Issued by the Product Verification Committee

Clarifications #1 – January 2007

Clarification 1-1. Regarding 4.1.4.1 – Optional criterion: Elimination of intentionally added lead

Question came from one subscriber:

1680 requires lead levels less than 50ppm. The verification requirements require either empirical data from supplier demonstrating compliance or analytical test data. The subscriber specifies that their suppliers not intentionally add lead. They also require their suppliers to provide test data at the level of 100ppm. The subscriber states that it is likely that other subscribers do not require test data at all, and that 50ppm is very low given testing capabilities. Is this sufficient?

Background Analysis: 1680 actually includes two different implicit standards for this criterion: 1) no intentionally added lead (in the criterion title and apparently the intent of the criterion) and 2) lead below 50ppm (the requirement in the criterion itself). This has implications for verification.

In addition the verification requirement in 1680 reads: “Evidence of certification from component manufacturers that is based on either empirical data demonstrating compliance or analytical test data demonstrating compliance.” Thus verification does not necessarily require testing to a specified level, but it does require either empirical or analytical data that demonstrates conformance to that level. The question is what “empirical data” is satisfactory. The “certification from component manufacturer” would seem to be an attestation by the component manufacturer that they have not added lead to the product and that none of their suppliers have added lead through any process. The certification can be backed up by empirical data that includes assurance of conformance through a quality control program.

This could be further supported, though not required, by evidence that the manufacturer has placed such requirement on their suppliers, that is, that they have specified no lead.

The specific subscriber that asked the question states that their documentation requires no added lead of suppliers. They would also need to provide evidence from the supplier that no lead was added, and then that would appear to meet the intent of the criterion for empirical data demonstrating conformance. However, in the requirements of their suppliers they specify testing at a less stringent level (100 ppm versus 50 ppm) than 1680 requires at 50ppm. Does the specification of a higher testing level imply that the product may not, in all cases, meet the criterion, even though “no added lead” is also specified? Since the standard wording cites specifically 50ppm, does this imply that there should be a test at that level?

The standard is not internally contradictory; it simply includes two different requirements for demonstration of conformance, separated by an “or”. Meeting either of those requirements would suffice for demonstration of conformance based on manufacturer-supplied verification data. Of course, nothing would prevent the PVC from having analytical tests performed to confirm the representation of the manufacturer.

Further Background Analysis: Subsequent to the adoption of this Clarification, two Interpretations were adopted by an IEEE Interpretations Group related to this criterion – Interpretation 1-5 and Interpretations 1-6. The Interpretations address all elements of the Clarification, with the exception of a specific reference to the 50 ppm threshold. Therefore, edits were made to the Clarification to result in the following.

PVC Determination: The wording of the criterion prevails over the title of the criterion wherever there is a conflict or inconsistency. In this case, the criterion defines the threshold to which the determination of no added lead must be measured – “50ppm by weight per listed part”.

·         Demonstration that parts do not exceed the 50 ppm level is required according to the wording of the criterion.

·         See Interpretations 1-5 and 1-6 for further detail on these questions.

·         See the Conformity Assessment Protocols for quality control procedures to satisfy these data requirements.

Clarification 1-2. Regarding 4.3.1.1 – Required criterion: Identification of materials with special handling needs

The following question came from one subscriber:

Would it be acceptable to the Green Council if we identified such materials in the users manual? We have checked several EPEAT products and we did not note any makings on the computer, but were indicated in the manual. I am referring to mercury in the backlight tube, which is exempted in the RoHS Directive specifically. The state of Vermont will require that notebook computers be labeled to identify the presence of mercury, by July 1, 2007. But we, and apparently other manufacturers are not yet ready to apply such a label as yet until close to that date. This is a very important point that remains to be resolved and would greatly appreciate your response

Background Analysis: The intent of the standard is to “provide treatment information to reuse and recycling facilities”. It does not specify how to provide the information, and therefore any reasonable attempt that would make the information directly accessible to recyclers would be reasonable.

It has been documented that manuals are not generally provided along with electronic equipment for recycling. Moreover, a survey of recyclers indicates that not very many access information from manuals.

When this criterion was developed, the thought was that this type of information would be available on a web site of some sort – either the manufacturers or a common one. The Green Electronics Council has spoken with the National Center for Electronics Recycling and IAER about hosting such a site, and there is interest.

PVC Determination: Posting treatment information on the manufacturer’s web site, possibly in an on-line manual, is acceptable. Likewise, labeling on the product would also make it directly accessible to recyclers. However, simply publishing the information in a hard copy manual that does not typically accompany a device at end-of-life is not an adequate demonstration of providing treatment information to recyclers.

Clarification 1-3. Regarding 4.3.1.2 – Required criterion: Elimination of paints or coatings that are not compatible with recycling or reuse

The following question came from one subscriber:

1) ASTM D256 method does not specify the sampling preparation procedure. It is not clear whether we need to imitate the typical recycling process for the IZOD impact test including extrusion or whether we could run a test by making test samples by molding plastic pieces. 2) Recycled resin will have potentially impacted by 1) recycling process including heat exposure and 2) paint coating mixed into the resin. It is not clear whether we will need to run two series of test, one without paint (either obtaining the part without pain or scraping the paint) and one with paint and compare the IZOD impact results.

A second question about this criterion came from a potential future subscriber:

As IEEE 1680, 4.3.1.2, says: All covered products shall not contain paints and coatings on larger plastic parts that are not compatible with recycling and reuse.

However, we’ve got some lab 3R reports analyzing that EMI shielding film (composed of metal) on plastic parts is so small quantity that could be neglected when recycling. Therefore, could it be acceptable for EPEAT?

A third similar question came from a subscriber:

Is it accepted in case the front bezel of the monitor has painting on it (silver color)? I have checked it with TUV and TUV said even if it has painting on it, it is recyclable.

Background Analysis: The standard requires that “compatible with recycling” refers only to the resulting physical/mechanical properties of the recycled resin and is defined in 3.2.2 by a specified ASTM lab test that compares the properties of a sample of the plastic with the coating relative to a sample of the same plastic without the coating. Clearly the samples of each must be prepared in a process that involves grinding, melting and molding in some manner, because that is how a recycled plastic material is produced. If the precise manner of doing so is not specified in the ASTM procedure, then the subscriber would have flexibility in how they would simulate the recycling process.

The verification requirements specify that the subscriber will provide the results of such a test, or the supplier verification of such, if paints/coatings are used.

The intent of the criterion is that large plastic parts (>100g) can be separated from the product and processed into a recycled plastic that retains characteristics that do not compromise its functionality. It uses the definition of “compatible with recycling” which is defined in 3.2.2 by the IZOD impact test.

In conducting the impact test, the following options have been defined:

Option 1 (preferred): Compare IZOD impact of two parts, following a recycling process simulation (i.e., grinding, pelletizing): 1) painted plastic part; 2) same part, but unpainted.

Option 2: Compare the IZOD impact of a painted plastic part, following a recycling process simulation, to the IZOD specification for the resin. The IZOD specification could be the manufacturer specification or supplier-provided material properties data.

PVC Determination: The 3.2.2 definition is compatible with either option above. The measure is if there has been >25% reduction in the IZOD test results in comparison with un-painted plastic, but it does not specify how the test level for un-painted plastic be defined.

The criterion should be applied to whole parts >100g in size as molded and pre-assembly, i.e. plastic housings. In other words, the manufacturer is not required to speculate as to how a recycler might disassemble the product, but rather should test the parts in the form they occur prior to assembly.

Note that neither the lab 3R reports nor the TUV assertion cited above are either a “manufacturer test” (unless, of course, 3R or TUV supported their assertion by the applicable test) or a “supplier verification”, so they would not meet the verification requirements.

Clarification 1-4. Regarding 4.3.1.8 – Required criterion: Minimum 65% reusable/recyclable

Regarding 4.3.1.9 – Optional criterion: Minimum 90% reusable/recyclable

Several companies have asked for clarification.

• How will we confirm conformance?

• How many recycling tiers are considered? In other words, if a 3^rd tier recycler discards some material, should that not be counted as recycled?

Following is a quote from one subscriber:

Issue: Calculation method is not clearly defined. For example, if a component or part is sent for recycling by tier one vendor to tier two vendor, whether the entire component/part can be considered as recyclable, or whether we would need to exclude a part of component that will not be recycled by the tier two vendor is not clear.

Background Analysis: These are difficult criteria to be certain of conformance, since demonstrating the recyclability of an electronic product is new and uncertain ground. The standard states that the definition is “in accord with” the WEEE Directive. The WEEE Directive will therefore provide the context for the definition of “recyclability”. However, the WEEE was adopted by the EU, and the enforcement, as well as many of the enforcement standards, is left to the member countries of Europe. Thus the EU has provided some but not all the principles necessary for EPEAT purposes.

Another important difference is that the WEEE Directive measures the recycling targets according to a stream of products. However, EPEAT relates to individual products. This makes it difficult to translate the WEEE targets into individual product design criteria.

Note that all quoted text below is from the WEEE Directive unless otherwise cited.

Article 7 of the WEEE Directive sets targets “regarding WEEE sent for treatment” for IT equipment:

• “Component, material and substance reuse and recycling shall be increased to a minimum of 65% by an average weight per appliance.”

• Note that a “recovery” rate of 75% is also set. It includes energy recovery, such as combustion in a waste-to-energy plant, and thus is not applicable in the EPEAT definition of recyclable. Therefore this target is not relevant.

The WEEE also provides certain other principles that must be considered in claiming product recyclability rates:

• Definition of “treatment” – “any activity after the WEEE has been handed over to a facility for depollution, disassembly, shredding, recovery or preparation for disposal and any other operation carried out for the recovery and/or the disposal of the WEEE”.

• WEEE treatment requires the removal of all fluids and selective treatment of Hg containing lamps, batteries, plastics with BFRs, CRTs, liquid crystal displays, and certain other components and materials. This does not imply that these materials cannot be counted toward recycling targets, if indeed they are recycled, but that they cannot be simply shredded with other components and materials.

• “Reuse of whole appliances…shall not be taken into account for the calculation of the targets.” However, the reuse of components is counted toward the recycling/reuse targets.

• The EU has recognized that it is allowable “to use an estimate as to the average percentage of reused, recycled and recovered materials.” [2005/369/EC: Commission Decision of 3 May 2005 laying down rules for monitoring compliance of Member States and establishing data formats for the purposes of the WEEE Directive.] This implies that the calculation of recyclability rates is not intended to be highly precise.

It is important to note that the required EPEAT criterion, based on the experience in Europe to date, is not difficult to achieve for the current stream of end-of-life electronics. “Existing systems show a recycling rate of about 80-90% (including energy recovery). It is still very difficult to make comparisons of recycling and treatment performance due to varying standards and definitions between countries.” [European Commission Technical Report Series, “Implementation of the WEEE Directive in the EU”, 2006.] Note that the 80 – 90% cited above compares to the WEEE target of 75%, not to the reuse/recycling rate of 65%. In any case, we expect that achieving the EPEAT required criterion of 65% would likely not be difficult, but achieving the optional criterion of 90% reusable/recyclable would likely require demonstration of higher recyclability than average existing products.

The key question is then how to determine what portion of a product is recyclable. At each tier in the chain of recycling facilities that handle the product, certain “non-recyclable” portions are disposed of, or used for some purpose other than recycling such as energy recovery. In other words, the key question for the subscriber is to know what portion of their product would end up as rejected material, and to deduct that from the total weight of the product.

PVC Determination: The following principles should be used by subscribers in determining the percentage reusable/recyclable for EPEAT conformance:

• Calculations for EPEAT will utilize the WEEE principles identified above, noting that energy recovery, such as combustion in a waste-to-energy plant, is specifically excluded from the EPEAT definition of recyclable.

• The reusable/recyclable percentage will be the weight of materials that is recyclable, divided by the total weight of the product, multiplied by 100.

• The manufacturer has no control over how a product is disassembled or shredded at end-of-life. Therefore the manufacturer should consider the reusability or recyclability of the materials and components as they are assembled or in the assembled product.

• Materials that would be separated out for disposal or energy recovery at the point of collection, by the sorter (triage), or by a disassembler or shredder, will not be counted as reusable/recyclable.

• The “demonstrated recycling technology” would be applied in assessing the reusability/recyclability of those materials and components as assembled. It is expected, though not specifically required, that a subscriber has investigated real world recycling processes relative to the specific characteristics of the materials and components of registered products to ascertain what portions would, through demonstrated technologies, in reality could be reused or recycled.

• The number of tiers in the recycling chain, or the location of those operations, is not strictly relevant to this calculation.

Clarification 1-5. Regarding 4.5.1.2 – Early adopter of a new ENERGY STAR standard:

The revision of the 1680.1 standard in 2010 clarified this issue and the Clarification is thus eliminated.

Clarification 1-6. Regarding 4.6.1.2 – Optional corporate annual report criterion: Auditing of recycling vendors.

Subscribers have asked: What is the geographic scope of this criterion? Are only the recycling vendors in North America (or the US) required to be audited annually to the 3rd tier, or does the criterion have worldwide application? If worldwide, does that mean all regions where first through third tier recyclers are located, or all regions where the product is sold? It has also been asked what type of auditing is required.

Background Analysis: This criterion was adopted late in the EPEAT development process and was discussed as being a partial “make-up” for not including restrictions on export of product to be recycled. Auditing of recycling vendors was discussed as partial protection against environmentally irresponsible recycling, including overseas where the major problems have been documented.

Further Background Analysis: The revision of the 1680.1 Standard added language to both 4.6.1.1 and 4.6.1.2 that clarified the geographic application of the criteria. These revisions require a change of some of the text in the Clarification, but not the essential message. Following is the revised Clarification.

Clarification 4-1.Regarding 4.1.4.1 Optional – Elimination of intentionally added lead in certain applications

Some manufacturers have asked what the limits are of components “that are directly used to generate an image”. Are graphics cards, chipsets, and processors included that are part of the computer, but are involved in sending a signal to the display device? Especially the question has arisen regarding what components of a notebook or an integrated computer are covered by this criterion, since the display device and the computer are part of the same unit.

Background: This criterion was meant to provide an optional point for reducing the lead content of VDUs beyond those mandated in RoHS. The full wording of the standard follows:

Product Criterion: The VDU, including housing, batteries, cables, adapters and other peripheral equipment used to generate an image, shall not contain lead greater than 50 ppm by weight per listed part unless it can be shown that the lead is present above this threshold due to the use of recycled content.

Applies to: VDUs only, including stand-alone units and those components of an integrated unit, e.g., a notebook computer, that are directly used to generate an image. This does not apply to European RoHS Directive exemptions.

Definition: 3.1.18 video display unit: a cathode ray tube, cathode ray tube device, and flat panel screen or similar display device, including stand alone units and those components of an integrated unit, e.g. a notebook computer, that are directly used to generate an image

PVC Clarification: The interpretation of this criterion should be consistent between stand-alone and integrated VDUs. For a stand-alone VDU, the criterion clearly covers any processors, chips, boards or other components that are resident in the VDU and are required to make it work, i.e. provide power, illuminate the screen, accept and translate an image from an external source, etc. It would therefore not apply to processors, boards, or chipsets that reside in the computer and are independent of the VDU, even though they are necessary for generating an image. This same principle should apply to notebooks and integrated units. The criterion therefore covers those parts and components that are functionally equivalent to those found in a stand-alone VDU, but would not cover graphics cards, processors and other components that are typically physically separate from the stand alone VDU.

Clarifications #5 – September 2008

Clarification Request 5-1 :

Shall glass filler in plastic components be included, or not included, in the calculation of the weight of plastic in the component? Should the weight of the glass filler be added into the denominator along with the weight of the other plastic?

A corollary question is whether glass filler should be included in the numerator as part of the recycled plastic.

Background:

Glass filler is blended with resin to form a plastic with special characteristics that is used in certain internal electronic components. Other materials may also be added, including, but not limited to, flame retardants or plasticizers.

The postconsumer recycled plastic content for the product as a whole is calculated as a percentage, whereby the total amount of postconsumer plastic in all the components is divided by the total amount of plastic in the product, and multiplied by 100. PCBs and packaging are excluded from the calculation.

Note that the criterion uses the term “plastic”, versus “resin” or some equivalent. The clarification hinges on this. The term plastic (the noun) is defined as “a plastic substance”, and plastic (the adjective) is defined as “capable of being molded or modeled”. Plastic is therefore defined by its physical characteristics.

PVC Clarification 5-1:

1. The denominator – weight of plastic in the product – The weight of the glass filler, and all other additives that are blended to formulate the plastic used to make the component, shall be included in the calculation of the total weight of the plastic for the purpose of calculating postconsumer recycled content.

Rationale: Glass filler is an integral part of the plastic used to make the component and, when blended with the resin and other additives has the characteristics of a plastic material.

2. The numerator – weight of recycled plastic in the product – Glass filler that is added as glass to the plastic, regardless of whether it is recycled or virgin glass shall not be included in the calculation of the amount of recycled plastic (the numerator). However, if the source of the glass filler is from postconsumer recycled plastic that contains glass filler, it shall then be included in the calculation of the amount of recycled plastic. The same applies to other additives.

Rationale: The criteria address plastics only. As noted, the definition of plastic references its physical characteristics. Therefore, it is the physical characteristics of the source material that determines whether it is recycled plastic. In the form of glass, it is not a plastic. However, when the source of the glass is from recycled plastic that contains glass filler, it is then in the form of plastic.

Example 1: Start with a 100g part that is made of a glass filled plastic. This part is ground and formed into pellets, and reformed into a new 100g part. Even though this part has a glass content, because I have recycled the entire glass filled plastic part into a new glass filled plastic part, the postconsumer recycled content would be 100%.

Total Weight of Recycled Plastic Content in Part		100g of recycled plastic
_____________________________________	=	_______________________	= 1 x100 = 100%
Total Weight of Plastic Part		100g of total weight of part

Example 2: Start with 20g of glass fill (either virgin or recycled glass) and 80g of plastic resin. This plastic resin is 50% by weight postconsumer recycled plastic and 50% by weight virgin plastic giving a total of 40 g of recycled plastic. The glass fill is blended with the plastic resin (containing 50% recycled resin) to create a 100 g part.

Total Weight of Recycled Plastic Content in Part		40g of recycled plastic
_____________________________________	=	_______________________	= .4 x100 = 40%
Total Weight of Plastic Part		100g of total weight of part

Clarification Request 5-2:

How shall the amount of recycled feedstock be calculated in the case where the recycled feedstock material is separated into parts (either at the molecular or material level) and only some portion of the feedstock is incorporated into the final plastic? Should the full weight of recycled plastic entering the plastic manufacturing process be counted, or only the portion that makes it into the final plastic used in the product?

Background:

Some plastic manufacturing processes break down recovered plastic materials into their chemical constituents and then reformulate resins using these chemical feedstocks. Likewise, recovered plastic parts may be separated by resin type for further processing. In either case, a portion of the incoming material stream may be discarded or used in another application.

PVC Clarification 5-2:

Recovered plastic parts or material that enter the manufacturing process, but are not included in the resulting plastic material that is used in the product, shall not be counted as recycled content in the product.

Determination of the recycled content of a plastic material in a product shall be a simplified mass balance that determines the weight of recycled material that enters the manufacturing process and calculates the weight of recycled material that is included in the “total plastic (by weight) in each product” (wording from the standard).

Rationale:

The criteria clearly refer to the recycled content of the product declared to EPEAT. Therefore, any portion of recovered plastic material that is discarded or diverted to another application would not be included in this calculation.

Clarification Request 5-3:

Should certain plastic components that do not lend themselves to recycled content due to functional or performance issues be excluded from, or included in, the calculation of the amount of plastic in the product (denominator)?

Background:

A subscriber expressed the opinion that only molded plastic parts/mechanical parts are currently being counted towards the total plastic weight in the product by subscribers and in verification. They expressed that certain plastic parts due to performance issues (e.g. clarity, product safety, etc.) are not good candidates for biobased or postconsumer recycled plastics, such as cable jackets, insulating sheets, light guides, and optical films. Furthermore, the subscriber believes that this was the intention of the standard development team.

The subscriber also noted that for equipment that uses a high percentage of highly recyclable metal the only plastics in the product may be the light guides, optical films and cable jackets. The overall objective of minimizing fossil fuel use in plastics, and waste from unrecyclable plastics, is achieved, but the product is disadvantaged by not being able to claim the recycled plastic points.

All plastics in the product, regardless of their function, shall be included in the determination of the total weight of plastics in the product, except those components specifically excluded in the standard.

Rationale: The 1680 Standard does not provide a basis for excluding some plastic parts, or portions of parts, according to the function they serve, other than PCBs. PCBs (and packaging in one criterion) are specifically excluded, and therefore there is no basis to believe that the standard developers intended to exclude other plastic components.

Clarifications #6 – January 2010

Clarification 6-1: Regarding 4.4.2.2 – Optional criterion: Modular design

 The following was received from two subscribers and a supplier. Their names have been replaced with X, Y and Z.:

X, Y and Z formally request an interpretation and clarification of the IEEE 1680 standard for criteria 4.4.2.2 – Optional criteria for modular design by the EPEAT Product Verification Committee. This is a follow up to the request made by X in May 2009.

The modular design 4.4.2.2 product optional criteria states:  Product shall have a modular design; for example, major components and processor can be changed.

Specifically, the EPEAT conformity assessment protocols guidance document (http://www.epeat.net/Docs/Protocols%204%204%20v.1.2.pdf page 4.4-9) states that processors cannot be soldered to the motherboard as shown in the table below.

Evaluation Guidance

Modularity means that major components must be easily removable, have standard connectors, and are readily replaceable. Processor cannot be soldered to motherboard. Note that criterion does not require that modules must be changeable by user and may be limited to designated service entities or the manufacturer. However, stating "take item to service entity" does not fulfill the "description of the module change method", which must be provided for the service entity.

At this time no interpretations or clarifications for modular design have been issued since the EPEAT criteria were developed in 2004 and 2005 and finalized as the IEEE 1680 standard in mid-2006. As you know, electronics technology is advancing rapidly with entirely new generations of technology and products introduced every 12 – 18 months. The latest processor technology often uses processors that are soldered to motherboards or cards to enable slimmer, lighter form factors that reduce the weight and materials used in both notebook and desktop computers. The latest products are also lower voltage with significantly improved energy efficiency.

X, Y and Z believe the original intent of the modular design criteria was to allow for the processor to be replaced as a singular component as it is provided as an example.  The standard, however, does not explicitly state that the processor must be singularly replaceable. Allowing motherboards with soldered processors to be replaced as an upgrade option to meet the modular design criteria is desirable for the following reasons:

·         Processors and motherboards work as a single subassembly or component. In product repair or upgrade situations the entire board is normally replaced rather than single components.

·         Today’s technologies increasingly use processors soldered to boards that help enable slimmer, lighter form factors that reduce materials use. For example new ultra portable notebooks and netbooks weigh about 3 pounds, while the previous generations of notebooks weigh 5 pounds or more. Weight examples for various models are available on the web sites for X and Y.

·         The new lighter models also are lower voltage and more energy efficient. The new smaller form factor systems are in the 30 watt range and older models about 100 watts.

·         Note that these new, lower cost products help enable access to technology and the internet for more consumers globally. As EPEAT becomes more active in retail situations this criteria will become more important to clarify.

The requested interpretation would not require a modification of the standard itself. However, the language noted above in the Conformity Assessment Protocols on the EPEAT.net website should be considered for modification to allow replacing entire motherboards (or similar module) with soldered processors as a valid upgrade option to meet the modular design optional criteria 4.4.2.2.

Background Analysis:

Staff is, of course, unwilling to change the protocols until the PVC provides direction.  A literal reading of the criterion states that the processor must be changeable, and that is the provision in the Protocols.

However, there are two factors to be considered:

1.       The case is made by the supplicants that, in essence, the intent can be met by considering the entire motherboard as the module, and allowing the replacement of the motherboard to be equivalent to “processor can be changed”.

2.       The reference to the processor is an example. The criterion reads “for example”, it does not read “including”. Does referencing an example mean that the example must be included, or may be included?

Clearly, this criterion will be subject to revision when the 1680.1 standard is reopened this coming year.  However, for at least a year this optional criterion will not be available to subscribers that use certain popular processors that are designed to be, and apparently are only available, soldered to the motherboard.

The PVC determination is based on the following logic:

·         The intent of the standard developers was to assure that the processor alone could be changed, and therefore it is not appropriate for the PVC to allow that the entire motherboard must be changed in order to change the processor.

·         While non-removable processors are supported by current design and recycling practices, EPEAT is intended to drive environmentally preferable change, not to adapt to industry practice. It’s not clear that removable processors are not technologically feasible. Rather, it is current industry practice. Couldn’t EPEAT drive a change in this practice if left as is?

·         LCAs show that the manufacture of electronic components (and upstream processes) contribute substantially to the environmental impact of computer products. If the PVC allows that the entire motherboard must be replaced in order to change the processor, we are significantly reducing the environmental benefit of this criterion.

·         Changing out the motherboard which has other functions integrated on the board defeats the purpose of extending the life of a product and reducing the environmental impact.

·         Finally, this is an optional criteria. If the intent is changed, the standard will be giving away a point, rather than creating an incentive towards a stretch goal.

PVC Determination: The criterion requires that the processor must be changeable independent of other components such as the circuit board to which it is attached.

The following was received from a subscriber:

I am being asked for clarification to a specific example where we have calculated a PCC for plastic as being 9.99%.  What guidance would you give me to pass along to our design team?  Do they have to reformulate to be at least or higher or is there a provision for rounding.

Background Analysis: The applicable provision in the standard reads: “Product shall contain on average a minimum of 10% postconsumer recycled plastic”.

The standard sets a threshold of 10%, not a specific value to be achieved.  Therefore it is not valid to round up to that amount in a declaration of conformance.  If the standard were to specify an amount to be achieved (no examples are identified), then normal rounding practice would apply.

PVC Determination:  When the standard sets a threshold of a specified amount, or of a percentage, for a specified quantity, the threshold cannot be said to be met if the actual amount is rounded up from below (or down from above) that amount. For example, a threshold of 10% recycled plastic means that the amount of recycled plastic must be at least 10%.  The calculated value of recycled plastic must be at or above the stated threshold.  Rounding a percentage up to the threshold is not allowed.

Subscribers must report the specified quantity with the highest level of accuracy their measurements allow, following standard engineering practice for significant digits.

A threshold is signified by language such as the following, or its equivalent:

·         A floor: “greater than”, “>”, “a minimum of”, “not less than”, “minimum”.

·         A ceiling: “less than” “<”, “a maximum of”, “not more than”, “shall not exceed”, “maximum”.

 The criterion reads:

Product Criterion: Spare parts and/or compatible replacement parts shall be available five years after end of production. Information on how to obtain replacement parts shall be provided to user.

Several issues were identified with this criterion in Verification Round 4 and the bulleted text below was decided on by the PVC during that Round.

PVC Determination:  The following principles shall be applied in determining conformance with criterion 4.4.3.1:

·         The whole product is not a part. The intent of the criterion is to extend the life of the product by replacing parts. So replacement of the whole product does not meet the intent.

·         The replacement parts must be available regardless of whether the user has taken an extended warranty.

·         Any charges for replacement parts are up to the subscriber, or their designated agent (the party who provides the replacement parts).

·         The subscriber is responsible for assuring that any agent designated to provide replacement parts will meet the replacement part requirements for the required period of time – 5 years after end of production.

·         The subscriber can determine for which parts replacement parts will be made available.

·         Parts may, at subscriber’s choice and user notification, be available only through service centers that do the replacement.

·         Replacement parts may be after-market, or refurbished, etc.

·         EPEAT can verify, within the 5-year period after end-of-production, that this criterion is met for products that have been archived.

The finding of an NC for this criterion should trigger EPEAT staff to request the subscriber to check that corrective action is taken for all their products, where needed.  EPEAT staff will subsequently check with the subscriber to make sure that such actions have been taken.