEC determines theevidence does not support Participating Manufacturer conformance, collect and review
additional evidence from the Participating Manufacturer to demonstrate conformance with
the Criterion.

9“Corrections” are the immediate actions that must be taken by the CAB to correct nonconformances. Corrections
must be completed within the 30-day period. “Corrective action plans” are the actions and timelines that the CAB
must develop to address and eliminate the root cause(s) of a nonconformance so as to prevent reoccurrence. The
Corrective action plan must be developed in the 30-day period; however, implementation of the plan may takelonger.
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Within 30 calendar days of receiving the audit report, the GEC-approved CAB must notify theParticipating Manufacturer within three business days of GEC’s decision and collect and review
additional evidence from the additional Participating Manufacturers to demonstrate
conformance with the Criterion. The Participating Manufacturer may be given up to threemonths from the date notified to make necessary corrections and provide the CAB withadditional documentation. If unable to demonstrate conformance in the three-month period,
the Participating Manufacturer must make appropriate changes [unselect EPEAT Criteria or
remove/archive the impacted product(s)].

Ongoing Requirements of CABs

(3)

If unable to provide additional documentation as per item (1) above, determine if additional
Participating Manufacturer clients may also be impacted by the same original conformity
decision (which was found nonconformant during the Annual EPEAT Audit), and collect andreview additional evidence from those additional Participating Manufacturer clients todemonstrate conformance with the Criterion.
Within 30 calendar days of receiving the audit report, the CAB must also determine if the same
original conformity decision was also made for additional Participating Manufacturers. The
CAB must notify GEC of these findings.
Similar to (2) above, the CAB must then notify the additional Participating Manufacturers
within three business days of notifying GEC and collect and review additional evidence fromthe additional Participating Manufacturers to demonstrate conformance with the Criterion.
The additional Participating Manufacturers may be given up to three months from the date
notified to make necessary changes and provide the CAB with additional documentation. If
unable to demonstrate conformance in the three-month period, the additional Participating
Manufacturers must make appropriate changes [unselect EPEAT Criteria or remove/archive
the impacted product(s)]CAB Performance Metrics
GEC evaluates the performance of all GEC-approved CABs against a series of customer service andconformity assurance metrics at least annually and shares the results with CABs during their Annual
EPEAT Audit of CAB. Results of these reviews are not made publicly available.
GEC views these performance metrics as a mechanism for encouraging continuous improvement in theprovision of conformity assurance services. Ultimately the goal is to support all GEC-approved CABs in
the critical service they provide in the EPEAT Conformity Assurance System and help them improve
where needed.
These performance metrics are also intended to promote consistent and objective conformity assurance
decisions within and across all GEC-approved CABs, and nonconformances may be given forunsatisfactory performance. For CABs that are not meeting performance metrics, GEC may holdadditional regularly scheduled meetings, provide further training on focused topics and work with CABs
on improvement plans, where warranted.

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Table 2: CAB Performance Metrics and Annual Expectations
Customer Service
Metric 1

Customer Service Provision Policy
GEC-approved CABs must have a policy in place that identifies that customer service for Participating
Manufacturer clients is measured and improved.

Ongoing Requirements of CABs

GEC-approved CABs must have a policy or procedure in place that addresses the following:• When assessing conformance to EPEAT Criteria, expectations for adequately articulating toParticipating Manufacturer clients why document submissions meet Criteria requirements or not,without providing consulting services to the Participating Manufacturer.
• High-level expectations for service delivery times for Participating Manufacturer clients.
GEC-approved CABs may use existing policies or service level procedures in place for other non-EPEAT
services as long as these meet the above requirements.
The policy and/or procedures will be reviewed during the Annual EPEAT Audit of CAB.
Technical Proficiency and Training
Metric 2

Calibration Meetings
At least one representative from each GEC-approved CAB must attend each Calibration Meeting. One
meeting annually may be missed due to extenuating circumstances without penalty.
If the frequency of meetings increases, the EPEAT Program will reassess attendance requirements andmay hold meetings in multiple time zones to better accommodate GEC-approved CABs.

Metric 3

Continuous Monitoring Training
For Level 0 and 1 Rounds, Aat least one CAB representative must attend all regularly scheduled
Continuous Monitoring training sessions for those product categories for which they are approved.
Individual Qualified Auditors participating in the Round, if unable to attend the training at the time it isheld, must watch the recording, and confirm in writing to the appropriate representative of their CAB
that this is complete. Auditors are only required to attend the training or review the recordings for the
specific Criteria they are investigating in the Round. For Level 2 Rounds, at least one CAB representative
must attend the training.

Metric 4

Annual Auditor Refresher Training
Qualified Auditors must attend the Annual Refresher Training. If unable to attend the training at thetime it is held, Auditors must watch the recording and confirm in writing to the EPEAT Program that thisis complete. In advance of the training, GEC-approved CABs must notify the EPEAT Program of any
Auditors that will be absent or any personnel changes affecting Auditor presence for the annual training
and exam.

Metric 5

Annual Auditor Proficiency
Qualified Auditors must pass the Annual Auditor Proficiency Exam with a score of 75% or greater.

Nonconformance Findings in Annual EPEAT Audit of CABs
Metric 6

Integration of EPEAT Program Requirements into Quality Management System
GEC-approved CAB should receive no more than five nonconformances related to the incorporation of
EPEAT Program requirements (as per Section 5.1) into its quality management system. During EPEAT
Audits of CABs, nonconformances will only be issued based on the effective version of P66, and notproposed revisions or versions not yet in effect.

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Metric 7

Conformity Assurance Decisions
GEC-approved CAB should receive no more than two nonconformances per product category due tounacceptable conformity decisions made during Documentation Review or Annual Renewal activities ordue to lack of acceptable documentation of the rationale for conformance or competence during
Documentation Review activities.

Metric 8

Corrections Beyond the Agreed Resolution Timeframe
All nonconformances should be corrected and corrective action plans implemented in the agreed
timeframe. In recognition that a CAB may experience delays out of its control when implementing
corrective action plans, a CAB may request an extension and notify the EPEAT Program of the reason forthe delay.

Ongoing Requirements of CABs

Continuous Monitoring
Metric 9Late Investigations Reports
No reports should be returned to the EPEAT Program after the specified deadline, unless the CAB
notifies the EPEAT Program at least 24 hours before the deadline and obtains approval from the EPEAT
Program to submit the Investigation Report past the deadline.

Metric 10

Insufficient Rationale to Support Recommendations
No more than two reports per product category should be returned to a CAB due to an insufficient
rationale to support the conformity recommendation.
Insufficient rationale to support the conformity recommendation means either a failure to address all
aspects of the criterion, including a description of the evidence provided for each aspect, or an
insufficient level of detail being provided to support the CAB’s recommendation. Before each Round,
EPEAT conducts training with each CAB to identify expectations for Investigation Reports.
While reviewing submitted Investigation Reports, the EPEAT Program may ask clarifying questions about
the Investigation Report and evidence submitted by the Participating Manufacturer to further
understand the evidence and/or CAB recommendation on conformity. In some cases, the EPEAT
Program may ask the CAB to update the Investigation Report to include additional details. Only if the
CAB does not make appropriate updates will the EPEAT Program consider there to be “insufficient
rationale to support the conformity recommendation”.
At any time during the Investigation Phase, and until reports are due to the EPEAT Program, CABs may
resubmit updated reports if they find an error, incomplete report, or report with insufficient rationale.

Metric 11

Incomplete Investigation Reports
No more than four reports (across all product categories) should be submitted with missing required
entries, or containing the name of the Participating Manufacturer or product under investigation, or
not following the correct format as specified in the Investigation Report template.
At any time during the Investigation Phase, and until the date that reports are due to the EPEAT
Program, CABs may resubmit updated reports if they find an error or determine the report isincomplete.

Metric 12

Recommendations that Differ from EPEAT’s Final Conformity Decision
No more than two CAB recommendations on conformity per product category, or no more than 20% ofrecommendations on conformity per product category, should differ from the EPEAT Program’s final
decisions due to the CAB’s misunderstanding of EPEAT Criteria or the associated conformity assurance
requirements.
Because the number of investigations a CAB conducts annually is dependent on the number ofParticipating Manufacturer clients it has, both metrics will be evaluated by the EPEAT Program, but
CABs can choose which metric will be used in their annual performance review. An exception is if a CAB

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has two or less investigations per product category annually. In such cases, only the second metric will
be evaluated.
While reviewing submitted Investigation Reports, the EPEAT Program may ask clarifying questions about
the Investigation Report and evidence submitted by the Participating Manufacturer to further
understand the evidence and/or CAB recommendation on conformity. In some cases, the EPEAT
Program may ask the CAB to change its recommendation on conformity based on the responses to thequestions. Only if the CAB does not change its recommendation will the EPEAT Program consider it a“recommendation that differs from EPEAT’s final conformity decision”.

Ongoing Requirements of CABs

If an Investigation Report contains insufficient rationale to support the Auditor’s recommendation, andthe EPEAT Program overturns the recommendation, this will only be counted towards Metric 12, not
Metric 10.
The EPEAT Program recognizes that some differences in recommendations and final decisions may be
due to unique Participating Manufacturer situations that are not fully addressed by EPEAT’s conformity
assurance requirements. Therefore, all differences are evaluated on a case-by-case basis.

CAB Summit
On an annual basis, GEC hosts a CAB Summit to further its goals of consistency, objectivity, andproficiency in the assessment of EPEAT-registered products. The CAB Summit is intended to strengthen
GEC-approved CAB understanding of current EPEAT policies and conformity assurance requirements andallows the EPEAT Program to bring issues to CABs for further discussion. The Summit is also designed tostimulate collaboration and knowledge sharing between the EPEAT Program and CABs, and further
empower GEC-approved CABs in their decision making with additional and focused training.
Conformity assurance guidelines and technical questions, policies, and EPEAT support for CAB outreachactivities may be discussed during the Summit, and both GEC-approved CABs and the EPEAT Program
can provide feedback on suggested changes.
GEC hosts the Summit through an online platform or in person, and one or more CAB representatives or
Qualified Auditors are required to attend. Provisional CABs are also strongly encouraged, but notrequired, to attend the Annual CAB Summit.
GEC-approved CABs are encouraged to invite additional personnel to specific sessions, where relevant.
GEC understands time commitments required for activities such as the CAB Summit and takes this into
consideration when planning annual activities. When hosting in person meetings, GEC may also decide
to offer an online session for GEC-approved CABs that are unable to travel.

Inappropriate Use of EPEAT Name and Marks
The GEC Conformity Assurance Body Agreement (P33) requires that GEC-approved CABs report to GEC
any observed inappropriate use of the EPEAT name and Marks. CABs are not responsible for pursuing
any misuse of the EPEAT name and Marks.

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Performance Improvement, Suspension or Termination
Section 5.6 outlines the progressive actions that GEC may take when a GEC-approved CAB fails to meetthe requirements identified in EPEAT Policy Manual (P65) and/or EPEAT Conformity Assurance
Implementation Manual (P66). In most situations when a CAB’s performance is no longer satisfactory,
GEC first develops a Performance Improvement Assistance Plan for the CAB before progressing tosuspension and/or termination.

Ongoing Requirements of CABs

5.6.1

Performance Improvement Assistance Plans

When a GEC-approved CAB fails to meet one or more of the requirements identified in EPEAT Policy
Manual (P65) and/or EPEAT Conformity Assurance Implementation Manual (P66), GEC may develop a
Performance Improvement Assistance Plan for the CAB. A Performance Improvement Assistance Plan isa tool that is intended to facilitate additional support and training for an individual CAB. Scenarios that
may lead GEC to develop such a Plan include but are not limited to:•••

Repeated or ongoing failure to meet one or more performance metrics identified in Section
5.3;
Repeated or ongoing failure to meet one or more requirements identified in EPEAT Policy
Manual (P65) and/or EPEAT Conformity Assurance Implementation Manual (P66);
Complaint(s) received by GEC regarding a CAB’s performance.

A Performance Improvement Assistance Plan identifies goals, action items and deadlines that the GECapproved CAB must meet to prevent progression to suspension and/or termination. The plan is basedon requirements in EPEAT Policy Manual (P65), EPEAT Conformity Assurance Implementation Manual(P66) and the CAB’s individual situation. CABs have an opportunity to review the proposed Performance
Improvement Assistance Plan before implementation, and a representative from both entities will sign
the document CAB Performance Improvement Assistance Plan (P73) to ensure commitment for
execution.
Performance Improvement Assistance Plans may include, but are not limited to:•Specific actions and deadlines for unresolved nonconformances resulting from an Annual
EPEAT Audit.

•

Regularly scheduled review of decisions made during Documentation Review and/or Annual
Renewal, where the Performance Improvement Assistance Plan identifies the Criteria andfrequency of review.

•

More frequent EPEAT Audits of CABs, where the Performance Improvement Assistance Plan
identifies the frequency of audits and the topics that will be reviewed.

•

Regularly scheduled reviews of CAB performance metrics, where the Performance
Improvement Assistance Plan identifies the frequency of reviews.

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Additional training sessions and/or one-on-one meetings between GEC and the CAB, where
the Performance Improvement Assistance Plan identifies the frequency of training sessions
and/or meetings.

•

Requiring additional Qualified Auditors to attend Calibration meetings, where the Performance
Improvement Assistance Plan identifies how many or which team members must attend.

•

Reinstating CAB Mentored Work Phase (as per Section 3.5).
o

The Performance Improvement Assistance Plan will identify the Criteria for which the
CAB’s decisions in a product category must be reviewed by the EPEAT Program. This may
include up to 100% of Required Criteria and/or 50% of Optional Criteria. All otherrequirements of CAB Mentored Work Phase, as per Section 3.5, shall apply.

o

The Performance Improvement Assistance Plan will identify how review of conformity
decisions for new or existing Participating Manufacturers will occur. This could include
review of decisions made during Initial Documentation Review and/or Ongoing
Documentation Review and recommendations made during Continuous Monitoring
activities.

o

If the CAB is not actively engaging with new Participating Manufacturers or completing
Ongoing Documentation Review, the Performance Improvement Assistance Plan will
include action items and deadlines that address this. This may result in an increased
assessment of Documentation Review and Annual Renewal decisions during the EPEAT
Audit of CAB.

GEC is not required to develop a Performance Improvement Assistance Plan for a CAB. There may besituations where a CAB is immediately suspended without completing a Performance Improvement
Assistance Plan, including but not limited to: providing consulting-like advice or services that impacts its
ability to remain impartial in EPEAT-related activities; providing unfair advantage to one or more
Participating Manufacturer clients; or undertaking other actions that put the integrity and credibility of
the EPEAT Program at risk.

5.6.2

Suspension and Termination

As per the EPEAT Policy Manual (P65), GEC, at its sole discretion, may suspend or terminate a GECapproved CAB and any decision to do so shall be considered final. Grounds for suspension or
termination as identified in EPEAT Policy Manual (P65) are as follows:•

Nonconformances identified during the Annual EPEAT Audit, or an audit performed by anaccreditation body that remain uncorrected beyond the agreed time.

•

Failure to implement and complete all requirements of a Performance Improvement
Assistance Plan within the designated timeframe.

•

Non-payment of annual EPEAT CAB Participation Fees to GEC.

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Any breach of GEC Conformity Assurance Body Agreement (P33) that goes uncorrected beyond
the agreed upon time.

•

Failure to meet the same Performance Metric for three consecutive years.

•

Failure to conform with the requirements identified in the EPEAT Conformity Assurance
Implementation Manual (P66) that remain uncorrected beyond the agreed time.

•

Loss of accreditation to ISO/IEC 17020 Conformity assessment – Requirements for theoperation of various types of bodies performing inspection or ISO/IEC 17065 Conformity
assessment – Requirements for bodies certifying products, processes and services, or failure toprovide a valid certificate.

•Intentionally sharing upcoming Continuous Monitoring Round details with Participating
Manufacturers before the date specified by the EPEAT Program with the intention of providing
the Participating Manufacturer an unfair advantage. (See Section 7.2.1 for actions the EPEAT
Program takes in such scenarios.)•

Obtaining a product directly from a Participating Manufacturer for laboratory evaluation
without first obtaining approval from the EPEAT Program.

•

Undertaking actions that put the integrity and credibility of the EPEAT Program at risk, such asproviding consulting-like advice or services that impacts the CAB’s ability to remain impartial in
EPEAT-related activities or providing unfair advantage to one or more Participating
Manufacturer clients.

5.6.2.1

Suspension

If a CAB meets one or more of the grounds for suspension or termination identified in Section 5.6.2, GEC
may suspend the CAB. GEC notifies the CAB in writing of the reasons for suspension, the suspension
period, and the actions that must be completed during the suspension period. The maximum period ofsuspension is six months. CABs that are suspended may continue to provide EPEAT-related conformity
assurance services to their existing Participating Manufacturer clients during the suspension period, but
may not accept new Participating Manufacturer clients.
During the suspension period, a CAB must complete all actions identified by GEC and implement
corrective action plans to prevent reoccurrence of the underlying issues in the future. Failure tocomplete the actions and/or implement corrective action plans will result in GEC terminating the CAB.
If a GEC-approved CAB’s accreditation to ISO/IEC 17020 or ISO/IEC 17065 is suspended or withdrawn, or
the CAB is unable to provide a valid accreditation certificate, GEC will automatically suspend the CAB.
The CAB must present GEC with a plan and timeline describing how the ISO/IEC 17020 or ISO/IEC 17065
suspension will be lifted or how it will regain accreditation. If a CAB’s ISO/IEC 17020 or ISO/IEC 17065
accreditation is withdrawn, it must become reaccredited within six months of the date of withdrawal.
Failure to regain complete ISO/IEC 17020 or ISO/IEC 17065 accreditation within six months will result
GEC terminating the CAB.

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5.6.2.2

Termination

Termination is cancellation of the agreement between GEC and the CAB and bars the CAB fromproviding EPEAT conformity assurance services for a minimum of one year. GEC notifies the CAB of
GEC’s intent to terminate in writing and within the timeframe identified in GEC Conformity Assurance
Body Agreement (P33).

Ongoing Requirements of CABs

On the termination date, GEC informs the CAB’s Participating Manufacturer clients of the termination.
GEC Conformity Assurance Body Agreement (P33) requires that CABs transfer their Participating
Manufacturer clients to a different GEC-approved CAB in the event of termination. GEC shall support
this orderly transition.
Affected Participating Manufacturers are given 12 months from the time of notification to engage a new
GEC-approved CAB and complete the necessary Initial Documentation Review requirements forchanging CABs (see Section 8.0). During this 12-month period, the Participating Manufacturers’ products
will remain on the EPEAT Registry. If the Initial Documentation Review requirements for changing CABs
are not completed in the 12-month period and in accordance with Section 8.0, the new CAB mustarchive the affected products until the Review process is completed. All other requirements for changing
CABs (including review of Optional Criteria) must also be met.
If, at the time of notification, affected Participating Manufacturers are engaged in ongoing Continuous
Monitoring Investigations, the EPEAT Program will cancel these Investigations. Once affected
Participating Manufacturers have engaged a new CAB, the EPEAT Program may assign Investigations
even during the required Initial Documentation Review process.

Administration of Participating Manufacturer Clients
GEC-approved CABs are required to inform the EPEAT Program when an existing Participating
Manufacturer indicates that it will not be renewing its contract for EPEAT-related conformity assurance
services. CABs are required to inform the EPEAT Program within five business days of receiving such a
notice to enable the EPEAT Program to adjust any Continuous Monitoring Investigations currently
underway or planned.

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6.0 Documentation Review
General Requirements

Documentation Review

6.1.1

Overview

Documentation Review is the process used by a GEC-approved CAB to evaluate a Participating
Manufacturer’s Criteria selections by assessing conformance (i.e., assess the integrity of documentation
provided by a Participating Manufacturer and determine if it demonstrates conformance with theCriteria – see Section 6.1.4) and by assessing competence (i.e., assess if the Participating Manufacturer
understands the requirements of the Criteria and can provide acceptable evidence – see Section 6.1.5).
Documentation Review is the CAB’s opportunity to ensure that they and their clients share a common
understanding of the requirements, the Conformity Assurance process, and what evidence is needed todemonstrate conformance on an ongoing basis
Documentation Review activities fall into two categories:•

Initial Documentation Review: This is the review conducted when a Participating Manufacturer
initially registers its first products in the EPEAT Registry or registers products in a new productcategory. Initial Documentation Review must be completed before a Participating
Manufacturer’s products can become EPEAT-registered for a product category.

•

Ongoing Documentation Review: This includes all other Documentation Review activities that
occur after a Participating Manufacturer’s initial products first appear in the EPEAT Registry fora product category. Ongoing Documentation Review can occur for a variety of reasons, such as
the addition of new products, changes to the EPEAT Criteria selected for EPEAT-registeredproducts and addressing nonconformances arising from Continuous Monitoring activities.

Documentation Review is required for both the Priority Verification Pathway and the Certification
Pathway. Where applicable, differences between these pathways are identified throughout Section 6.
Only Qualified Auditors can conduct Documentation Review activities, assess Participating Manufacturer
competence against Criteria, and remove Documentation Review Requirements for Criteria.
During the Documentation Review process, a Participating Manufacturer is expected to cooperate with
its GEC-approved CAB and facilitate the Documentation Review process. This includes:•

Understanding EPEAT Criteria and any supplementary information as necessary (e.g., externalmaterials referenced in the Criteria, Clarifications, and/or Conformity Guidance Materials).

•Compiling documentation and submitting it to the GEC-approved CAB in an organized and timely
manner.

•Responding to questions raised by the GEC-approved CAB.

•

Maintaining sufficient records to prepare for Continuous Monitoring activities.

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Throughout the remainder of Section 6, the use of the term “CAB” shall imply a GEC-approved CAB.

6.1.2

Documentation Review Process

Documentation Review

During both Initial Documentation Review and Ongoing Documentation Review, a series of steps arefollowed by Participating Manufacturers and CABs, as identified in the diagram below.

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6.1.3

Documentation Review Plan

For both Initial Documentation Review and Ongoing Documentation Review, CABs must develop a
Documentation Review Plan that identifies the products and EPEAT Criteria that will be reviewed andreflects the conformity assurance pathway selected by the Participating Manufacturer. CABs must share
the Documentation Review plan with Participating Manufacturers at the beginning of theDocumentation Review process.

Documentation Review

To enable CABs to develop Documentation Review Plans and sample products or choose representative
products, Participating Manufacturers must provide their CABs with a list of products they wish toregister, the EPEAT Criteria selected for those products and where applicable, additional information tofacilitate the product selection and sampling process (e.g., details regarding product configurations,components, bills of material, packaging, manufacturing processes and supply chains).
Section 6.2.1 provides additional guidance on product selection and sampling for Initial Documentation
Review; however, this guidance may also be used for Ongoing Documentation Review.

6.1.4

Assessing Conformance

When assessing conformance, CABs must evaluate evidence submitted by Participating Manufacturers
and make determinations of conformance with EPEAT Criteria using the guidance provided in thisSection (6.1.4) and keep appropriate records as identified in Section 6.1.7. Typically, the evaluation
process is iterative, and CABs may request additional evidence from Participating Manufacturers.
Participating Manufacturers may also demonstrate nonconformance to a Criterion and need to makeappropriate changes to come into conformance. CABs must maintain a record of how thenonconformance was communicated, what new evidence was provided and how the evidence
demonstrated conformance. Some nonconformances may result in denying product registration for
select or all products.
6.1.4.1

Criteria for Different Locations of Use (Countries)

Participating Manufacturers designate their EPEAT-registered products as available for use bypurchasers in specific countries. Some EPEAT Criteria may be selected differently for individual locationsof use (countries). Evidence provided for these Criteria must demonstrate that the Participating
Manufacturer and their products are conformant in the identified locations of use (countries).
Depending on the Pathway chosen, Participating Manufacturers must either demonstrate conformancefor all identified locations of use (Certification Pathway) or for an appropriate sample of identified
locations of use (Priority Verification Pathway).
Section 6.2.1 provides additional guidance on sampling for Initial Documentation Review; however, thisguidance may also be used for Ongoing Documentation Review.
6.1.4.2

Priority Criteria

When a new product category is launched or revised, the EPEAT Program identifies “Priority Criteria”.
Priority Criteria are the minimum EPEAT Criteria selected by the Participating Manufacturer that must
be reviewed by the CAB before allowing a Participating Manufacturer’s first products in a product

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category to become EPEAT-registered. For each product category, Priority Criteria are all Required
Criteria in the category and those Optional Criteria in the category that the EPEAT Program has
identified as being more difficult to demonstrate conformance with. The list of Priority Criteria for eachproduct category is available to Participating Manufacturers and CABs on the EPEAT Registry and toother stakeholders upon request.
6.1.4.36.1.4.2 Types of Evidence and Ensuring Integrity of Evidence

Documentation Review

When assessing conformance to EPEAT Criteria, CABs must use the following normative requirements
and guidance to inform their decisions:•

Specific language used in EPEAT Criteria (normative).

•

Published Clarifications (normative).

•

Published EPEAT Conformity Guidance Materials (guidance).

Participating Manufacturers may provide various forms of evidence to demonstrate conformance with
EPEAT Criteria including but not limited to accreditation certificates, evaluation reports fromlaboratories, process or procedural documents, descriptions or lists of product components andmaterials, supplier letters, corporate reports, product manuals and other information produced
internally. Acceptable forms of evidence may be stipulated in certain EPEAT Criteria.
When accepting evidence from a Participating Manufacturer as part of the Documentation Review
process, CABs must first verify the integrity of the information before it can be relied upon to makeconformity decisions. CABs are required to use their professional judgement in assessing the integrity of
information and must specifically consider the following:•

Information supplied by other parties must meet the requirements stipulated in the relevant
EPEAT Criterion.

•

Information provided should be clearly dated and dates should be consistent with the Criteria
requirements.

•

If information supplied by other parties includes a determination or evaluation, the individual
making the determination or evaluation must be clearly identified along with an indication of
their authority for making the evaluation/determination.

•

Information such as test data or reports produced by a laboratory accredited to ISO/IEC 17025
by an ILAC member accreditation body may be considered as accurate, on the basis of thelaboratory’s accreditation. Similarly, certificates or reports produced by bodies such as
certification bodies or inspection bodies that are accredited to a relevant ISO conformity
assessment standard by an ILAC or IAF member accreditation body may also be considered as
accurate. Some EPEAT Criteria require certification bodies to be accredited by an ILAC or IAF
member body.

•

All laboratory reports, including those from internal laboratories and accredited third-party
laboratories must contain the following information: laboratory name and location; date of

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testing; identification of product, component or material evaluated; test method(s) used and if
applicable, detection limits; evaluation results; sign off from an appropriate party at thelaboratory; and if applicable, identification of relevant laboratory accreditations.

Documentation Review••

Some EPEAT Criteria allow Participating Manufacturers to submit supplier letters or
manufacturer declarations as evidence – these are called “declarations of conformity”.
Participating Manufacturers must ensure any declaration of conformity is structured such thatit aligns with the requirements of ISO/IEC 17050-1 Conformity assessment – Supplier’s
declaration of conformity- Part 1: General Requirements and that any supporting
documentation from the issuer to substantiate a declaration of conformity aligns with therequirements described in ISO/IEC 17050-2 Conformity assessment – Supplier’s declaration ofconformity- Part 2: Supporting documentation and CABs must ensure that all declarations ofconformity contain the information identified below10.
oA unique identifier for the declaration of conformity (a specific way to uniquely identify
the declaration itself).

o

The name and contact address of the organization issuing the declaration.

o

The identification of the object of the declaration of conformity (e.g., name, type, date ofproduction or model number of a product, component, or material).

o

The statement of conformity (e.g., “As delivered, the object of the declaration describedabove is in conformity with X requirements or documents”).

o

A complete and clear list of standards or other specified requirements, as well as theselected options, if any.

o

The date and place of issue of the declaration of conformity.

oThe signature (or equivalent sign of validation), name and function of authorized person(s)acting on behalf of the organization issuing the declaration.

o

Any limitation on the validity of the declaration of conformity.

Some EPEAT Criteria specify acceptable test methods or standards that must be used todemonstrate conformance, while others state that an equivalent may be used.

10This requirement only applies to new declarations of conformity submitted to demonstrate conformance withthe revised Criteria from the Sustainability Impact Module criteria development process. This requirement takes
effect starting February 15, 2023. Participating Manufacturers are not required to revise existing declarations ofconformity that are already in use for existing Criteria.
The EPEAT Program will provide declaration of conformity templates in the Registry for each revised Criterion thatallows for such declarations. Participating Manufacturers are not required to use the templates, however if theprovided template is not used, the content of the declaration must capture all the same details as those covered in
the template
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Documentation Review

6.1.5

o

If a Criterion does not allow the use of an equivalent, CABs must inform EPEAT of its or its
Participating Manufacturer client’s request to use an alternative and the EPEAT Program
makes the final decision.

o

If a Criterion allows for the use of an equivalent, CABs may use their expertise andprofessional judgment to accept alternative test methods or standards. The EPEAT
Program requests that CABs inform EPEAT of the alternative so that EPEAT can update
Conformity Guidance Materials.

Assessing Competence

When assessing competence, CABs also use professional judgement to evaluate Participating
Manufacturers’ understanding of EPEAT Criteria and their ability to demonstrate conformance on an
ongoing basis (referred to as “competence”). Assessing Participating Manufacturer competence with
EPEAT Criteria is required for the Priority Verification Pathway. Participating Manufacturers that selectthe Certification Pathway are not required to demonstrate competence with EPEAT Criteria; however,
CABs may still track this information should the Participating Manufacturer want to switch to the Priority
Verification Pathway.
When a Participating Manufacturer demonstrates competence for a Criterion, the CAB may remove therequirement for further Documentation Review for that Criterion. The decisions made by CABs for
Participating Manufacturer conformance and Participating Manufacturer competence are separate andmay be made at different points in time.
Competence is evaluated on a Criterion-by-Criterion basis. If a Participating Manufacturer demonstrates
competence and an understanding of the Criterion and the required evidence to show conformance, theCAB may remove the requirement for further Documentation Review for that Criterion. CABs must keep
appropriate records of the evaluation and decision, as per Section 6.1.7.
To demonstrate competence, Participating Manufacturers are expected to identify relevant sections of
documentation submissions to their CAB and explain why or how the evidence meets individual
Criterion requirements.
In addition to the guidance provided above, positive indicators of Participating Manufacturer
competence include:•

Providing the correct form of accurate evidence with minimal guidance from the CAB.

•

Clearly indicating how the evidence demonstrates conformance (e.g., by directing the CAB to
specific pages in a manual or indicating within a test report where the relevant test results canbe found).

•For EPEAT Criteria that include multiple elements, indicating how the evidence demonstrates
conformance with each specific element.

•

Applying the appropriate normative references.

Indicators that the competence threshold is not being met include:

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Showing a continued inability to provide relevant and adequate evidence and/or
documentation.

•

Needing to update evidence and documentation to address Criterion elements.

•

Not providing evidence to support conformance to all elements of a Criterion.

•

Providing large amounts of evidence without indicating how the evidence demonstrates
conformance or providing evidence that clearly demonstrates non-conformance (e.g., test
report that shows non-conformant levels).

•

Providing the wrong type of evidence (e.g., CAB requests a test report for specific substancesand Participating Manufacturer provides a test report that does not include the requested
information).

•

Consistently not applying appropriate normative references.

The length of time it takes to review a Criterion alone is not a sole indicator that competence has notbeen demonstrated. In these situations, the CAB may use professional judgment to assess whether theParticipating Manufacturer understands the Criterion and whether the Participating Manufacturer will
have difficulties demonstrating conformance for other products or demonstrating conformance for theCriterion in the future Continuous Monitoring activities.
It may be necessary for the CAB to review the same EPEAT Criterion for multiple products or acrossmultiple locations of use (countries) before they are confident in the Participating Manufacturer’s
competence to provide evidence of conformance.

6.1.6

Activating Products and Criteria

CABs allow product(s) and the EPEAT Criteria selected for the product(s) to appear in the EPEAT Registryby using the Registry software to “activate” the product(s) and Criteria. GEC may perform a data quality
review of Criteria selections to ensure they are appropriate for the product type before the activation isapproved.

6.1.7

Documentation Review Records

CABs must keep all records related to Documentation Review including Documentation Review plans,evidence provided by the Participating Manufacturer, the rationale for accepting evidence anddetermining conformance, and the rationale for decision to remove the requirement for Documentation
Review for one or more EPEAT Criteria because the Participating Manufacturer demonstrated
competence against the Criteria.
In some cases, CABs may determine that Documentation Review is not necessary [such as in cases
where the conformity assurance needs are similar for multiple locations of use (countries)]. In these
instances, CABs must also maintain records documenting where and why Documentation Review was
specifically not performed.

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The CAB must maintain their own internal list of all products that used the Certification Pathway for
Initial Documentation Review, in order to perform the required Continuous Monitoring activities(Annual Renewal).

Initial Documentation Review
6.2.1

Documentation Review Plan, Product Selection and Sampling

Documentation Review

During Initial Documentation Review, CABs must develop a Documentation Review Plan as per Section
6.1.3 and share this Plan with the Participating Manufacturer.
Participating Manufacturers must first provide their CAB with an initial list of products they wish toregister in the product category and the EPEAT Criteria selected for each product. Participating
Manufacturers must also provide further details to facilitate the CAB’s product selection and sampling
process for Initial Documentation Review (e.g., details regarding product configurations, components,
bills of material, packaging, manufacturing processes and supply chains).
A Participating Manufacturer may choose to add additional products to the initial list at a later stage in
the Initial Documentation Review process. In such cases, there may be additional product activation andDocumentation Review requirements (see Section 6.2.4).
The table below identifies the product selection and sampling processes CABs must use for the Priority
Verification and Certification Pathways.
Product Selection and Sampling:
Priority Verification Pathway

Product Selection and Sampling:
Certification Pathway

Allows for the use of a product sampling technique toreview all Criteria across all products. Sampling may also
be applied across all selected locations of use (countries).

Allows for the use of product families or groups of products withsimilar characteristics, which do not affect how or if the
products conform with all selected EPEAT Criteria. Allows
information from one product to be used to represent otherproducts from the same family or group, instead of evaluatingeach product individually.

Where a Participating Manufacturer submits more than
one product during Initial Documentation Review,
assessing conformance may be spread across several
products. In these cases, the CAB should sample several
products from the initial list of products, based on producttypes and characteristics, and review different EPEAT
Criteria for each product.
The CAB must identify the sampling process used in its
Documentation Review Procedures. The CAB must
document the product selection and sampling decisions
made.

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Where a Participating Manufacturer submits more than one
product during Initial Documentation Review, assessing
conformance may be spread across several representative
products.
The CAB must have a documented procedure for assessing afamily or group of products, which identifies what informationmust be evaluated to determine similarity of productcharacteristics and outlines guidelines for selecting
representative product(s). The CAB must document the productselection and sampling decisions made.

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6.2.2

Assessing Conformance

Documentation Review

During Initial Documentation Review, a Participating Manufacturer must demonstrate conformance withall selected Criteria for the sampled products (Priority Verification Pathway) or representative products(Certification Pathway) from the initial list of products included in the Initial Documentation Review Plan
before any of the products on the list can become EPEAT-registered. For the Priority Verification
Pathway, conformance must be demonstrated for a sampling of locations of use (countries), and for the
Certification Pathway, conformance must be demonstrated for all locations of use (countries) includedin the Initial Documentation Review Plan. CABs must follow the guidance provided in Section 6.1.4 whenassessing conformance.
During Initial Documentation Review, a Participating Manufacturer must demonstrate conformance
with, at minimum, all Priority Criteria (both Required and Optional Priority Criteria) selected for the
initial list of products included in the Initial Documentation Review Plan before any of the products in
the initial list can become EPEAT-registered. CABs must follow the guidance provided in Section 6.1.4
when assessing conformance.
For the Priority Verification Pathway, CABs may review Non-Priority Optional Criteria during Initial
Documentation Review or as part of Ongoing Documentation Review as specified in Section 6.3.1.
However, CABs and Participating Manufacturers may choose to review all selected Criteria (both Priority
and Non-Priority) during Initial Documentation Review before any products become EPEAT-registered ina product category.
For the Certification Pathway, during Initial Documentation Review, the Participating Manufacturer mustshow conformance for all representative products, all selected Criteria (Priority and Non-Priority) andlocations of use (countries) included in the Initial Documentation Review Plan before the representative
products can become EPEAT-registered in the product category.

6.2.3

Assessing Competence

During Initial Documentation Review, CABs use professional judgement and follow the guidance
provided in Section 6.1.5 to assess Participating Manufacturers’ competence (Participating
Manufacturers’ understanding of EPEAT Criteria and their ability to demonstrate conformance on an
ongoing basis). If a Participating Manufacturer demonstrates competence for a Criterion, the CAB may
remove the requirement for further Documentation Review for that Criterion.
During Initial Documentation Review, assessing Participating Manufacturer competence with EPEAT
Criteria is required for the Priority Verification Pathway. Participating Manufacturers that select theCertification Pathway are not required to demonstrate competence with EPEAT Criteria during Initial
Documentation Review; however, CABs may still track this information should the Participating
Manufacturer want to switch to the Priority Verification Pathway.

6.2.4

Activating Products

Activation of products after Initial Documentation Review should only occur for those products includedin the initial list of products identified by the Participating Manufacturer and included in the Initial

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Documentation Review Plan. The Participating Manufacturer must have demonstrated conformancewith all Criteria selected and locations of use (countries) based on the pathway chosen. At a minimum,
the Participating Manufacturer must have demonstrated conformance with all Priority Criteria they haveselected for the Priority Verification Pathway, or all Criteria and locations of use (countries) selected for
the Certification Pathway.

Documentation Review

For the Priority Verification Pathway:•

If a Participating Manufacturer chooses to add additional products to the initial list at a laterstage in the Initial Documentation Review process, CABs may activate those products only if
the Participating Manufacturer has also demonstrated competence for all Priority Criteria
selected for the additional products. The Participating Manufacturer is required to confirm via
electronic means (in the EPEAT Registry), that any new product they wish to add to theRegistry is similar to and does not have substantive differences with another product (of thesame product type) that is currently in the Initial Documentation Review process.

•If a Participating Manufacturer chooses to add additional products to the initial list at a latestage in the Initial Documentation Review process and If the Participating Manufacturer has
not demonstrated competence for one or more Priority Criteria they have selected, CABs mustsample the additional products as per the requirements in Section 6.2.1 and, at minimum,
review at least one of the additional products to assess conformance for those Criteria.

•

A Participating Manufacturer may choose to select additional Optional Criteria at a later stage
in the Initial Documentation Review process. The Participating manufacturer must
demonstrate conformance with the additional Criteria before the initial list of products can be
activated with the additional Criteria selected. If conformance has not been demonstrated, theCriteria must be unselected before the CAB can activate the initial list of products.
oIf these are Priority Criteria, the Participating Manufacturer must demonstrate
conformance with the additional Criteria before the initial list of products can be activatedwith the additional Criteria selected. If conformance has not been demonstrated, theCriteria must be unselected before the CAB can activate the initial list of products.
If these are Non-Priority Optional Criteria, the CAB may activate the initial list of productswith the additional Criteria selected; however, the Participating Manufacturer must
demonstrate conformance with the additional Criteria during Ongoing Documentation
review as per the requirements in Section 6.3.1.

•

For the Certification Pathway:o

If a Participating Manufacturer chooses to add additional products or an additional
product group/family to the initial list at a later stage in the Initial Documentation Review
process, CABs may activate those products only if (1) the additional products are
determined to be included in the family or group of products and covered by the
representative model(s) chosen, or (2) if the Participating Manufacturer has demonstrated
conformance with all selected Criteria and locations of use (countries) for the additional
products or product group/family.

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A Participating Manufacturer may choose to select additional Optional Criteria at a laterstage in the Initial Documentation Review process. The CAB may activate the initial list of
products with the additional Criteria selected only if the Participating Manufacturer has
demonstrated conformance with those Criteria. If conformance has not been
demonstrated, the Criteria must be unselected before the CAB can activate the initial listof products.

Documentation Review

The table below summarizes the process by which CABs perform initial product activation for both theCertification and Priority Verification Pathways.
Initial Product Activation:
Priority Verification Pathway

Initial Product Activation:
Certification Pathway

The CAB may activate the initial list of products to appear
in the EPEAT Registry after Initial Documentation Review
of all Priority Criteria selected by the Participating
Manufacturer is complete. The Initial Documentation
Review must show conformance with all Priority Criteria
selected. Additional products added to this list may only
be activated if the Participating Manufacturer
demonstrated competence for all Priority Criteria
selected for the additional products.

The CAB may activate products to appear in the EPEAT Registry
after Initial Documentation Review for all selected Criteria
across all products (or product groups) and all identified
locations of use (countries) is complete. The Initial
Documentation Review must show conformance with all
selected Criteria. Additional products can be added to this list if
they are covered by the representative model(s) chosen or if all
Criteria and locations of use (countries) are reviewed for
additional product groups/families identified.

Results of the Initial Documentation Review are valid
until the EPEAT Program implements the Criteria
resulting from a Full Product Category Revision, after
which time the Participating Manufacturer must undergo
the Initial Documentation Review process again. (AnyMinor Criteria Revisions or Major Criteria Revisions must
be addressed during Ongoing Documentation Review.)

Participating Manufacturers can modify their EPEAT Criteria
selections only with approval from the CAB. Any addition of new
Optional Criteria requires the CAB to perform Initial
Documentation Review of the Criteria.

The initial products may appear in the EPEAT Registry
while the Participating Manufacturer completes Ongoing
Documentation Review for all non-Priority Criteria
selected. The Participating Manufacturer has 12 months
to complete this process as per Section 6.3.1. If notcompleted within this timeframe, the CAB archives all
the Participating Manufacturer’s products or unselects
the non-Priority criteria.

Results of the Initial Documentation Review are valid for three
years, after which time the Participating Manufacturer must
undergo the Initial Documentation Review process again. (AnyMinor Criteria Revisions or Major Criteria Revisions must be
addressed during Ongoing Documentation Review.)

Ongoing Documentation Review
Whenever Participating Manufacturers are required to complete Ongoing Documentation Review, CABs
and Participating Manufacturers must follow the guidance provided in Section 6.1. CABs should also use
professional judgement and the sampling guidance provided in Section 6.2.1 when performing Ongoing
Documentation Review.
Ongoing Documentation Review takes place in several instances, including, but not limited to thescenarios outlined below.

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6.3.1

Initial Documentation Review Non-Priority Optional Criteria

A Participating Manufacturer must complete the review of all remaining non-Priority Criteria from Initial
Documentation Review if they are using the Priority Verification Pathway.
After the initial list of products from Initial Documentation Review are activated in the EPEAT Registry
for a product category, the Participating Manufacturer has 12 months from the date of this initialactivation to complete Ongoing Documentation Review for all selected non-Priority Criteria that were
not reviewed as part of Initial Documentation Review. CABs must track the 12-month deadline for all
Participating Manufacturers completing this type of Ongoing Documentation Review.

Documentation Review

If Ongoing Documentation Review of non-Priority Criteria is not completed within the 12-month period,
the Participating Manufacturer must either unselect these Criteria or archive the products that haveselected these Criteria. The CAB is responsible for performing these actions if they are not completed by
the Participating Manufacturer. =During this 12-month period, Participating Manufacturers may choose to select new Optional Criteria
and/or add new products to the EPEAT Registry. Sections 6.3.1.1 and 6.3.1.2 below identify the required
Ongoing Documentation Review requirements for these specific situations.
6.3.1.1

Adding New Products During 12-month Period

During the 12-month period from initial product activation in a product category (as identified above),
the Participating Manufacturer may choose to add new products to the EPEAT Registry. CABs may
immediately activate these products only if the Participating Manufacturer has demonstrated
competence for all Priority Criteria selected for the new products. If competence has not been
demonstrated for one or more Priority Criteria, the Participating Manufacturer must demonstrate
conformance to these Criteria for the new products before they can be activated.
Additionally, if the Participating Manufacturer has also selected new Non-Priority Optional Criteria forthe new products, the process in 6.3.1.2 must be followed.
6.3.1.2

Selecting New Non-Priority Optional Criteria During 12-month Period

During the 12-month period from initial product activation in a product category (as identified above),
Participating Manufacturers may choose to select new non-Priority Optional Criteria. CABs may
immediately activate these Criteria for EPEAT-registered products; however, Participating
Manufacturers must demonstrate conformance with these Criteria and complete the Ongoing
Documentation Review process before the 12-month deadline. If not completed in this timeframe, theParticipating Manufacturer must either unselect these Criteria or archive the products that haveselected these Criteria. The CAB is responsible for performing these actions if they are not completed by
the Participating Manufacturer.
Additionally, if the Participating Manufacturer has also selected new Non-Priority Optional Criteria forthe new products, the process in 6.3.1.1 must be followed.

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6.3.26.3.1

New Products

A Participating Manufacturer wants a new product(s) to become EPEAT-registered.

Documentation Review••

Under the Priority Verification Pathway (and if not in the 12-month period from initial productactivation in a product category as described in Section 6.3.1):o

If a Participating Manufacturer has not demonstrated competence for a Required
Criterion, Ongoing Documentation Review of that Criterion must be completed before thenew product(s) can become EPEAT-registered.

o

If a Participating Manufacturer has not demonstrated competence for an Optional
Criterion selected for the new product(s), Ongoing Documentation Review of that Criterionmust be completed before the new product(s) can become EPEAT-registered. The
Participating Manufacturer can choose to unselect that Criterion in order to have the new
product(s) activated.

o

If a Participating Manufacturer has demonstrated competence and completed
Documentation Review for the selected criteria, they are required to confirm via electronicmeans (in the EPEAT Registry), that any new product added to the Registry is similar to anddoes not have substantive differences with another product (of the same product type)that is currently registered.

o

If a Participating Manufacturer has demonstrated conformance but not demonstrated
competence for a Corporate Criterion (either Required or Optional), Ongoing
Documentation Review of that Criterion must be completed before the new product(s) can
become EPEAT-registered. If the Corporate Criterion has annual performance, reporting orother disclosure requirements, the Participating Manufacturer and/or CAB may develop analternative way for the Participating Manufacturer to demonstrate they understand theCriterion before the next annual reporting cycle and must have this approved by the EPEAT
Program. The CAB may also request that the EPEAT Program works with the CAB andParticipating Manufacturer to find an acceptable method to demonstrate competence.

Under the Certification Pathway: The CAB may conduct an assessment to determine if the new
products have similar characteristics (which do not affect how or if the products conform withall selected EPEAT Criteria) to those assessed in the Initial Documentation Review process. If
the assessment reveals the new products have similar characteristics, the Initial
Documentation Review results may be used for the new products. If the new products cannot
be grouped with existing EPEAT-registered products due to dissimilar characteristics, Ongoing
Documentation Review must be conducted for the new products before they can be activated.

6.3.36.3.2

New Optional Criterion

A Participating Manufacturer wants to select a new Optional Criterion for EPEAT-registered products.
•

Under the Priority Verification Pathway (and if not in the 12-month period described in Section
6.3.1): A Participating Manufacturer must demonstrate conformance and complete Ongoing

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Documentation Review of any new Optional Criterion before that Criterion can be added to
EPEAT-registered products. During this process, the Participating Manufacturer may also
demonstrate competence to the new Optional Criterion. When the Participating Manufacturer
has demonstrated competence, the new Optional Criterion may be selected for any new
products added in the future without further review. If the Participating Manufacturer did notdemonstrate competence, then the Optional Criterion must be reviewed again for any new
products added in the future that are selecting the Optional Criterion.
•

Under the Certification Pathway: A Participating Manufacturer must complete Ongoing
Documentation Review of any new Optional Criteria before those Criteria can be added to
EPEAT-registered products.

Documentation Review

6.3.46.3.3

New Location of Use (Country)

A Participating Manufacturer wants to identify an additional location of use (country) for an EPEATregistered product.
•

Under the Priority Verification Pathway: If the Participating Manufacturer has notdemonstrated competence for a Criterion that may be selected differently for different
locations of use (countries), Ongoing Documentation Review must be completed for the newlocation of use (country) before the Criterion can be added to EPEAT-registered products inthat new location of use (country).

•

Under the Certification Pathway: The Participating Manufacturer must complete Ongoing
Documentation Review for the new location of use (country) and associated EPEAT Criteria
before the Criterion can be added to EPEAT-registered products.

6.3.56.3.4

Loss of Confidence in Participating Manufacturer Competence

A CAB may lose confidence in a Participating Manufacturer’s ability to demonstrate conformance with
one or more EPEAT Criteria (typically because of a nonconformance finding from Continuous Monitoring
activities or a nonconformance identified outside of Continuous Monitoring) and may reinstate theDocumentation Review requirement for those Criteria. In these cases, Participating Manufacturers mustcomplete Ongoing Documentation Review again for those Criteria for any new products.

6.3.66.3.5

EPEAT Criteria Revisions

When the EPEAT Program releases revisions to EPEAT Criteria, Participating Manufacturers can continue
to register their products to the pre-revision version of the EPEAT Criteria until the time the revised
Criteria are implemented by the EPEAT Program. Table 3 below identifies Ongoing Documentation
Review requirements for EPEAT Criteria revisions.

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Documentation Review

Table 3: Documentation Review Requirements for EPEAT Criteria Revisions
Type of Revision

Overview of Revision

Implementation and Documentation Review

Minor Criteria
Revisions•

The scope of this revision is limited tocorrections, changes, and updates totext to further clarify existing
requirements.

•

The revisions are typically editorialchanges with no obvious significant
reduction of points for EPEAT-registeredproducts.

•

The estimated timeframe for
implementation is one to two months
after publication of the revisions.

•

In addition to the revisions categorized
as Minor Criteria Revisions, the scope of
this revision is limited to new Criteria
identified to address gaps insustainability impact areas, and revisions
requested by stakeholders.

The EPEAT Program provides a timeline for
implementation of the revisions and the deadline forwhen Participating Manufacturers must come into
conformance with the revisions. Participating
Manufacturers must complete any required
Documentation Review activities before the identified
deadline. If these activities are not completed by thedeadline, Participating Manufacturers must unselectCriteria or archive products that are no longer
conformant. If these actions are not taken byParticipating Manufacturers, the CABs must then takethese actions. This applies to both the Priority
Verification and Certification Pathways.

Major Criteria
Revisions••

These revisions could result in a loss ofpoints and/or a change in EPEAT tier
(EPEAT Bronze, EPEAT Silver, EPEATGold) for EPEAT-registered products.

Participating Manufacturers are responsible forreviewing applicable changes to Criteria and ensuringcontinued conformance with selected Criteria andunselecting Criteria or archiving products that are nolonger conformant. Participating Manufacturers may berequired to submit documentation to CABs for review todemonstrate conformance to Criterion changes.
Priority Verification Pathway:•

The estimated timeframe for
implementation is four to six months
after publication of the revisions.

CABs are responsible for completing Ongoing
Documentation Review activities for Participating
Manufacturer clients before the date specified by
EPEAT.

Certification Pathway:

Global Electronics Council•

As part of Continuous Monitoring and Annual
Renewal activities (see Section 7.3), CABs are
responsible for assessing the impacts of Minor andMajor Criteria Revisions on Participating
Manufacturer clients. If the Participating
Manufacturer’s Annual Renewal date occurs before
the deadline to implement minor and major criteria
revisions, the Annual Renewal process can be used
to address the revisions.

•

Where applicable, CABs obtain and review new
evidence from Participating Manufacturers to ensureongoing conformance with the revisions.

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Documentation Review

Table 3: Documentation Review Requirements for EPEAT Criteria Revisions
Type of Revision

Overview of Revision

Implementation and Documentation Review

Full ProductCategory
Revisions•

All Criteria are open to modification andrevision.

Priority Verification and Certification Pathways:•

The revisions could result in potential
and significant reduction of EPEATregistered product availability.

•

The estimated timeframe for
implementation is nine to eighteenmonths after publication of Criteria.

•

The EPEAT Program provides a timeline for when therevisions will be implemented, when Participating
Manufacturers must come into conformance withthe revisions and when Continuous Monitoring
Activities will begin.

•

Participating Manufacturers must work with their
CABs to complete Initial Documentation Review, as
per Sections 6.1 and 6.2, for the revisions by thedate specified by the EPEAT Program.

•Previous Initial Documentation Review results will nolonger be valid after this date.

•

All products that have not completed the Initial
Documentation Review process for the Criteria
revisions will be removed (archived).

Rebranding of EPEAT-Registered Products
Situations may arise where one Participating Manufacturer wants to rebrand another Participating
Manufacturer’s product that is already an active EPEAT-registered product and have it registered under
its own brand, without changing from their current GEC-approved CAB. The Original Participating
Manufacturer (the one that originally registered the product) has already demonstrated that the
product meets EPEAT Criteria, and both Participating Manufacturers are demonstrating ongoing
conformance with Criteria that address corporate activities.
The EPEAT Program allows for this to happen through an amended Documentation Review processdescribed in Table 4 below. Each Participating Manufacturer is responsible for specific conformity
assurance activities and may use their own CAB to implement them, which may result in a different CAB
being used by each Participating Manufacturer. If during this process, the Rebranding Participating
Manufacturer (the one that wants to rebrand an already EPEAT-registered product as its own brand)also wishes to change to a different CAB, it must instead follow the requirements in Section 8. Transfer
of confidential information between GEC-approved CABs or Participating Manufacturers is not required
and the EPEAT Program will not identify products as being “rebranded” on the EPEAT Registry.

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Table 4: Responsibilities During Rebranding of EPEAT-Registered Products
Topic

Original Participating Manufacturer
Responsibilities(Manufactures the product and originallyobtained EPEAT registration)

Rebranding agreement

The parties have a formal agreement in place that identifies the products that will be rebranded
and stipulates fulfillment of the conformity assurance activities identified below. Specifically, thismust include the Original Participating Manufacturer:•

Documentation Review•
Initial Documentation
Review for EPEAT
Criteria that address
product attributes

Rebranding Participating Manufacturer
Responsibilities(Does not manufacture the product and isrebranding the EPEAT-registered product under
its own brand)

Taking responsibility for Continuous Monitoring Investigations assigned to the Rebranding
Participating Manufacturer for product Criteria that do not have disclosure requirements andresolving any resulting nonconformances.
Notifying the Rebranding Participating Manufacturer of any changes in the rebranded
product(s) registration status, EPEAT tier or EPEAT Criteria selected for product attributes.

Must ensure that all products included in therebranding agreement maintain EPEAT
registration status and conform with all
selected Criteria that address productattributes.

Must ensure that Initial Documentation Review
is conducted for the products in the rebranding
agreement for those Criteria that have productdisclosure requirements including but notlimited to criteria related to warranties, productservicing, spare parts, and public availability of
LCAs. Is responsible for providing sufficientevidence to show conformance with these
Criteria.
Can only select Optional Criteria that are
product-related if the Optional Criteria wereselected by the Original Participating
Manufacturer for the product.
Must present the rebranding agreement asevidence during Initial Documentation Review.
However, this agreement cannot be used todemonstrate competence with EPEAT Criteria or
conformance for other products not included in
the rebranding agreement.
Note:• The EPEAT Program maintains a list ofCriteria that have product disclosure
requirements for each product category[Rebranding of EPEAT-Registered Products:
Product Criteria with Disclosure
Requirements (P82)], which is available on
the EPEAT Registry and upon request.
• CABs must evaluate and track whether
competence is demonstrated for each ofthese Criteria as per the requirements in
Section 6.1.5.

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Documentation Review

Table 4: Responsibilities During Rebranding of EPEAT-Registered Products
Topic

Original Participating Manufacturer
Responsibilities(Manufactures the product and originallyobtained EPEAT registration)

Rebranding Participating Manufacturer
Responsibilities(Does not manufacture the product and isrebranding the EPEAT-registered product under
its own brand)

OngoingDocumentation Review
for EPEAT Criteria that
address productattributes

Must meet all Ongoing Documentation
Review requirements for all selected Criteriathat address product attributes.

Must meet all Ongoing Documentation Review
requirements for those Criteria that haveproduct disclosure requirements and is
responsible for providing sufficient evidence toshow conformance with these Criteria.
Can only select Optional Criteria that are
product-related if the Optional Criteria wereselected by the Original Participating
Manufacturer for the product.
If the Original Participating Manufacturer adds
Optional Criteria, the Rebranding Manufacturer
may also add these Criteria. If the Criteria haveproduct disclosure requirements, then Ongoing
Documentation Review is required.
Must maintain a record that all products
included in the rebranding agreement are
actively EPEAT-registered at the effective dateof the agreement and on an ongoing basis.

Initial and Ongoing
Documentation Review
for Criteria that
address corporate
activities

Must meet all Initial and Ongoing
Documentation Review requirements for all
selected Criteria that apply to its corporate
activities.

Must meet all Initial and Ongoing
Documentation Review requirements for all
selected Criteria that apply to its corporate
activities.

Removing (archiving)products

Must notify the Rebranding Participating
Manufacturer if any products in therebranding agreement are archived.

Must archive all products within two businessdays of receiving archival notification from theOriginal Participating Manufacturer.

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Documentation Review

Table 4: Responsibilities During Rebranding of EPEAT-Registered Products
Topic

Original Participating Manufacturer
Responsibilities(Manufactures the product and originallyobtained EPEAT registration)

Rebranding Participating Manufacturer
Responsibilities(Does not manufacture the product and isrebranding the EPEAT-registered product under
its own brand)Continuous Monitoring

Must implement all Continuous Monitoring
activities assigned to them for all EPEAT
Criteria.

Must implement all Continuous Monitoring
activities assigned to them for the rebranded
products for all EPEAT Criteria except for thosethat do NOT have product disclosure
requirements. These Investigations or Annual
Renewal activities must be implemented by the
Original Participating Manufacturer.

Must take responsibility for Continuous
Monitoring Investigations assigned to theRebranding Participating Manufacturer for
products in the rebranding agreement and for
product Criteria that do not have disclosure
requirements.

Note:• If a Criterion that does NOT have productdisclosure requirements is assigned to theRebranding Participating Manufacturer, theCAB must inform the EPEAT Program within
five business days of receiving investigation
assignments. The EPEAT Program will thenreassign the investigation(s) to the Original
Participating Manufacturer.

Nonconformances
Related to Continuous
Monitoring

Responsible for correcting nonconformances
found from Continuous Monitoring activities
identified above.

Responsible for correcting nonconformances
found from Continuous Monitoring activities
identified above.

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Nonconformances Outside Continuous Monitoring
6.5.1

Nonconformances Identified by a CAB

During ongoing interactions with a Participating Manufacturer client that are outside of Continuous
Monitoring activities, a CAB may identify that an EPEAT-registered product is not in conformance withan EPEAT Criterion. The CAB must report this instance to the EPEAT Program.

Documentation Review

The CAB must notify the Participating Manufacturer that it has 30 calendar days in which to correct thenonconformance and restore accuracy to the Registry by either submitting evidence demonstrating
conformance or unselecting the nonconformant Criteria. The CAB must copy the EPEAT Program on theemail to the Participating Manufacturer.
CABs are responsible for reviewing the documentation and determining if the actions demonstrate
conformance as identified in Table 5 below. If the Participating Manufacturer does not respond to therequest for additional evidence, the affected product(s) must be archived or impacted criteria
unselected at the end of the 30-calendar day timeframe. For all nonconformances identified by a CAB
outside of Continuous Monitoring activities, the EPEAT Program may assign a Level 1 Investigation for
the impacted EPEAT Criterion(a) during a future Round.

6.5.2

Nonconformances Identified by EPEAT Program

During ongoing EPEAT conformity assurance activities outside of Continuous Monitoring activities or
EPEAT Audits of CABs, the EPEAT Program may discover that a Participating Manufacturer isnonconformant with one or more EPEAT Criteria. The EPEAT Program will notify the Participating
Manufacturer and their GEC-approved CAB of the nonconformance.
The Participating Manufacturer has 30 calendar days from the date of notification to correct thenonconformance and restore accuracy to the Registry by either submitting evidence demonstrating
conformance or unselecting the nonconformant Criteria.
CABs are responsible for reviewing corrective actions and supporting evidence and determining if theactions demonstrate conformance as identified in Table 5 below. If the Participating Manufacturer does
not respond to the request for additional evidence, the affected product(s) will be archived or impacted
criteria unselected at the end of the 30-calendar day timeframe. For all nonconformances identified
outside of Continuous Monitoring activities, the EPEAT Program may assign a Level 1 Investigation for
the impacted EPEAT Criteria during the next applicable Round.

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Table 5: Actions and Evaluation for Nonconformances Identified Outside Continuous Monitoring
Corrective Action Options for Participating
Manufacturers

Required Evaluation and Record Keeping by CABs

Participating Manufacturer unselects the EPEAT
Criterion.

The CAB confirms that the corrective action was taken and retains arecord of the corrective action process and the final correction
made.

Documentation Review

Participating Manufacturer removes thenonconforming product (“archives” the product).

The CAB must reinstate the requirement for Documentation Review
for the EPEAT Criterion.

Participating Manufacturer provides additional
evidence that demonstrates conformance.

The CAB reviews the new evidence and assesses if conformance isestablished.

Participating Manufacturer makes appropriatechanges to come into conformance and provides
evidence of implementing these changes to the CAB.

•

If conformance is established:o The EPEAT Criterion may remain selected, and product may
remain in as EPEAT-registered.
o The CAB may elect to not reinstate the requirement forDocumentation Review for the EPEAT Criterion if theParticipating Manufacturer has demonstrated competence(understanding of the Criterion’s requirements) during thecorrection process. The CAB must maintain record of why
this requirement was not reinstated.

•

If conformance is not established:o The CAB notifies the Participating Manufacturer that further
action must be taken (unselect Criterion or archive theproduct). If the Participating Manufacturer does not takeaction, the CAB is responsible for unselecting the criterionor archiving the product. If the CAB does not do this, the
EPEAT Program archives the product.
o The CAB must reinstate the requirement for Documentation
Review for the EPEAT Criterion.

The CAB retains a record of the corrective action process, allactivities conducted, and the final correction made.

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7.0 Continuous Monitoring
Overview

Continuous Monitoring

The EPEAT Program ensures the ongoing conformance of EPEAT-registered products through an ongoingsurveillance process known as Continuous Monitoring. Continuous Monitoring activities occur
throughout the year and test the ability of Participating Manufacturers to prove conformance with
EPEAT Criteria on an ongoing basis. All EPEAT-registered products in all product categories and all
Participating Manufacturers are subject to Continuous Monitoring, regardless of the conformity
assurance pathway used during Initial Documentation Review.
Continuous Monitoring occurs in the form of Investigations planned by the EPEAT Program andimplemented by GEC-approved CABs within discrete timeframes (Continuous Monitoring Rounds), or as
part of annual Documentation Review activities conducted by GEC-approved CABs for the Certification
Pathway (Annual Renewal). Only Qualified Auditors can conduct Continuous Monitoring activities. An
overview of Continuous Monitoring Activities is provided in Table 6 below.
Table 6: Continuous Monitoring Activities
Name

Investigative Methods Implemented
by GEC-approved CABS

Duration

Conformity
Assurance Pathway

Addressing
Nonconformances

Level 0Investigation

Review of publicly available
information without the Participating
Manufacturer’s involvement. Occurs
during Rounds.

14-calendar day
investigation
periodPriority Verification
and Certification

Level 1
Investigation

Review of evidence provided byParticipating Manufacturer. Must use
practices as identified inDocumentation Review (as per Sections
6.1 and 6.2). Occurs during Rounds.

60-calendar day
investigation
periodPriority Verification
and Certification

Nonconformances
must be corrected
in 30-calendar day
corrective action
periodLevel 2
Investigation

Laboratory evaluation of products.
Products acquired without Participating
Manufacturer’s involvement, where
possible. Products must be new (notrefurbished or repaired) and received
by the laboratory in the original
packaging. Occurs during Rounds.

150-calendar day
investigation
periodPriority Verification
and Certification

AnnualRenewalDocumentation Review of Corporate
Criteria with annual reporting
requirements. Review of product or
corporate changes to assess if ongoing
conformance is affected. Review ofminor revisions to EPEAT Criteria,
formal Clarifications, conformity
guidance and program documents toassess if additional documentation isneeded.

Duration varies
based on changes
but cannot exceed
Annual Renewal
deadline.

Certification

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Nonconformances
must be addressed
during Annual
Renewal period

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During Continuous Monitoring activities, Participating Manufacturers are required to cooperate with
their GEC-approved CAB and facilitate the review process. This includes:•

Reading applicable Criteria, verification requirements, and any supplementary information asnecessary (e.g., external materials referenced in a Criterion, Clarifications, or Conformity
Guidance Materials).

•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.

•

Responding to all questions from the GEC-approved CAB in a timely manner.

Continuous Monitoring

Throughout the remainder of Section 7, the use of the term “CAB” shall imply a GEC-approved CAB.

Continuous Monitoring Rounds
In September or October of each year, the EPEAT Program publishes an annual Continuous Monitoring
Round Schedule for the following year to allow GEC-approved CABs and Participating Manufacturers
time to prepare internal resources accordingly. The Schedule identifies the general timing of Rounds andthe investigative methods that must be used by CABs in each Round.
In the same timeframe, the EPEAT Program provides GEC-approved CABs with an estimated range of
how many Level 0 and Level 1 Investigations each of its Participating Manufacturer client will beassigned in the following year. CABs must pass this information onto each Participating Manufacturer
client.
The EPEAT Program also provides GEC-approved CABs with additional details on Level 2 investigations
for the following year (an estimated number of products and product types that will be examined). This
information is only made available to facilitate CAB resource planning. GEC-approved CABs cannot share
this information with Participating Manufacturer clients.
Continuous Monitoring Rounds include the following five phases:

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Preparation
Phase

The EPEAT Program develops Round materials, and CABs prepare for Round activities and receive
Continuous Monitoring Training. Timeframe is 28 calendar days.

Investigation
Phase

CABs actively conduct Investigations, make recommendations on conformity, and prepare draft Investigation
Reports. Participating Manufacturers may or may not be actively involved in the Investigations. If draft
Investigation Reports are submitted during this Phase, activities normally conducted in the Deliberation
Phase may occur. Timeframe dependent on type of investigative methods used.

Deliberation
Phase

A pre-established period in which the EPEAT Program reviews draft Investigation Reports and supporting
evidence and makes final decisions of conformity. CABs may be asked to revise a draft Investigation Reportor obtain additional information from their Participating Manufacturer and will be given five business days to
do so. Timeframe is 45 calendar days.

Corrective
Action Phase

Participating Manufacturers correct nonconformances found during Investigations and CABs review for
acceptability. Timeframe for development of corrections and corrective action plans is 30 calendar days.

ReportingPhase

The EPEAT Program prepares and publishes an Outcomes Report summarizing the Round results. Timeframe
is 14 calendar days.

All Continuous Monitoring timeframes identified in this document represent the minimum length oftime for the specific Round activities to occur. The EPEAT Program may extend or adjust Continuous
Monitoring Round schedules including when the Round is already underway. In such cases, the EPEAT
Program will provide an updated Round schedule and deadlines to those CABs with assigned
investigations.
Under exceptional force majeure circumstances, a Participating Manufacturer may request an extension
to a Continuous Monitoring Round phase. The Participating Manufacturer must submit a request in
writing to the EPEAT Program no later than 2 business days before the end of the phase, outlining therationale for the request and the requested length of extension. The EPEAT Program is solely
responsible for deciding whether to extend a Continuous Monitoring Round phase, and all decisions are
considered final.

7.2.1

Preparation Phase

The EPEAT Program develops an individual plan (Round Plan) for each Continuous Monitoring Round,which specifies the EPEAT Criteria to be investigated, the method of investigation that CABs must use,
and the specific dates when the Investigation activities must be completed. Round Plans identify specificdates that actions must occur, but do not specify a particular time zone. CABs are permitted to initiate
the Investigation and Corrective Action Phases of a Round on the date indicated in the time zone where
the CAB or its auditor(s) are located. In such cases, the end of the Investigation and Corrective Action
Phases must also occur in this same time zone. Where a report is due to the EPEAT Program, it must be
submitted by 11:59 pm North American Pacific Time on the given date. The EPEAT Program also selects
the Participating Manufacturers and EPEAT-registered products for investigation and creates“assignments” for each CAB during the Preparation Phase.
Specific Continuous Monitoring Round details are only provided at the time when the Round occurs.
Within three weeks of a Round launch, the EPEAT Program provides CABs with Investigation

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assignments, the Round Plan, reporting templates, and other supporting materials and provides
individual Continuous Monitoring Training for the CABs’ Qualified Auditors (see Tables 6, 7 and 8 in
Section 7.2.2 for timing). For Level 2 Investigations, the EPEAT Program provides CABs with a laboratory
report template that identifies expectations for what types of visual inspection and/or testing are
required.

Continuous Monitoring

Prior to the start of the Investigation Phase, CABs may discuss assigned Investigations internally with
their Qualified Auditors but can only inform Participating Manufacturer clients on the date identified by
the EPEAT Program (see Tables 6, 7 and 8 in Section 7.2.2 for timing). If a CAB informs or notifies a
Participating Manufacturer about Continuous Monitoring Round details before the start of the Round,
the CAB must immediately notify the EPEAT Program. The EPEAT Program will determine appropriate
action, which may include cancelling the impacted Investigation, or assigning a different product orCriterion for investigation for that Participating Manufacturer.
After the Investigative Phase begins, the EPEAT Program publishes the Round Plan and informs
stakeholders that the Round has officially launched.

7.2.2

Investigation Phase

Each CAB is responsible for conducting all assigned Investigations using the identified method ofinvestigation and meeting all deadlines outlined in the Round Plan. For Level 0 Rounds, Participating
Manufacturers are only notified of Level 0 Investigations after the EPEAT Program makes the final
conformity decision. For Level 1 Rounds, CABs must notify affected Participating Manufacturer clients of
the Investigations on the start date of the Round and are permitted to do so on that date in their local
time zone. (In such cases, the end of the investigation period must also occur in this same time zone.)
CABs are encouraged to ask the EPEAT Program questions about applicable Criteria or Round logistics
and raise any issues or concerns at any time during the Round.
For Level 2 Rounds, CABs must obtain a brand new product, in the original packaging, and inform the
EPEAT Program when the product(s) has been obtained for testing. Returned, repaired, or refurbishedproducts and products not in the original packaging are not permitted for Level 2 testing. If the
product(s) has not been obtained for testing within 30 calendar days of the launch of the Investigation
Phase, CABs must inform the EPEAT Program. In this situation, the EPEAT Program may instructs the CAB
to directly contact the Participating Manufacturer to obtain the product. The Participating Manufacturer
then becomes responsible for ensuring the product is received by the laboratory chosen by the CAB for
testing.
At the conclusion of the Investigations, CABs submit draft Investigation Reports (using the template
provided by the EPEAT Program) and all supporting evidence collected during the Investigations (e.g.,laboratory reports, certificates, procedural documents, etc.) to the EPEAT Program by 11:59 pm North
American Pacific Time on the deadline date identified. Draft Investigation Reports must include a
recommendation on conformity and a clear rationale to support the recommendation. CABs ensure thatdraft Investigation Reports do not contain references to the Participating Manufacturer or product thatwas investigated to facilitate impartial review of the reports by the EPEAT Program.

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Continuous Monitoring

If 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 request approval from the EPEAT
Program to submit the Investigation Report(s) past the deadline. The EPEAT Program will evaluate therequest and may extend the deadline. Where a CAB fails to submit a draft Investigation Report by thedeadline without notifying and obtaining approval from the EPEAT Program in advance, or where the
EPEAT Program denies a request for an extension, the EPEAT Program reserves the right to take any of
the following actions: notify the Participating Manufacturer directly of the outstanding report(s), cancel
the Investigation with possible reassignment in a future Round, and/or automatically assign anonconformance.
As per Section 7.2.3, the EPEAT Program reviews draft Investigation Reports and evidence as soon as
possible after received and may ask questions or seek clarity from CABs. Therefore, CABs areencouraged to submit draft Investigation Reports as soon as possible after collecting all appropriate
evidence from the Participating Manufacturer and completing all investigative activities. A CAB may berequired to seek additional evidence or rewrite sections of an Investigation Report. In these cases, theCAB has the remainder of the Investigation Phase to collect additional evidence from the Participating
Manufacturer and resubmit the draft Investigation Report before the original deadline for Reportsubmission.
If a CAB revises a draft Investigation Report for Level 1 and 2 investigations, the CAB must send therevised draft to the investigated Participating Manufacturer within five business days of submission to
the EPEAT Program. Level 0 Investigation Reports are only provided to Participating Manufacturers after
the EPEAT Program makes all final decisions of conformity for that Round.
For recommendations of nonconformance, CABs must identify the high-level reason for thenonconformance in the Investigation Report:
Demonstrated
Nonconformance

Evidence definitively shows the EPEAT Criteria are not met.

Insufficient Evidence to
Demonstrate Conformance

Evidence provided by a Participating Manufacturer in a Level 1 Investigation is incomplete
and does not definitively show either conformance or nonconformance.

No Documentation
ProvidedParticipating Manufacturer has not provided any supporting evidence or documentation
during the investigation period for a Level 1 Investigation.

Product Not Obtained
for Testing

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The CAB was unable to obtain the selected product within the 150-calendar day investigation
period of a Level 2 Investigation.

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CABs must also identify in the Investigation Reports if nonconformances are due to a minor error (seethe table below and Annex 1 for additional guidance).
Minor Error

The four cases where nonconformances can be categorized as a minor error are:
•
•
•

•

Continuous Monitoring

Nonconformance

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 the Participating Manufacturer during a Level 1
Investigation where the Participating Manufacturer indicated the product has reached
end-of-life and is no longer available on the market.
A CAB is unable to obtain a product from the market during a Level 2 Investigation where
the Participating Manufacturer indicated the product has reached end-of-life and is nolonger available on the market.

All nonconformances that do not meet the definition of minor error must be categorized as anonconformance. This specifically includes, but is not limited to, the following:••

No response to a request for documentation or no documentation provided during theinvestigation period of a Level 1 Investigation (except for when the Participating
Manufacturer indicated the product is end-of-life and no longer available on the market).
All nonconformances found in Level 2 Investigations (except for when the CAB was
unable to obtain the product for evaluation by a laboratory and the Participating
Manufacturer indicated the product has reached end-of-life and is no longer available on
the market).

For some Level 1 and 2 Investigations, CABs must also provide the draft Investigation Reports with theirrecommendations on conformity to the Participating Manufacturers (see Tables 7, 8 and 9).
Tables 7, 8 and 9 below provide further details and requirements for implementing Continuous
Monitoring Investigations.

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Table 7: Level 0 Investigation Activities(also see flowchart in Annex 2)
Topic

Requirements and Additional Details

Applicable conformity assurance
pathway(s)Priority Verification and Certification

Investigative methods used by CABs during
investigation period

Qualified Auditors evaluate publicly available information for conformance
to assigned EPEAT Criteria or aspects of EPEAT Criteria (the EPEAT Program
may elect not to have all requirements in the Criteria investigated). CABs
are prohibited from requesting information or clarification from
Participating Manufacturers.

Continuous Monitoring

If the product was assessed during Initial Documentation Review throughthe Certification Pathway, CABs may use a valid certificate for a
Participating Manufacturer’s product as evidence of conforming with
EPEAT Criteria.
If a Participating Manufacturer switches to the Certification Pathway andcompletes the Initial Documentation Review for the product during theRound’s investigation period, the CAB may use a valid certificate for a
Participating Manufacturer’s product as evidence of conforming with
EPEAT Criteria.
CABs notify Participating Manufacturers ofInvestigations

Prohibited. Participating Manufacturers are only notified of Level 0
Investigations after the EPEAT Program makes the final conformity
decision.

Recommendations by CABs

May be Conformance, Nonconformance, or Inconclusive.
CABs recommend Inconclusive if publicly available information could not
be found or did not provide enough details to determine conformance.

Nonconformance categories

CABs must choose either minor error or nonconformance as per theguidance in Section 7.2.2 and Annex 1.

Assignments and Round documents to CABs

21 calendar days before the Round Launch Date

Continuous Monitoring Training by EPEAT

7 calendar days before the Round Launch Date

Length of investigation period

14 calendar days

Draft Investigation Reports (withrecommendation on conformity) andevidence due from CABs to EPEAT

14 calendar days after the end of the investigation period, but CABs areencouraged to submit investigation reports as they are completed. Reports
must be submitted no later than 11:59 pm North American Pacific Time on
the deadline date.
If a CAB does not submit a draft Investigation Report by the deadline
without notifying the EPEAT Program of a delay at least 24 hours before
the reports are due, the EPEAT Program reserves the right to take further
action [notify the Participating Manufacturer directly of the outstanding
report(s), cancel the Investigation with possible reassignment in a future
Round, and/or automatically assign a nonconformance for theinvestigation]. The EPEAT Program tracks the submission of lateInvestigation Reports for CAB performance metric 9.

Draft Investigation Reports (same as
submitted to EPEAT) sent to Participating
Manufacturers by CABs

Global Electronics Council

Prohibited. Investigation Reports can only be sent to Participating
Manufacturers after the EPEAT Program makes the final decision on
conformity.

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Table 8: Level 1 Investigation Activities(also see flowchart in Annex 3)
Topic

Requirements and Additional Details

Applicable conformity assurance pathway(s)Priority Verification and Certification

Investigative methods used by CABs during
investigation period

Qualified Auditors request evidence from Participating Manufacturers andevaluate it for conformance to assigned EPEAT Criteria.

Continuous Monitoring

If the product was assessed during Initial Documentation Review throughthe Certification Pathway, CABs may use a valid certificate for a
Participating Manufacturer’s product as evidence of conforming with
EPEAT Criteria.
If a Participating Manufacturer switches to the Certification Pathway andcompletes the Initial Documentation Review for the product during theRound’s investigation period, the CAB may use a valid certificate for a
Participating Manufacturer’s product as evidence of conforming with
EPEAT Criteria.
CABs notify Participating Manufacturers ofInvestigations

CABs must notify Manufacturers in writing (e.g., by e-mail) on the Round
Launch Date identified by the EPEAT Program. CABs are permitted to notify
Manufacturers on the Round Launch Date in their own local time zone.

Recommendations by CABs

May be Conformance, Nonconformance or Inconclusive

Nonconformance categories

CABs must choose either minor error or nonconformance as per theguidance in Section 7.2.2 and Annex 1.
CABs must assign a nonconformance if there was no response or no
documentation received from the Participating Manufacturer during theInvestigation Period.
CABs must categorize a nonconformance as a minor error if theParticipating Manufacturer indicated the product has reached end-of-lifeand is no longer available on the market.

Assignments and Round documents to CABs

21 calendar days before the Round Launch Date

Continuous Monitoring Training by EPEAT

7 calendar days before the Round Launch Date

Length of investigation period

60 calendar days

Draft Investigation Reports (withrecommendation on conformity) andevidence due from CABs to EPEAT

14 calendar days after the end of the investigation period, but CABs areencouraged to submit investigation reports as they are completed.
Reports must be submitted no later than 11:59 pm North American PacificTime on the deadline date.
If a CAB does not submit a draft Investigation Report by the deadline
without notifying the EPEAT Program of a delay at least 24 hours before
the reports are due, the EPEAT Program reserves the right to take further
action [notify the Participating Manufacturer directly of the outstanding
report(s), cancel the Investigation with possible reassignment in a future
Round, and/or automatically assign a nonconformance for theinvestigation]. The EPEAT Program tracks the submission of lateInvestigation Reports for CAB performance metric 9.

Draft Investigation Reports (same as
submitted to EPEAT) sent to Participating
Manufacturers by CABs

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Within 5 business days of submission to the EPEAT Program

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Table 9: Level 2 Investigation Activities

Continuous Monitoring(also see flowchart in Annex 4)
Topic

Requirements and Additional Details

Applicable conformity assurance
pathway(s)Priority Verification and Certification

Investigative methods used by CABs during
investigation period

CABs obtain products from the marketplace without Participating
Manufacturer involvement. CABs may research where products areavailable on the open market before the Round launch date but products
cannot be purchased before the Round launch date. If unable to do obtain
the product in the marketplace within 30 calendar days (e.g., products are
not commercially available or only sold through contracts), CABs notify the
EPEAT Program and must then obtain the product directly from theParticipating Manufacturer, where the Participating Manufacturer
becomes responsible for ensuring the product is received by thelaboratory.
Products are then evaluated by independent laboratories for conformance
to assigned EPEAT Criteria or aspects of EPEAT Criteria (the EPEAT Program
may elect not to have all requirements in the Criteria investigated). CABs
are not permitted to obtain information or documentation from theParticipating Manufacturer unless specified by the EPEAT Program in thelaboratory report template or with written approval from the EPEAT
Program to do so.

When products cost US $10,000 or more

CABs may work with the EPEAT Program and the Participating
Manufacturer to find an alternate way to verify conformance to theidentified Criteria. The approach will depend on the Criteria, and the EPEAT
Program may offer suggestions on alternate ways to verify conformance(e.g., provision of high-risk components or materials for testing, onsite
inspection of the product).

Laboratory requirements

Laboratories must have valid accreditation to ISO/IEC 17025 from a bodythat is an ILAC Member and signatory to the ILAC Mutual Recognition
Arrangement (ILAC MRA). CABs must confirm that the evaluation methods
are covered by the laboratory’s accreditation scope or, for non-standard
methods of evaluation, by other mechanisms or best practices to produce
accurate and reliable results.

CABs notify Participating Manufacturers ofInvestigations

After the product has been received by the laboratory OR when CABs mustreach out to Participating Manufacturers because the products could not
be found in the market.

Recommendations by CABs

May be Conformance, Nonconformance or Inconclusive.
If unable to obtain the product within the 150-calendar day investigation
period, CABs automatically recommend nonconformances for all EPEAT
Criteria investigated. This will be identified in the Outcomes Report.
CABs may recommend Inconclusive when Conformance orNonconformance cannot be determined due to limitations in theevaluation technique(s).

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Table 9: Level 2 Investigation Activities

Continuous Monitoring(also see flowchart in Annex 4)
Nonconformance categories

CABs must identify all nonconformances as nonconformances. Exception: if
the CAB is unable to obtain the product and the Participating Manufacturer
indicated the product has reached end-of-life and is no longer available on
the market, the CAB must identify the nonconformance as a minor error.

Assignments and Round documents to
CABs

14 calendar days before the Round Launch Date

Continuous Monitoring Training by EPEAT

7 calendar days before the Round Launch Date

Length of investigation period

150 calendar days

Draft Investigation Reports (withrecommendation on conformity) andevidence due from CABs to EPEAT

14 calendar days after the end of the investigation period. CABs must also
send the laboratory reports at the same time. CABs are encouraged tosubmit investigation reports as they are completed. Reports must be
submitted no later than 11:59 pm North American Pacific Time on thedeadline date.
If a CAB does not submit a draft Investigation Report by the deadline
without notifying the EPEAT Program of a delay at least 24 hours before
the reports are due, the EPEAT Program reserves the right to take further
action [notify the Participating Manufacturer directly of the outstanding
report(s), cancel the Investigation with possible reassignment in a future
Round, and/or automatically assign a nonconformance for theinvestigation]. The EPEAT Program tracks the submission of lateInvestigation Reports for CAB performance metric 9.

Draft Investigation Reports (same as
submitted to EPEAT) sent to Participating
Manufacturers by CABs

7.2.3

Within 5 business days of submission to the EPEAT Program. CABs mustalso send the laboratory reports at the same time.

Deliberation Phase

During the 45-calendar day Deliberation Phase, the EPEAT Program reviews the Draft Investigation
Reports and supporting evidence submitted by CABs for completeness and the rationale to support
recommendations of conformity and makes the final decisions on conformity.
The EPEAT Program reviews draft Investigation Reports and evidence as soon as possible after received.
The EPEAT Program first reviews draft Investigation Reports, and where applicable, laboratory reports,
which do not identify the Participating Manufacturer or product investigated, to ensure that all Criterion
elements have been reviewed during the Investigation Phase and a recommendation has been made by
the CAB. Only after reviewing the Investigation Report does the EPEAT Program review the submitted
evidence to make the final conformity decision. This process is implemented to facilitate impartial
review of the reports by the EPEAT Program.
The EPEAT Program may ask questions or seek clarity from CABs.
•A CAB may be required to seek additional evidence or rewrite sections of a draft Investigation
Report. In these cases, the CAB has five business days to update the draft Investigation Report

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Continuous Monitoring

and resubmit it and allowable additional evidence to the EPEAT Program. Failure to makeappropriate updates will be reflected in the CAB’s performance metrics (see Section 5.3). For
Level 1 and Level 2 Investigations, the CAB must provide the Participating Manufacturer a copyof the revised draft Investigation Report within five business days of submitting it to the EPEAT
Program. Level 0 Investigation Reports are only provided to Participating Manufacturers after
the EPEAT Program makes all final decisions of conformity for that Round.
•

If the EPEAT Program has follow-up questions, an additional five business days may beprovided for the CAB to address questions or revise the Investigation Report.

•

If a CAB is unable to complete the update within the five business days, it must inform the
EPEAT Program and propose an alternative timeline and the EPEAT Program may grant an
extension. Where a CAB fails to submit a revised draft Investigation Report by the deadline
provided, the EPEAT Program reserves the right to take any of the following actions: notify theParticipating Manufacturer directly of the outstanding report(s), cancel the Investigation withpossible reassignment in a future Round, make a final decision based on the information thatwas originally provided, and/or automatically assign a nonconformance.

EPEAT final decisions on conformity may be Conformance, Nonconformance or Inconclusive. For
inconclusive findings in Level 0 and Level 2 Investigations, the EPEAT Program may require the CAB toinvestigate the same Criterion in a subsequent Level 1 Round to definitively determine conformance.

7.2.4

Corrective Action PhaseAt the start of the Corrective Action Phase, the EPEAT Program sends the Investigation Reports with thefinal conformity decisions to the CABs. If the final decision is Conformance, the Investigation Report isconsidered final, and the Investigation is closed. If the final decision is nonconformance, theInvestigation moves into the Corrective Action Phase.
CABs must distribute the Investigation Reports with the final decision on conformity to Participating
Manufacturer clients on the date identified by the EPEAT Program (and may do so based on the date intheir own local time zone). CABs are prohibited from distributing these reports earlier than the dateidentified by EPEAT in their local time zone.
7.2.4.1

Investigated Products

For both minor errors and nonconformances, Participating Manufacturers have 30 calendar days tomake corrections11 for investigated products and restore accuracy to the EPEAT Criteria selected (seeTables 9 and 10 for applicable options). CABs are responsible for reviewing corrections and supporting
evidence and determining if the corrections demonstrate conformance.
CABs update the Investigation Reports with a description of the corrections taken, the recommendationon acceptability, and a clear rationale to support the recommendation. The EPEAT Program makes the
final decision on the acceptability of corrections made by Participating Manufacturers for investigated11“Corrections” are the immediate actions that must be taken by the Participating Manufacturer to correct
nonconformances. Corrections must be completed within the 30-calendar day period.

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products. If the EPEAT Program requires further clarification on the correction, CABs have until the endof the Corrective Action Phase, or if the Corrective Action Phase is completed, five business days to seek
additional evidence from the Participating Manufacturer, respond to questions and if necessary, submit
a revised Corrective Action Investigation Report.
When a Corrective Action Investigation Report (or revisions to the Report in response to EPEAT Program
questions) has not been received by the EPEAT Program by 11:59 pm North American Pacific Time on
the deadline provided, the EPEAT Program reserves the right to inform the affected Participating
Manufacturer that the Corrective Action Investigation Report is outstanding. The EPEAT Program also
reserves the right to make the final decision based on the information that was originally provided orarchive the investigated product.

Continuous Monitoring

7.2.4.2

Similarly Affected Products

In this same 30-calendar day Corrective Action Phase, Participating Manufacturers must also develop
corrective action plans12 for other EPEAT-registered products that may be affected by the sameunderlying issue causing the minor error or nonconformance but were not the subject of investigation(called “similarly affected products”). Participating Manufacturers must provide their CABs with a list of
the similarly affected products, if applicable, and the corrective action plans, which must identify thesteps that will be taken to address the underlying issue and the timeframe for implementation. The
maximum allowable timeframe for implementation of corrective action plans is six months.
The EPEAT Program does not provide final approval of Participating Manufacturers’ corrective actionplans for similarly affected products. CABs are responsible for reviewing and approving these plans andupdating the Investigation Reports with a summary of the plans (actions and timeframes) and an
indication of approval. CABs are expected to follow-up with Participating Manufacturer clients to ensure
the plans are fully implemented in the identified timeframe. If the Participating Manufacturer does not
implement the corrective action plan to address similarly affected products, the CAB may archive theaffected products. The EPEAT Program may require CABs to submit evidence of effective
implementation of corrective action plans and/or review corrective action plans for similarly affected
products during the Annual EPEAT Audit of CABs.
7.2.4.3

Reinstatement of Requirement for Documentation Review:

For nonconformances, CABs may be required to reinstate the requirement for Documentation Review
for the investigated EPEAT Criterion (see Tables 10 and 11 for requirements on reinstatement). The
relevant steps for Documentation Review (see Section 6.1) must then be followed to remove theDocumentation Review Requirement for that EPEAT Criterion.

12“Corrective action plans” are the actions and timelines that the Participating Manufacturer must develop to
address and eliminate the root cause(s) of a nonconformance so as to prevent reoccurrence for other productsthat are also affected by the nonconformance assigned to the investigated product. The corrective action plan
must be developed in the 30-calendar day period; however, implementation of the plan may take longer.
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Table 10: Corrections for Nonconformances (Level 0, 1 and 2 Investigations)
Correction Options for Participating
Manufacturers

Required Evaluation by CABs

Participating Manufacturer unselects the EPEAT
Criterion.

The CAB confirms the correction was made by the Participating
Manufacturer and updates the Investigation Report to identify thecorrection made, the recommendation on acceptability and therationale for the recommendation.

Continuous Monitoring

Participating Manufacturer removes thenonconforming product (“archives” the product).
When archiving a product on the EPEAT Registry,
the user must enter the reason for archival as“product found nonconformant in continuous
monitoring activities (Round)”.

Participating Manufacturer provides additional
evidence that demonstrates conformance. Thiscan only include new evidence that was notprovided during the investigation period.

The CAB must reinstate the requirement for Documentation Review
for the EPEAT Criterion. Exception: The Participating Manufacturer
also corrects the underlying issue for similarly affected products
during the 30-calendar day Corrective Action Phase and thiscorrection shows the Participating Manufacturer has demonstrated
competence (understanding of the Criterion’s requirements). In suchcases, the CAB must maintain a record of why this requirement was
not reinstated.
The CAB reviews the new evidence and assesses if conformance isestablished.
•

If conformance is established:o The EPEAT Criterion may remain selected, and product may
remain EPEAT-registered.
o The CAB may elect to not reinstate the requirement forDocumentation Review for the EPEAT Criterion if theParticipating Manufacturer has demonstrated competence(understanding of the Criterion’s requirements) during thecorrection process. The CAB must maintain a record of why
this requirement was not reinstated.

•

If conformance is not established:o The CAB notifies the Participating Manufacturer that further
action must be taken (unselect Criterion or archive theproduct). If the Participating Manufacturer does not takeaction, the CAB is responsible for archiving the product. If the
CAB does not do this, the EPEAT Program archives the
product.
o The CAB must reinstate the requirement for Documentation
Review for the EPEAT Criterion.

Participating Manufacturer makes appropriatechanges to come into conformance and provides
evidence of implementing these changes to the
CAB. These changes may be to the investigatedproduct or to corporate practices.

The CAB updates the Investigation Report with details on thecorrection made and evidence submitted, the recommendation on
acceptability and the rationale for the recommendation.
Corrective Action Phase Activity

Timeframe

Corrective action period (timeframe in whichcorrection must be made and reviewed)

30 calendar days

Investigation Reports (with recommendations oncorrection acceptability) and evidence due from
CABs to EPEAT

14 calendar days after the end of the corrective action period. CABs
are not required to send these Reports to Participating
Manufacturers but may do so if they wish.

Final Investigation Reports (with final decisions
on corrections) sent to CABs by EPEAT

28 calendar days after the end of the corrective action period

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Table 10: Corrections for Nonconformances (Level 0, 1 and 2 Investigations)
Correction Options for Participating
Manufacturers
Final Investigation Reports (with final decisions
on corrections) sent to Participating
Manufacturer by CABs

Required Evaluation by CABs
Within 5 business days of receiving Final Investigation Reports fromthe EPEAT Program

Continuous Monitoring

Table 11: Corrections for Minor Errors (Level 0, 1 and 2 Investigations)
Correction Options for Participating Manufacturers

Required Evaluation by CABs

If the product is end-of-life and no longer available inthe market, Participating Manufacturer must remove(“archive”) the product. When archiving a product on
the EPEAT Registry, the user must enter the reason
for archival as “product found nonconformant inContinuous Monitoring activities (Round)”.

The CAB confirms that the correction was made by theParticipating Manufacturer (the end-of-life product was archived,or the evidence indicates the minor error was corrected andconformity re-established). In these cases, the CAB is not
required to reinstate the Documentation Review requirement
but may elect to do so.

Participating Manufacturer corrects the minor humanor administrative error and provides evidence of thecorrection to the CAB. Examples of corrections
include but are not limited to:If the Participating Manufacturer does not take the appropriate
action, the CAB is responsible for archiving the product. If the
CAB does not do this, the EPEAT Program archives the product. In
these cases, the CAB must reinstate the requirement forDocumentation Review for the EPEAT Criterion.

•••

Updating a value that was insignificantly
above/below the actual value.
Fixing a broken URL.
Providing updated certificates or reports.

The CAB updates the Investigation Report with details on thecorrective actions taken, the recommendation on acceptability
and the rationale for the recommendation.

Corrective Action Phase Activity

Timeframe

Corrective action period (timeframe in whichcorrection must be made and reviewed)

30 calendar days

Investigation Reports (with recommendations oncorrection acceptability) and evidence due from CABs
to EPEAT

14 calendar days after the end of the corrective action period.
CABs are not required to send these Reports to Participating
Manufacturers but may do so if they wish.

Final Investigation Reports (with final decisions oncorrections) sent to CABs by EPEAT

28 calendar days after the end of the corrective action period

Final Investigation Reports (with final decisions oncorrections) sent to Participating Manufacturer by
CABs

Within 5 business days of receiving Final Investigation Reports
from the EPEAT Program

7.2.5

Reporting Phase

Investigation Reports are not made public. Fourteen calendar days after completion of the Corrective
Action Phase and the close of all Investigations, the EPEAT Program publishes an Outcomes Report. For
each Continuous Monitoring Round, the Outcomes Report summarizes Round activities, identifies the
EPEAT Criteria investigated and the method of investigation, and highlights overall conformity results
and trends.

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Outcomes Reports also identify the names of products and Participating Manufacturers that received
nonconformances and how corrections were made to restore accuracy to the EPEAT Registry. Because
minor errors are generally clerical in nature and do not materially affect the validity of products in the
EPEAT Registry, minor errors are not disclosed in the Outcomes Report. Outcomes Reports do not
identify the names of products and Participating Manufacturers that received Inconclusive findings.

Annual Renewal

Continuous Monitoring

Annual Renewal is a form of Continuous Monitoring performed by CABs on products that used theCertification Pathway for Initial Documentation Review. In the Certification Pathway, results from Initial
Documentation Review are valid for a three-year period with the proviso that CABs perform Annual
Renewal activities to confirm ongoing conformance. During the second and third years of this period,
CABs must work with Participating Manufacturer clients to:•

Ensure Participating Manufacturer ongoing conformance with selected EPEAT Criteria, whichhave annual reporting requirements at the corporate level.

•

Ensure Participating Manufacturer conformance with Minor Criteria Revisions and Major
Criteria Revisions that have been released in the previous 12-month period.

•

Assess the impact of Participating Manufacturer changes to the product or corporate activities
on conformance with EPEAT Criteria and where necessary, evaluate if new evidence supports
conformance.

•

Assess the impact of updated EPEAT Program requirements and guidance on conformancewith EPEAT Criteria and where necessary, evaluate if new evidence supports conformance.

The timing of Annual Renewal activities is determined by the date each product first completed Initial
Documentation Review for all selected criteria using the Certification Pathway. For the second and thirdyears, Annual Renewal activities must be completed prior to that year’s anniversary of completion of theInitial Documentation Review activities.

7.3.1

Criteria with Corporate Level Annual Reporting Requirements

Participating Manufacturers must provide evidence demonstrating continued conformance with EPEAT
Criteria that were selected as part of Initial Documentation Review and have annual performance,
reporting or other disclosure requirements at the corporate level. A list of the applicable EPEAT Criteria
for each product category is maintained by the EPEAT Program and available to CABs and Participating
Manufacturers. CABs review the evidence in accordance with Documentation Review practices
identified in Sections 6.1 and 6.2.

7.3.2

Minor and Major Criteria Revisions

In the 12-month period preceding Annual Renewal activities, the EPEAT Program may release Minor or
Major Revisions to EPEAT Criteria (see Table 3 for a description of these revisions). CABs must determine
if additional evidence is needed from Participating Manufacturer clients to demonstrate conformancewith the changes to EPEAT Criteria. CABs must keep records of how this determination was made.

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Where necessary, CABs obtain and review the additional evidence in accordance with Documentation
Review practices identified in Sections 6.1 and 6.2.

7.3.3

Product and Corporate Changes

Continuous Monitoring

CABs must work with Participating Manufacturer clients to identify any changes that occurred in theprevious 12-month period, which may affect conformance with selected EPEAT Criteria (including thosethat address attributes of the product and those that address corporate activities of the Participating
Manufacturer). Changes may include but are not limited to:•

Product design or packaging.

•

Materials and components.

•

Manufacturing and assembly processes.

•

Suppliers and supply chain performance.

•

Environmental management systems.

•

Third-party certifications.

•

Participating Manufacturer operating procedures and/or conformance assurance processes.

•

Services or support programs offered by the Participating Manufacturer to purchasers.

•

Information on the product that is made publicly available by the Participating Manufacturer.

If one or more changes have the potential to affect conformance with EPEAT Criteria, CABs obtain andreview new evidence from the Participating Manufacturers in accordance with Documentation Review
practices identified in Sections 6.1 and 6.2.

7.3.4

Updates to EPEAT Program Requirements and GuidanceOver the previous 12-month period, the EPEAT Program may release new Clarifications, make updates
to Conformity Guidance Materials and/or update requirements in P66 EPEAT Conformity Assurance
Implementation Manual. The updated guidance and requirements may include changes to acceptable
forms of evidence, new details in the evidence that must be assessed, and/or additional requirements
for conformity assurance-related processes.
CABs are responsible for determining if any of the guidance or programmatic updates have the potential
to impact Participating Manufacturer conformance with EPEAT Criteria or how conformance was first
determined for Participating Manufacturer clients. CABs must keep records of how this determination
was made.
Where necessary, CABs obtain and review the additional evidence in accordance with Documentation
Review practices identified in Sections 6.1 and 6.2.

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7.3.5

Nonconformances and Corrections

If Annual Renewal activities confirm the Initial Documentation Review results and the EPEAT Criteria
selected by Participating Manufacturers, the EPEAT Criteria may remain selected, and the product may
remain EPEAT-registered.

Continuous Monitoring

If Annual Renewal activities do not confirm the Initial Documentation Review results, CABs are
responsible for communicating the nonconformance to its Participating Manufacturer.
Nonconformances may arise from Participating Manufacturers:•

No longer meeting the requirements of EPEAT Criteria that have annual reporting
requirements at the corporate level.

•

Not meeting Minor or Major Criteria Revisions released in the previous 12 months.

•

No longer meeting one or more EPEAT Criteria due to changes made to the product and/or
corporate activities or due to revised EPEAT Program guidance or requirements.

All nonconformances found in Annual Renewal must be corrected by Participating Manufacturers prior
to that year’s anniversary of the product registration date. CABs are responsible for reviewing andapproving these corrections.
If appropriate corrections are not made by the Participating Manufacturer, the CAB notifies theParticipating Manufacturer that action must be taken (unselecting the applicable EPEAT Criteria orarchiving the product). If the Participating Manufacturer does not take action, the CAB is responsible forarchiving the product and must notify the EPEAT Program. If the CAB does not archive the product, the
EPEAT Program takes this action.

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8.0 Changing CABs
At any time, Participating Manufacturers may change from using one GEC-approved CAB to a different
CAB for any given product category. Participating Manufacturers may change CABs for one or moreproduct categories but must transfer all products in the product category to the new CAB. Participating
Manufacturers must maintain a contractual relationship with at least one GEC-approved CAB during thetransition process to address ongoing conformity assurance activities such as Continuous Monitoring.

Changing CABs

A Participating Manufacturer must notify the EPEAT Program of their intention to change to a new GECapproved CAB a minimum of 60 calendar days prior to the change. The new GEC-approved CAB must
provide the EPEAT Program with written acceptance of the Participating Manufacturer as a new client.
Participating Manufacturers must undergo Initial Documentation Review for all active products in eachproduct category being moved to the new CAB. The new CAB is responsible for conducting these
activities in accordance with Section 6 to evaluate the Participating Manufacturer’s conformance withand competence against EPEAT Criteria. This includes collecting and evaluating evidence of conformancefor selected EPEAT Criteria. The new CAB must inform the EPEAT Program when Initial Documentation
Review begins and provide a status update every 30 calendar days thereafter until Initial Documentation
Review activities are completed.
For each conformity assurance pathway, the new GEC-approved CAB must use the appropriate productsampling processes for Initial Documentation Review and is required to review specific EPEAT Criteria as
per the following:
Priority Verification Pathway

Certification Pathway

The new CAB must complete Initial Documentation Review of all Priority Required
Criteria before the Participating Manufacturer’s products can appear as EPEATregistered under the new CAB’s conformity assurance services. As per Section 6,
any product sampling technique must be applied across all active EPEAT-registeredproducts if choosing representative products for evaluation. Within 12 months ofthe products appearing under the new CAB, Documentation Review of all selected
Optional Criteria (both Priority and non-Priority) must be completed, or the Criteria
must be unselected, or the products archived until this Review is completed. Any
new Optional Criteria previously not selected by the Participating Manufacturer
must be successfully reviewed before appearing in the EPEAT Registry.

The new CAB must complete Initial
Documentation Review for all
EPEAT Criteria and locations of use(countries) selected by theParticipating Manufacturer before
the products can appear as EPEATregistered under the new CAB’s
conformity assurance services.

The new CAB must notify the EPEAT Program when the Initial Documentation Review is complete, atwhich point the EPEAT Program will change the Participating Manufacturer’s CAB of record in the EPEAT
Registry to the new CAB. Once products appear as EPEAT-registered under the new CAB’s conformity
assurance services, the transition process is considered complete, and the new CAB takes full
responsibility for all required conformity assurance activities including Ongoing Documentation Review
and any new Continuous Monitoring activities.
Until the transition process is complete, the existing CAB is still considered the CAB of record and is
responsible for fulfilling all conformity assurance activities for the Participating Manufacturer. If the

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Changing CABs

transition process is completed during an active Continuous Monitoring Round, the EPEAT Program will
work with the Participating Manufacturer and both old and new CABs to determine how best totransition the investigative activities to the new CAB.

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9.0 Complaints and Appeals
For the purposes of this document (EPEAT Conformity Assurance Implementation Manual P66),
complaints and appeals referenced in Section 9 are only related to conformity assurance activities,
recommendations, and decisions for the EPEAT Conformity Assurance System. GEC organizational
activities continue without limitation during an investigation into a complaint or appeal, unlessotherwise identified in Section 9.

Complaints and Appeals

A complaint is a written expression of dissatisfaction related to conformity assurance activities,
recommendations, or decisions, other than an appeal, submitted to a GEC-approved Conformity
Assurance Body or the EPEAT Program by any person or organization.
An appeal is a written request for reconsideration of a conformity recommendation or decision basedon either procedural or technical grounds. Appeals can be made to GEC-approved Conformity Assurance
Bodies or the EPEAT Program. Appeals may only be lodged by Participating Manufacturers or GECapproved CABs.
GEC-approved CABs must have procedures in place that identify how all complaints and appeals will be
managed. Upon receiving a complaint or appeal, a GEC-approved CAB must acknowledge receipt,
conduct a fair investigation to resolve the issue, and ensure impartiality is maintained in theinvestigative process. All complaints and appeals must be addressed swiftly and transparently, tracked
internally, and not result in discriminatory actions.
Participating Manufacturers and GEC-approved CABs are strongly encouraged to raise conformity
assurance related questions and issues to the EPEAT Program as part of the ongoing conformity
assurance process. The EPEAT Program strives to resolve these through other processes and seeks to
avoid their escalation to formal complaints and appeals, wherever possible.

Complaints
9.1.1

Complaints Raised to CABs

A Participating Manufacturer may raise a complaint with its GEC-approved CAB if there is disagreement
regarding the CAB’s conformity decision made during Documentation Review, Continuous Monitoring
activities, or discoveries of nonconformances found outside of Continuous Monitoring. Complaints
regarding conformity decisions made during Documentation Review can only be raised after the final
CAB decision on conformity of the Criterion is made, not during the iterative Documentation Review
process that occurs between Participating Manufacturers and CABs.
The complaint must be submitted in writing to the CAB within 30 calendar days of receiving theconformity decision from the CAB or within the timeframe specified in the CAB’s complaints process,whichever is less. The CAB then shall follow its complaints process and keep appropriate records of theinvestigation conducted and how the complaint was resolved. The CAB’s complaints process shall beconcluded within 30 calendar days. GEC reserves the right to review such records during the Annual
EPEAT Audit of CABs. Complaints related to conformity decisions must be raised and resolved within

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these timeframes because they can impact the status of products on the EPEAT Registry as well as thecredibility of the EPEAT Program.
GEC-approved CABs may receive complaints that are not related to its Participating Manufacturer clients(e.g., complaints about non-client’s EPEAT-registered products, conformity decisions made by other
CABs, other conformity assurance activities). CABs must forward all such complaints to the EPEAT
Program and should not initiate an investigation regarding these issues unless explicitly instructed by
the EPEAT Program to do so. The EPEAT Program will determine the appropriate next steps and only
involve the CAB if warranted.

Complaints and Appeals

9.1.2

Complaints Raised to EPEAT Program

The EPEAT Program may receive a complaint from a Participating Manufacturer about its GEC-approved
CAB’s conformity decision made during Documentation Review or Continuous Monitoring activities. In
such cases, the EPEAT Program will require that the Participating Manufacturer first try to resolve thecomplaint directly with its CAB. If a Participating Manufacturer is not satisfied with the resolution of thecomplaint, then it may raise the issue directly to the EPEAT Program for further consideration. The
EPEAT Program strives to resolve such issues jointly with the Participating Manufacturer and CAB.
The EPEAT Program may receive a complaint from any stakeholder regarding the status of an EPEATregistered product, conformity decisions or recommendations, or other conformity assurance activities.
In such cases, the EPEAT Program may notify the applicable GEC-approved CAB and instruct the CAB toinitiate an investigation where appropriate. Within 30 calendar days of notification by the EPEAT
Program, the CAB must conduct the investigation following its complaints process, document the steps
taken, and communicate the outcome of the investigation to the EPEAT Program. If the investigation
results in a Participating Manufacturer being found nonconformant with one or more EPEAT Criteria, thesteps identified in Section 6.5 shall be followed.

Appeals
Appeals may be made on either procedural or technical grounds. Procedural appeals are made on the
grounds that a conformity recommendation or decision should be reconsidered because a required
internal or external process was not followed. Technical appeals are made on the grounds that a
conformity recommendation or decision should be reconsidered because a specified requirement was
not interpreted correctly. During technical appeals, the appellant cannot provide additional evidence
beyond what was supplied during the original conformity assurance activities.

9.2.1

Appeals Raised to CABs

9.2.1.1

Documentation Review

A Participating Manufacturer may appeal a GEC-approved CAB’s conformity decision made during
Documentation Review activities. The appeal must be submitted in writing to the CAB within 30
calendar days of receiving the conformity decision from the CAB or within the timeframe specified in the
CAB’s appeals process, whichever is less. Within five business days of receiving the appeal, the CAB must
determine if enough information has been provided to proceed with the appeal. The CAB then shall

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follow its appeal process and keep appropriate records of the investigation conducted and the final
decision on the appeal. The CAB’s appeals process shall be concluded within 30 calendar days. GEC
reserves the right to review records regarding the above appeals made to CABs during the Annual EPEAT
Audit of CABs.
9.2.1.2

Continuous Monitoring

Complaints and Appeals

A Participating Manufacturer may appeal a GEC-approved CAB’s recommendation of nonconformanceor unacceptable corrections for an Investigation in a Continuous Monitoring Round. The appeal must be
submitted in writing to the CAB, within 10 days of receiving the relevant draft Investigation Report fromthe CAB or within the timeframe specified in the CAB’s appeals process, whichever is less. Within fivebusiness days of receiving the appeal, the CAB must determine if enough information has been provided
to proceed with the appeal and inform the EPEAT Program of this decision.
•

If the appeal is proceeding, the EPEAT Program will postpone review of the relevant draft
Investigation Report until the CAB has concluded its appeals process. The CAB’s appeals
process shall be concluded within 30 calendar days.

•

Depending on the outcome of the appeal, the CAB may need to submit a revised Investigation
Report to the EPEAT Program. If required, the CAB must submit the revised Investigation
Report within 14 days of the conclusion of the appeals process.

•

Where corrective action is required following a CAB investigation into an appeal, the EPEAT
Program provides the CAB with new Corrective Action Phase deadlines if necessary. In thiscase, the appellant is still provided a 30-day Corrective Action period. Dissemination of EPEAT
corrective action decisions for all other investigations in the affected Round, as well as
publication of the Outcomes Report, may be delayed.

A Participating Manufacturer may appeal a GEC-approved CAB’s conformity decision made during
Annual Renewal activities conducted for the Certification Pathway. The appeal must be submitted inwriting to the CAB within 30 calendar days of receiving the conformity decision from the CAB or within
the timeframe specified in the CAB’s appeals process, whichever is less. Within five business days ofreceiving the appeal, the CAB must determine if enough information has been provided to proceed withthe appeal. The CAB then shall follow its appeal process and keep appropriate records of theinvestigation conducted and the final decision on the appeal. The CAB’s appeals process shall beconcluded within 30 calendar days.
GEC reserves the right to review records regarding the above appeals made to CABs during the Annual
EPEAT Audit of CABs.

9.2.2

Appeals Raised to EPEAT Program

9.2.2.1

EPEAT Audits of CABs

A Provisional CAB may appeal one or more nonconformance findings in their Initial EPEAT Audit.
Similarly, a GEC-approved CAB may appeal one or more nonconformance findings in their Annual EPEAT
Audit. The appeal must be submitted in writing to GEC within 30 business days of the date that GEC sent

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the audit report to the CAB. GEC evaluates if the appellant has provided enough documentation to
warrant proceeding with the appeal before proceeding with an investigation into the appeal. During
GEC’s appeals process, the CAB will continue to address any other nonconformance findings foundduring the Initial or Annual EPEAT Audit.
9.2.2.2

Continuous Monitoring

Complaints and Appeals

Participating Manufacturers and GEC-approved CABs may appeal final decisions on conformity and final
decisions of unacceptable corrections made by the EPEAT Program during Continuous Monitoring Round
Investigations. Appeals must be submitted in writing within 10 calendar days of the date that the EPEAT
Program specified Investigation Reports with the final decisions on conformity or corrections were to be
distributed by CABs to Participating Manufacturers. The appellant must indicate whether the appeal isbased on procedural or technical grounds.
If a Participating Manufacturer or GEC-approved CAB appeals a final decision on conformity made for aLevel 2 Investigation, the appellant must be prepared to provide another, identical product for reevaluation by the laboratory, at their own cost, if necessary. The written appeal must establish thereason for the appeal and if applicable, the reason for possible re-evaluation of the investigatedproduct.

EPEAT Program Complaints and Appeals Process
As described in Section 9.1.2 and 9.2.2, specific complaints and appeals regarding conformity assurance
activities may be raised to the EPEAT Program. This section describes the process used to address suchcomplaints/appeals and does not apply to complaints/appeals raised directly to GEC-approved CABs.
Complaints and appeals regarding conformity assurance activities must be made in writing to the EPEAT
Program within the timeframes specified in Sections 9.1.2 and 9.2.2, and must include the following
information to be considered complete:
1.

Identification of the issue:•

For procedural complaints/appeals, identification of the relevant clause(s) of thisdocument, EPEAT Conformity Assurance Implementation Manual (P66) against which thecomplaint or appeal is based.

•2.

For all appeals related to Continuous Monitoring Round investigations, identification of theInvestigation number originally assigned by the EPEAT Program;
Rationale or reason for the complaint/appeal; and3.

Evidence substantiating the basis for the complaint/appeal.
•

For technical appeals of final conformity decisions or final decisions of unacceptablecorrections: Because Continuous Monitoring Investigations are time-bound activities, theappellant cannot provide additional evidence beyond what was originally submitted during
the Continuous Monitoring Investigation.

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Within five business days of receipt of a complaint or appeal, the EPEAT Program evaluates thecomplaint or appeal for completeness and notifies the complainant/appellant of the outcome of theevaluation. If determined to be complete, the EPEAT Program assigns a Complaint/Appeal Manager andconducts an investigation. During the investigation, the complainant/appellant may be asked to respondto questions or provide additional information.
Depending on the nature of the complaint, the EPEAT Program may convene a Complaints Committee.
For all appeals, the EPEAT Program convenes an Appeals Committee. The Complaint/Appeal Manager
may also serve as a member of such Committees.

Complaints and Appeals

The Complaints/Appeals Committee (or, where applicable and appropriate for complaints, theComplaint Manager) reviews the complaint/appeal, all submitted documentation, and results of theinvestigation and makes a final decision on the complaint/appeal.
Complaints and appeals are handled swiftly and as transparently as possible, while still respecting theconfidentiality of all parties involved. Any GEC personnel who is the subject of the complaint or appeal is
not permitted to be involved in the investigation of that complaint or appeal, is not permitted to serveas Complaints/Appeals Manager for that complaint/appeal and is not permitted to serve on the
Complaints/Appeals Committee for that complaint/appeal.
GEC ensures that complaints and appeals do not result in discriminatory actions. No complainant,appellant, or other individual shall be negatively treated for bringing forward a complaint or appeal,
providing information related to a complaint or appeal, or helping to resolve a complaint or appeal.
GEC notifies the complainant/appellant in writing of its decision on the complaint/appeal within 30
calendar days of the start of the investigation. The EPEAT Program is responsible for managing
investigations into complaints and appeals and GEC retains full authority to make the final
determination in the case of all complaints and appeals pertaining to conformity assurance related
activities.

Non-Conformity Assurance Related Complaints
GEC-approved CABs may receive complaints regarding GEC’s management of the EPEAT Program,potential misuse of the EPEAT mark or misleading claims. CABs must forward all such complaints to the
EPEAT Program and should not initiate an investigation regarding these issues unless explicitly
instructed by the EPEAT Program to do so. The EPEAT Program will determine the appropriate next
steps and only involve the CAB if warranted.

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10.0 Force Majeure EventsThe EPEAT Program may issue temporary addenda to this document, EPEAT Conformity Assurance
Implementation Manual (P66), to address unforeseeable and extraordinary circumstances that are
beyond the control of Participating Manufacturers or GEC-approved CABs. Such circumstances include
but are not limited to natural disasters, acts of war or terrorism, significant labor strikes, devastating
accidents to a supplier facility, epidemics, or pandemics.

Force Majeure EventsThe EPEAT Program may also issue temporary exemptions during Documentation Review andContinuous Monitoring activities due to force majeure events.

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11.0 Revisions and Effective Date
The EPEAT Program reviews EPEAT Conformity Assurance Implementation Manual (P66) on an annual
basis to determine if revisions are required. Revisions to this document are generally published on
February 15 and take effect on July 1 of any given year, however GEC may, at its sole discretion, identify
specific revisions which take effect on another date before or after July 1.

Revisions and Effective Date

GEC considers programmatic needs when determining the effective date for all revisions and iscommitted to ensuring its decision is transparent and fair for all stakeholders, including Participating
Manufacturers, GEC-approved CABs, and purchasers.

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11.012.0 Supplementary Information
Acronyms
The following acronyms are used in this document.
CAB: Conformity Assurance Body
CGG: Conformity Guidance GroupIAF: International Accreditation Forum

Supplementary Information

ILAC: International Laboratory Accreditation Cooperation

References
The following documents are referenced in this document, EPEAT Conformity Assurance Implementation
Manual (P66), and are indispensable for its application. Undated references indicate that the latest
edition of the referenced document applies.
•

CAB Application Form (P40)•

CAB Performance Improvement Assistance Plan (P73)•

Conformity Guidance Group Issue Paper and Feedback Form (P88)•

EPEAT Policy Manual (P65)•

GEC Conformity Assurance Body Agreement (P33)•

GEC EPEAT License and Participating Manufacturer Agreement (P26)•

ISO 9000 Quality management systems – Fundamentals and vocabulary•

ISO/IEC 17000 Conformity assessment – Vocabulary and general principles•

ISO/IEC 17020 Conformity assessment – Requirements for the operation of various types ofbodies performing inspection•

ISO/IEC 17025 General requirements for the competence of testing and calibration laboratories•

ISO/IEC 17050-1 Conformity assessment – Supplier’s declaration of conformity – Part 1:
General Requirements•

ISO/IEC 17050-2 Conformity assessment – Supplier’s declaration of conformity – Part 2:
Supporting documentation•

ISO/IEC 17065 Conformity assessment – Requirements for bodies certifying products,
processes, and services•

Level 0 Investigation Report Template (P70)•

Level 1 Investigation Report Template (P35)

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Level 2 Investigation Report Template (P36)•

Outcomes Report Template (P63)•

Rebranding of EPEAT-Registered Products: Product Criteria with Disclosure Requirements (P82)

Definitions
The following definitions are referenced throughout this document, EPEAT Conformity Assurance
Implementation Manual (P66), and are indispensable for its application.

Supplementary Information

Active / Activate: Term that refers to the status of a product that is currently identified in the EPEAT
Registry as meeting EPEAT Criteria (“active”) or the process of using the EPEAT Registry software to
make a product appear in the EPEAT Registry (activate).
Annual Renewal: Continuous Monitoring activities conducted by a GEC-approved CAB for a Participating
Manufacturer’s products that have used the Certification Pathway.
Antitrust Statement: GEC assigns the highest priority to full compliance with both the letter and thespirit of antitrust laws and therefore a statement is read at the beginning of meetings that are facilitatedby GEC and include industry members to remind participants not to engage in anti-trust behaviors andthat care should be taken to avoid discussions that may suggest or tend to reflect agreements among
competitors as to: price; terms of sale that could impact price; allocation of customers, markets or
territories; bid-rigging; and boycotts or joint refusals to do business with others. Participants must abideby the antitrust statement and avoid any conduct that might violate, or would create the appearance ofa violation of, antitrust laws.
Appeal: For the purposes of this document, EPEAT Conformity Assurance Implementation Manual (P66),
an appeal is a written request for reconsideration of a conformity recommendation or decision based oneither procedural or technical grounds. Appeals can be made to GEC-approved Conformity Assurance
Bodies or the EPEAT Program. Based on definition of appeal in ISO/IEC 17000 Conformity assessment –Vocabulary and general principles.
Applicant Conformity Assurance Body (Applicant CAB): Conformity Assurance Body whose CAB
Application Form (P40) and all supporting documentation have been received by GEC but has not yet
been granted status as a Provisional Conformity Assurance Body.
Archived / Archive: Term that refers to the status of a product that once appeared in the EPEAT Registry
but no longer meets EPEAT Criteria (“archived”).
Certification Pathway: One of two ways to complete Initial Documentation Review, where results ofInitial Documentation Review are valid for three years or until the EPEAT Program implements theCriteria resulting from a Full Product Category Revision, whichever is earlier. Any Minor Criteria
Revisions or Major Criteria Revisions must be addressed during Ongoing Documentation
Review.Documentation Review is completed immediately and requires a Participating Manufacturer todemonstrate conformance with all selected EPEAT Criteria at the outset.

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Clarification: Formal guidance issued by the EPEAT Program to clarify ambiguous wording in EPEAT
Criteria or in associated conformity assurance requirements. Typically issued to mitigate the potential
for different conformity decisions being made because of the ambiguous language.

Supplementary Information

Competence: Ability of a Participating Manufacturer to demonstrate an understanding of an EPEAT
Criterion’s requirements and their ability to demonstrate conformance to that Criterion on an ongoingbasis. A participating Manufacturer’s competence for a Criterion is evaluated by its GEC-approved
Conformity Assurance Body.
Complaint: For the purposes of this document, EPEAT Conformity Assurance Implementation Manual(P66), a complaint is a written expression of dissatisfaction related to conformity assurance activities,
recommendations, or decisions, other than an appeal, submitted to a GEC-approved Conformity
Assurance Body or the EPEAT Program by any person or organization. Based on definition of complaintin ISO/IEC 17000 Conformity assessment — Vocabulary and general principles.
Conformance: Conclusion, based on the results of conformity assurance activities, in which the party
being assessed has demonstrated the fulfillment of specified requirements. Based on definition of“decision” in ISO/IEC 17000 Conformity assessment – Vocabulary and general principles.
Conformity Assurance Body (CAB): A body that performs conformity assessment activities, excluding
accreditation. Based on definition of conformity assessment body in ISO/IEC 17000 Conformity
assessment — Vocabulary and general principles.
Conformity Assurance Body Mentored Work Phase (CAB Mentored Work Phase): Period of time where
GEC provides additional support to a newly approved Conformity Assurance Body to increase its
proficiency in EPEAT Program required methods of conformity assurance. During this Phase, GEC
evaluates and approves the Conformity Assurance Body’s conformity decisions made in the Initial
Documentation Review for its initial Participating Manufacturer clients. Because Conformity Assurance
Bodies in this Phase cannot activate products or newly selected Criteria or remove a Documentation
Review requirement for a Criterion, GEC facilitates these activities for them.
Conformity Guidance Group (CGG): A group of stakeholders with technical expertise or with access tosuch expertise that is convened by the EPEAT Program to obtain technical input and feedback on EPEAT
conformity assurance processes, technical requirements in EPEAT Criteria and implementation of
updated and amended EPEAT Criteria. The Conformity Guidance Group is open to all stakeholders but is
not a standing committee and does not hold any decision-making authority.
Conformity Guidance Materials: Informative and supplemental guidance published by the EPEAT
Program to enhance Participating Manufacturer and Conformity Assurance Body understanding of
EPEAT Criteria and associated conformity assurance requirements.
Conformity Requirements and Guidance Materials: Documents developed by the EPEAT Program
designed 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.

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Continuous Monitoring: Ongoing surveillance process for confirming the accuracy of information
identified by Participating Manufacturers in the EPEAT Registry. Continuous Monitoring includes
conformity assurance activities conducted in Continuous Monitoring Rounds and in Annual Renewals.
Continuous Monitoring Round: Discrete period of time where GEC-approved Conformity Assurance
Bodies conduct Investigations that have been selected and assigned to them by the EPEAT Program. The
EPEAT Program identifies which products and EPEAT Criteria must be evaluated, specifies the method ofinvestigation (Level 0, Level 1 or Level 2), and assigns Investigations to Conformity Assurance Bodies.

Supplementary Information

Corrective Action Phase: Period of a Continuous Monitoring Round during which Participating
Manufacturers must correct the issues underlying final decisions of nonconformance identified in
Investigations. During this period, Participating Manufacturers must also develop a corrective action
plan to address other similarly affected products.
Correction: Action(s) taken to immediately correct a nonconformance within a specified timeframe.
Corrective Action Plan: Plan, with actions and timelines, developed to eliminate the root cause(s) of anonconformance so as to prevent reoccurrence. Based on definition of corrective action in ISO 9000
Quality management systems – Fundamentals and vocabulary.
Deliberation Phase: Period of a Continuous Monitoring Round where the EPEAT Program reviews
Investigation Reports and supporting evidence submitted by GEC-approved Conformity Assurance
Bodies and makes final decisions of conformity on the Investigations.
Demonstrated Nonconformance: High-level reason for a nonconformance in an Investigation where
evidence provided by a Participating Manufacturer definitively shows EPEAT Criteria are not met.
Documentation Review: Iterative process used by a GEC-approved Conformity Assurance Body toevaluate a Participating Manufacturer’s Criteria selections by assessing conformance (i.e., assess theintegrity of documentation provided by a Participating Manufacturer and determine if demonstrates
conformance with the Criteria) and by assessing competence (i.e., assess if the Participating
Manufacturer understands the requirements of the Criteria and can provide acceptable evidence).
Documentation Review Requirement: EPEAT Program conformity assurance requirement where a
Participating Manufacturer must show competence for an EPEAT Criterion and cannot activate theCriterion without Documentation Review being performed by a GEC-approved CAB. When theDocumentation Review Requirement is instated or reinstated for a Criterion, a Participating
Manufacturer must provide evidence and demonstrate conformance to that criterion.
EPEAT Audit of Conformity Assurance Body (EPEAT Audit of CAB): Audit conducted by the EPEAT
Program to evaluate a Conformity Assurance Body’s ability to meet EPEAT Program requirements as
identified in EPEAT Policy Manual (P65) and EPEAT Conformity Assurance Implementation Manual (P66).
EPEAT Criteria: Environmental and social requirements developed through a balanced, voluntary
consensus process and adopted by the EPEAT Program. Sometimes referred to as “Criteria” or“Criterion”.

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EPEAT Program: A comprehensive voluntary sustainability Type 1 ecolabel that helps purchasers identify
more sustainable technology products and services, which is owned and managed by the Global
Electronics Council (GEC). EPEAT Program staff are employees of GEC. All activities and responsibilities
associated with “EPEAT” or the “EPEAT Program” identified in this document are undertaken by GEC
employees.
EPEAT-registered Product: Product appearing on the EPEAT Registry with active status. Sometimes
referred to as “registered product”.

Supplementary Information

EPEAT Registry: Online repository that identifies more sustainable technology products and services in avariety of different product and service categories that currently meet EPEAT Criteria (referred to as“active”) and that previously met EPEAT Criteria (referred to as “archived”).
EPEAT Trademark: Visual representations of the name EPEAT and stylized marks EPEAT Bronze, EPEAT
Silver, EPEAT Gold, and the EPEAT logo, which Participating Manufacturers are licensed to use
contingent on meeting the terms in GEC License and Participating Manufacturer Agreement (P26).
Active products appearing in the EPEAT Registry have been verified as meeting specific EPEAT
environmental and social criteria associated with the Marks. By appearing in the EPEAT Registry,
Products are considered to be using the Marks and Participating Manufacturers are not required to use
the Marks on their physical Products. Also known as EPEAT Marks.
Full Product Category Revision: One of the three possible categories assigned by the EPEAT Program to
Criteria revisions resulting from Continuous Maintenance in GEC’s Dynamic Criteria Development
Process. In this type of revision, all EPEAT Criteria are open to modification and revision, and the process
begins with an update to State of Sustainability Research. Estimated timeframe for implementation isnine to eighteen months after publication. The other two categories are Minor Criteria Revision and
Major Criteria Revision.
GEC-approved Conformity Assurance Body (GEC-approved CAB): Status of a Conformity Assurance
Body assigned by GEC after successful completion of the Initial EPEAT Audit, including correction of allnonconformances and implementation of all corrective action plans, and successful qualification of atleast two individuals to be Qualified Auditors for each product category in which the Conformity
Assurance Body offers conformity assurance services for the EPEAT Program. GEC-approved CABs may
provide EPEAT conformity assurance services for Participating Manufacturer clients.
Impartiality / Impartial: Presence of objectivity, where objectivity is understood to mean that conflictsof interest do not exist or are resolved so as not to adversely influence conformity assurance andprogrammatic activities. Based on the definition of impartiality in ISO/IEC 17000 Conformity assessment– Vocabulary and general principles and ISO/IEC 17065 Conformity assessment – Requirements forbodies certifying products, processes, and services.
Inconclusive: Result of an Investigation where sufficient and objective evidence has been evaluated but
a conclusion of conformance or nonconformance cannot be determined due to limitations in theevaluation technique(s). Typically, only Level 2 Investigations result in a finding of Inconclusive.
Initial Documentation Review: Documentation Review activities conducted by a GEC-approved
Conformity Assurance Body when a Participating Manufacturer initially registers its first products in the

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EPEAT Registry or registers products in a new product category. Initial Documentation Review must becompleted before a Participating Manufacturer’s products can become EPEAT-registered for a productcategory.
Insufficient Evidence to Demonstrate Conformance: High-level reason for a nonconformance in an
Investigation where evidence provided by a Participating Manufacturer is incomplete and does notdefinitively show either conformance or nonconformance.
Investigation: Activities conducted in a Continuous Monitoring Round where a Participating
Manufacturer’s conformance to EPEAT Criteria is evaluated by a GEC-approved Conformity Assurance
Body.

Supplementary Information

Investigation Phase: Period of a Continuous Monitoring Round where GEC-approved Conformity
Assurance Bodies are actively conducting Investigations.
Investigation Report: Report prepared by a GEC-approved Conformity Assurance Body summarizing thecontinuous monitoring activities conducted during an Investigation, identifying the Conformity
Assurance Body’s recommendation on conformity, and submitted to the EPEAT Program at theconclusion of an Investigation. Investigation Reports are considered to be in draft form until the EPEAT
Program makes the final decision on conformity or the final decision on a correction for findings ofnonconformance.
Level 0 Investigation: Type of Investigation where a GEC-approved Conformity Assurance Body reviews
publicly available information without the Participating Manufacturer’s involvement or submission ofevidence.
Level 1 Investigation: Type of Investigation where a GEC-approved Conformity Assurance Body reviews
evidence submitted by a Participating Manufacturer.
Level 2 Investigation: Type of Investigation where a GEC-approved Conformity Assurance Body acquiresa Participating Manufacturer’s product from the marketplace, without the Participating Manufacturer’s
involvement where possible, and has the product evaluated by a laboratory.
Major Criteria Revision: One of the three possible categories assigned by the EPEAT Program to Criteria
revisions resulting from Continuous Maintenance in GEC’s Dynamic Criteria Development Process. In thistype of revision, in addition to the revisions categorized as Minor Criteria Revisions, the scope is limited
to new criteria identified to address gaps in sustainability impact areas, and revisions requested bystakeholders. Estimated timeframe for implementation is four to six months after publication. The othertwo categories are Minor Criteria Revision and Full Product Category Revision.
Minor Criteria Revision: One of the three possible categories assigned by the EPEAT Program to Criteria
revisions resulting from Continuous Maintenance in GEC’s Dynamic Criteria Development Process. In thistype of revision, the scope is limited to corrections, changes, and updates to text to further clarify
existing requirements. Estimated timeframe for implementation is one to two months after publicationof the revisions. The other two categories are Major Criteria Revision and Full Product Category
Revision.
Minor Error: Category assigned to a nonconformance for the following four scenarios:

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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 during a Level 1 Investigation
where the Participating Manufacturer indicated the product has reached end-of-life and is nolonger available on the market, and•A GEC-approved CAB is unable to obtain a product from the market during a Level 2
Investigation where the Participating Manufacturer indicated the product has reached end-oflife and is no longer available on the market.

Nonconformance: Conclusion, based on the results of conformity assurance activities in which the party
being assessed has not demonstrated the fulfillment of specified requirements. Based on definition of“decision” in ISO/IEC 17000 Conformity assessment – Vocabulary and general principles. This specifically
includes the following:•

No response to a request for documentation or no documentation provided during theinvestigation period of a Level 1 Investigation, except for when the Participating Manufacturer
indicated the product is end-of-life and no longer available on the market, and•All nonconformances found in Level 2 Investigations, except for when the CAB was unable toobtain the product for evaluation by a laboratory and the Participating Manufacturer indicatedthe product has reached end-of-life and is no longer available on the market.

No Documentation Provided: High-level reason for a nonconformance in an Investigation where theParticipating Manufacturer has not provided any supporting evidence or documentation during theInvestigation Phase.
Ongoing Documentation Review: Documentation Review activities conducted by a GEC-approved
Conformity Assurance Body after a Participating Manufacturer’s initial products first appear in the
EPEAT Registry for a product category. Ongoing Documentation Review can occur for a variety ofreasons, such as the addition of new products, changes to the EPEAT Criteria selected for EPEATregistered products and addressing nonconformances arising from Continuous Monitoring activities.
Optional Criterion / Criteria: EPEAT Criteria that represent a Participating Manufacturer’s commitment
to innovation in environmental and social performance. Participating Manufacturers have the option to
select one or more Optional Criteria for each EPEAT-registered product. If selected, the Participating
Manufacturers must demonstrate conformance with the Optional Criterion. EPEAT-registered products
are identified by tier as EPEAT Bronze, EPEAT Silver or EPEAT Gold. All products must meet all Required
EPEAT Criteria, and the tiers differentiate products by the percentage of Optional EPEAT Criteria the
products meet
Outcomes Report: Report published by the EPEAT Program at the conclusion of each Continuous
Monitoring Round to summarize the activities conducted, identify EPEAT Criteria investigated and themethod of investigation, highlight overall conformity results and trends, and identify the products andGlobal Electronics Council

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Participating Manufacturers that received nonconformances and the corrections made to restore
accuracy of the EPEAT Registry.
Participating Manufacturer: Brand owner that registers products in the EPEAT Program and is
responsible for ensuring ongoing conformance of the products against the EPEAT Criteria selected for
those products. A Participating Manufacturer must retain the services of a Provisional Conformity
Assurance Body or a GEC-approved Conformity Assurance Body to participate in the EPEAT Program.

Supplementary Information

Preparation Phase: Period of a Continuous Monitoring Round where the EPEAT Program selects
products, EPEAT Criteria and the method of investigation (Level 0, Level 1, or Level 2), assigns
investigations to GEC-approved Conformity Assurance Bodies, and conducts training for GEC-approved
Conformity Assurance Bodies
Priority Criteria: Criteria identified by the EPEAT Program for each product category, which are theminimum to which a Participating Manufacturer must demonstrate conformance to a GEC-approved
Conformity Assurance Body before allowing the Participating Manufacturer’s products to appear in the
EPEAT Registry for each product category. Priority Criteria include all Required Criteria for any given
EPEAT product category.
Priority Verification Pathway: One of two ways to complete Initial Documentation Review, where
results of Initial Documentation review are valid until the EPEAT Program implements the Criteria
resulting from a Full Product Category Revision. Any Minor Criteria Revisions or Major Criteria Revisions
must be addressed during Ongoing Documentation Review. Documentation Review is staggered over
several months for up to one year.
Procedural Appeal: Appeal made on the grounds that a conformity recommendation or decision should
be reconsidered because a required internal or external process was not followed.
Provisional Conformity Assurance Body (Provisional CAB): Status of a Conformity Assurance Body
assigned by GEC after successful evaluation of the submitted CAB Application Form (P40), review ofaccreditations, and full execution of GEC Conformity Assurance Body Agreement (P33). Provisional CABs
may solicit business for EPEAT conformity assurance services but may not provide these services until
granted status as a GEC-approved CAB.
Qualified Auditor: CAB personnel who has met and maintained the necessary qualifications and been
approved by the EPEAT Program to provide conformity assurance services for the EPEAT Program.
Sometimes referred to as “Auditor”.
Required Criterion / Criteria: EPEAT Criteria against which a Participating Manufacturer must
demonstrate conformance before a product can become EPEAT-registered and appear in the EPEAT
Registry.
Technical Appeal: Appeal made on the grounds that a conformity assurance recommendation ordecision should be reconsidered because a specified requirement was not interpreted correctly.

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Annex 1: Nonconformances and Minor Errors

Supplementary Information

The flowchart below provides additional guidance to GEC-approved CABs for identifying if
nonconformances resulting from Continuous Monitoring Investigations are “minor errors”.

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Supplementary Information

Annex 2: Level 0 Investigations

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Supplementary Information

Annex 3: Level 1 Investigations

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Supplementary Information

Annex 4: Level 2 Investigations

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Document Change History
Revision

AuthorDescription of Change

ApproverApproval Date

Effective Date

10

L. Hoppe

Initial release2020 Jan 172020 Jan 17

20

SeniorManager,
Ecolabels
andResources

Restructuring of document and further
clarifying existing policies. Addition orchanges to: Guidance for raising questions
with EPEAT; Organizations can only apply
once each 12 months to be a CAB; Initialaudit required for Provisional CABs; New
minimum criteria for review in CAB
Mentored Work Phase; Topics for annual
and bi-annual audits of CABs; Process if
Auditor fail exams; Annual Auditor
proficiency training and exam; CAB must
attend Calibration mtgs and mtgs governedby Chatham House Rule and anti-truststatement; Updated CAB metrics including
new customer service metric; New reasonsfor CAB suspension or termination; annual
CAB Summit; No visual inspection
requirement for Certification Pathway but
products may be included in Level 2; Details
needed in test reports; New process forrebranding products already EPEATregistered; Minor NCs must be corrected in
30 days; 6 months max for corrective action
plan for similarly affected products; List of
criteria for Annual renewals; Guidance forwhen CABs identify NCs outside ofContinuous Monitoring; Updated criteria
for review when changing CABs; additional
definitions and references; acronyms; Force
Majeure Events.

L. FernandezSalvador
SeniorDirector,
Ecolabels andManufacturer
Resources2021 Feb 15

2021 July 01

formation

Supplementary Information

Issue

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Revision

AuthorDescription of Change

ApproverApproval Date

Effective Date

2

1

SeniorManager,
Ecolabels
andResources

Throughout: Formatting and fixing typos;
Defining timeframes (calendar vs businessdays); Additional documents available;
Defining correction versus corrective action
plan. Additional clarity: Clarifications(2.2.1); CGG meets on as needed basis,
topics may include transition timeframe forrevised criteria (2.2.4); Reviewing CAB
applications (3.2); Only qualified auditors
can perform work, must be qualified foreach product category (3.3.1, 4.1);
Mentored work can include Continuous
Monitoring (3.5); Reordering for clarity (5.6,
6.0, 9.0); Further details on PIAP,
suspension and termination (5.6.1, 5.6.2,
5.6.2.1, 5.6.2.2); Change in terms to
Nonconformance and Minor Error(throughout 7.2); CABs encouraged toprovide Reports early to address questions(7.2.2); EPEAT may follow-up on
Inconclusive findings (7.2.3); Inconclusive
findings not identified in Outcomes Reports(7.2.5); Timing for Annual Renewal activities(7.3); Further details on complaints andappeals (9.1.1, 9.1.2, 9.2.1, 9.2.2, 9.3). New:
Scenarios where attestations may be used,
docs will be available when finalized (2.2.5);
Public availability of which categories CABs
are approved (3.4); Specialized training may
be used for auditors (4.4.2); Ability toreference P66 in CAB's QMS but substantive
activities must be in procedures (5.1);
Annual audit of CABs include review of Mfr
CAPs and previous NCs related toconformity decisions (5.2.1); Requirements
to address Mfrs that may be affected byNCs (5.2.2.1); Must gain EPEAT approval forlate submission of Reports (5.3, throughout7); If CASB terminated, Mfr clients given 12
months to complete Documentation
Review with new CAB (5.6.2.2); CABs must
notify GEC is Mfr no longer a client (5.7);
Diagram to explain Documentation review(6.1.2); No confidential info transferred inrebranding, products not identified asrebranded, requirements for Continuous
Monitoring (6.4); NCs identified by EPEAT
outside Continuous Monitoring (6.5.2);
Using local time zone and implications forlate Reports (throughout 7.2); referencesand definitions (11.2, 11.3).

SeniorDirector,
Ecolabels andManufacturer
Resources2022 Feb 152022 July 01

formation

Supplementary Information

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Revision

AuthorDescription of Change

ApproverApproval Date

Effective Date2

2

SeniorManager,
Ecolabels
andResources

Additional clarity: Process for auditors onleave (4.2.1, 4.2.2); Continuous monitoring
training (4.2.3); Retention of records for 3
years after contract with Mfr ends (5.1);
Nonconformances related to conformity
decisions and notifying Mfr (5.2.2.1); Metric
3 and training attendance (5.3); Examples
for demonstrating competence (6.1.5); CABs
and Mfrs may develop alternate methods todemonstrate competence for specificcriteria (6.3.1); Products for testing must be
new and in original packaging (7.1, 7.2.2);
Time to revise IRs (7.2.3, 7.2.4.1); Appeals
during Continuous Monitoring (9.2.1.2).
Additions: Clarification may be released for
CGG review period (2.2.1); Auditor training
for revised Criteria from Sustainability
Impact Modules (3.1, 3.3.1, 4.1, 4.2); CAB
mentored work phase with revised Criteria
from Sustainability Impact Modules (3.5);
Metrics 4 and 11 (5.3); Declarations ofconformity (6.1.4.2); Conforming new
products similar to existing products (6.2.4,
6.3.1); Impacts of force majeure events on
ongoing conformity assurance activities(10.0); Section on revisions and effective
date (11.0). Changes: Reference to priority
criteria removed (2.1, 6.1.4.2, 6.2.2, 6.2.4,
old 6.3.1, old 6.3.1.1, old 6.3.1.2, 6.3.1, 8.0);
Name and intent of conformity guidancematerials (2.2.2); Removed section on
conformity assurance where equivalent
regulatory requirements exist (2.2.5);
Timeframe for providing evidence ofcorrections during Annual EPEAT Audit of
CAB (5.2.2); Changes to metrics 1 and 12(5.3); Actions in Continuous Monitoring forforce majeure circumstances (7.2); Updated
definitions (12.3).

VP, Ecolabels
andManufacturer
Resources

Proposed
2023 Feb 15

Proposed
2023 Jul 01

formation

Supplementary Information

Issue

Global Electronics Council

EPEAT Conformity Assurance Implementation Manual
P66 Issue 2 Rev 2 – Released October 17, 2022 for Stakeholder Comment Period© 2020 Green Electronics Council

Page 96