Conformity Packet 1680.3: 4.6

Conformity Guidance 1680.3: 4.6.1.1 Conformity Guidance 1680.3: 4.6.1.2 Conformity Guidance 1680.3: 4.6.2.1 Conformity Guidance 1680.3: 4.6.2.2

1680.3 4.6

Conformity Guidance 1680.3: 4.6.1.1Required: Provision of product take-back service

1680.3 4.6.1.1

Applicable Interpretations,Clarifications, Outcome Reports

Document/Evidence Request Document Review Standards Common Conformity Issues and Details to Remember

EPEAT ClarificationsClarification 34

Outcomes ReportsIE 2013-02

List of first-tier recyclers and/or management companies involved in take-back program.

Documentation showing business relationship exists with each listed recycler and/or management company (e.g. contracts, invoices, receiving documents).

Notification to purchaser of take-back service (e.g. URL, purchaser, contract, product literature).

Evidence declaring any direct costs to the consumer at the point of service for the take-back service.

If the manufacturer participates in the country’s regulatory recycling system, provide evidence of compliance with the system in the area where the product is registered.

List should include all first tier recyclers providing recycling, refurbishing and/or reuse service for the take-back program, and an indication of how they process the equipment and materials in the applicable country(ies).

Document should show business relationship with recycler(s) and/or management companies exists before the registration of applicable products.

Notification should adequately explain how purchasers can utilize the take-back program. If manufacturer participates in regulatory schemes for take-back, they still must notify the purchaser how the purchaser can participate in those schemes.

Evidence must indicate direct costs (if any) to the consumer to utilize the take-back program.

Evidence must indicate the manufacturer participates in the regulatory system and is in compliance with the specific regulatory system (e.g. contract, country registration, receipts).

If the manufacturer uses authorized distributors to sell products, evidence may be required to show the distributors are provided notification of the take-back. service at the time of sale of the product.

Take-back management services may be provide via contracts or leases for commercial customers.

Take-back programs must be provided in all countries where this criterion is declared, but can be implemented differently depending on the country.

Takeback is not required to be free and the manufacturer must declare any direct costs to consumers at the point of sale.

Somewhat difficult to

demonstrate conformance

Sample Conformity Packet

1680.34.6.1.1 Required: Provision of product take-back service

1680.3 4.6.1.1

The following data samples and explanation are intended to illustrate examples of acceptable data. Other types or forms of data may also be acceptable in conformity documentation.

Take-back program must be established before product

registration on EPEAT

Company Name

Country by distributor

Documentation of Take Back Service

1680.3 4.6.1.1

List of First Tier recyclers

1st Tier Recyclers

SIMS Recycling Solutions

ERS International

Provide evidence of business relationship with each first tier recycler

through a contract, invoice, or other supporting documents

Take-back service may be provided by distributors as well as the OEM but OEM is responsible for ensuring

take-back services is provided.

Note that these fees are what the manufacturer pays and do not provide

information related to what the purchaser / user pays for the service.

Notification to User of Take-Back Service

1680.3 4.6.1.1

The manufacturer may submit a URL that notifies the user of how they can find more information about the

take-back service.www.companyxyz/learn/us/en/takeback/

How it works

We'll pick up any COMPANY XYZ product for free*, anywhere* in Canada. Currently, the At-Home Pickup program is only available for Canada shipments through Authorized Company.

Make sure you have backed up or transferred all data.Ensure all confidential data has been deleted from your hard drive.Fill in your information online** and Authorized Company will email you a prepaid waybill and instructions on how to schedule a pickup.Call Authorized Company to schedule your pickup. Let Authorized Company know you would like to schedule a pickup for the Company XYZ Return Program.Wait for Authorized Company to pick up your package within the agreed pickup schedule, or you may leave the package outside your door on the day you have scheduled the pickup.

Notification of take-back service should include country(ies) where it is

offered and generally how the purchaser can take

advantage of it.

Declaration of direct costs to customer to use the take-back program

1680.3 4.6.1.1

How it works

We'll pick up any COMPANY XYZ product for free*, anywhere* in Canada. Currently, the At-Home Pickup program is only available for Canada shipments through Authorized Company.

Make sure you have backed up or transferred all data.Ensure all confidential data has been deleted from your hard drive.Fill in your information online** and Authorized Company will email you a prepaid waybill and instructions on how to schedule a pickup.Call Authorized Company to schedule your pickup. Let Authorized Company know you would like to schedule a pickup for the Company XYZ Return Program.Wait for Authorized Company to pick up your package within the agreed pickup schedule, or you may leave the package outside your door on the day you have scheduled the pickup.

This website declares that it is free to participate in the take-back program. Note

that the take-back program does not need to be free to

be conformant to this criterion.

Conformity Guidance 1680.3: 4.6.1.2Optional: Provision of take-back service for broader scope of products

1680.3 4.6.1.2

Applicable Interpretations,Clarifications, Outcome Reports

Document/Evidence Request Document Review Standards Common Conformity Issuesand Details to Remember

EPEAT ClarificationsClarification 26

Outcomes ReportsIE 2015-03IE 2014-02IE 2013-02

For each applicable country where the manufacturer registers products and offers take back services pursuant to 4.6.1.1, provide:

Annual disclosure of volumes by weight for all consumer electronics1 that the company manufactures or manufactured, under all the brand names owned by the manufacturer with the following data:

a) Volume of products collected in jurisdictions with local2 or federally mandated collection programs;

b) Volume of products collected voluntarily (efforts beyond required collection under local or federally mandated programs)

c) Total volume of products collected

Disclosure of volumes must appear on the manufacturer’s website. The annual disclosures should be available for the previous two consecutive years OR if only a single disclosure is available, one annual disclosure and procedure/policy committing to the annual disclosure.

Regarding reporting requirement a):· If a country has local or federally mandated requirements for

recycling consumer electronics and if these mandates require reporting of recycling volumes by manufacturers or brand owners, the annual disclosure will not be zero.· If a country has local or federally mandated requirements for

recycling consumer electronics where data is only collected by local or federal program, and not subsequently provided to manufacturer, then the annual disclosure can state “not publicly available” or “unknown”. Information to support this claim must be provided.· If a value of zero is claimed, evidence must prove that there are

no local or federally mandated requirements for manufacturers to recycle consumer electronics, either individually or in cooperative schemes.

Regarding reporting requirement b): The voluntary take-back only needs to be demonstrated after product declaration.

You may disclose ‘0’ for voluntary take-back of consumer electronics if it is within one year of the criteria declaration. See Clarification 26 for more details.

Disclosures must be on the manufacturer’s website, even if disclosure is ‘0’.

Disclosures must include all the reporting requirements – they should not combine reporting requirements a and b to show only the total volume of products collected.

A listing should be provided about which consumer electronics are included in the broader scope.

Disclosure is required for each country where the manufacturer registers products. Disclosures should state which country they are reporting on.

1Consumer electronics is defined as electronic equipment, including, but not limited to, TVs, VCRs/DVDs/DVRs, home theater, handheld and software-based games, computers, printers, andInternet appliances. 2 The term ‘local’ includes state and provincial programs. See Clarification 26 for more details.

Somewhat difficult to

demonstrate conformance

Sample Conformity Packet

1680.34.6.1.2 Optional – Provision of take-back service for broader scope of products

1680.3 4.6.1.2

The following data samples and explanation are intended to illustrate examples of acceptable data. Other types or forms of data may also be acceptable in conformity documentation.

• Company XYZ provides take back services for all consumer electronic products it manufacturers,

including faxes, printers, computers, monitors, and all-in-ones. Click here for information regarding

mail-back and drop off locations.

• To view the volume of products collected through the take back program, see:

www.companyxyz/recycling/allelectronics/reporting

Evidence of takeback program for broader scope of products

1680.3 4.6.1.2

This describes the availability of the take-

back program for a broader scope of products

than those that are registered in EPEAT,

including a list of the types of consumer products.

It also provides a link to where the volume

disclosures are available

Annual Volume Disclosures for declared country

1680.3 4.6.1.2

Volume of products collected in the United States

FY 2015(Metric Tons)

FY 2016(Metric Tons)

In jurisdictions with local or federally mandated collection programs

7,450.4 8,500

Collected voluntarily

1,688.3 800.65

Total 9,138.7 9,300.65

This shows annual disclosures of reporting requirements a, b, and c for all consumer electronics. Since there

are two consecutive years, it also indicates a history of annual

disclosures.

Notice that each reporting requirement are separate data points.

Note that the country is identified.

Conformity Guidance 1680.3: 4.6.2.1Required: End-of-life processing requirements

1680.3 4.6.2.1

Applicable Interpretations,Clarifications, Outcome Reports

Document/Evidence Request Document Review Standards Common Conformity Issues and Details to Remember

EPEAT ClarificationsClarification 17Clarification 18Clarification 24Clarification 34

Outcomes ReportsIE 2015-03IE 2014-02IE 2013-02Note: This criterion was impacted by a revision to the 1680.3 standard in 2017. All outcomes reports listed here apply to the previous version of the criterion.

A list or map of all initial service providers and locations used by the manufacturer for end of life processing

Evidence of a business relationship between the manufacturer and each initial service provider

Documentation which demonstrates participation in a nationwide recycling scheme which has been approved by the government of the country being verified (this option is available when manufacturers do not have control of the selection of initial service providers)

AND (if the government approved program only covers a portion of a country)/OR

Copy of a report of findings from the auditor or auditing body

Evidence of accreditation from auditing body and/or evidence that demonstrates auditor’s competency

List or map must include all initial service providers used by the manufacturer for end of life processing, including their locations

Evidence must name both the manufacturer and service provider and demonstrate a current relationship

Documentation must show the following:• The manufacturer participates in the recycling scheme

and the scheme is approved by the government in the country being verified (e.g. contracts, tipping invoice)

• The scope of the products accepted by the recycling scheme

• Documentation must demonstrate adherence to the requirements for a Qualified Recycling Standard listed in the criterion

Audit results must include all Conformances, Nonconformances, and corrective action plan for any Nonconformances found.

Acceptable accreditations for auditors include ISO/IEC 17021 or ISO/IEC 17065. Auditor’s competency should include environmental management systems and the qualified recycling standard.

End of life materials are not required to be processed in the same country they are collected

In the event that a government approved program only covers a portion of a country, manufacturer must demonstrate that initial service providers meet the criterion requirements in any part(s) of the country not covered by the program

Products declared in the US or Canada must prove conformance either through participation in a nationwide take back program or by demonstrating that initial service providers are certified to a qualified recycling standard

Clarification 24 provides additional detail regarding the definition of “components, scrap, and materials derived from equipment” from exempt programs

1 Qualified recycling standards include R2, E-Stewards, EN 50625 Series, and WEEELABex V10. Other recycling standards may be qualified by GEC according to the criterion details.

Very difficult to

demonstrate conformance

Updated 10-24-17 after 1680.3 Revisions

Continued on next page

Conformity Guidance 1680.3: 4.6.2.1Required: End-of-life processing requirements

1680.3 4.6.2.1

Applicable Interpretations,Clarifications, Outcome Reports

Document/Evidence Request Document Review Standards Common Conformity Issues and Details to Remember

A statement from the manufacturer regarding performance of the auditor or auditing body

OR

Copy of initial service provider’s certificate to a qualified recycling standard1

If using an agent for recycling services, copy of contracts between the manufacturer and agent, and agent and service provider

If any exemptions are claimed2, evidence that the manufacturer complies with all requirements of import, export and transit countries

AND

Evidence that the manufacturer sends residual materials to a recycler that meets the standards outlined in the Standard

Statement should address whether the auditor or auditing body conforms with the qualified recycling standards, if there is a corrective action plan in place ,or the manufacturer plans to sever business ties with the service provider

Certificates must be current and must cover all initial service providers.

Contracts should have terms covering the period of investigation

Evidence should clearly state that the manufacturer is in compliance with all applicable requirements

Evidence should prove a business relationship between the manufacturer and recycler that accepts this material

2Exemptions are listed in 1680.3 4.6.1.1.

Very difficult to

demonstrate conformance

Continued

Sample Conformity Packet

1680.34.6.2.1: Required– End-of-life processing requirements

1680.3 4.6.2.1

The following data samples and explanation are intended to illustrate examples of acceptable data. Other types or forms of data may also be acceptable in conformity documentation.

List of initial service providers and qualified recycling standard

1680.3 4.6.2.1

Service Provider (in Canada) Qualified Recycling Standard

SIMS Recycling Solutions E-Stewards

Global E-Waste Solutions Ltd. R2 Certification

This list of initial service providers (for the take-back

program from 4.6.1.1) indicates the qualified

recycling standard that each meets. You can find qualified

recycling standards on the EPEAT website:

http://www.epeat.net/resources/recycling/#tabs-

1=overviewNote that this list should pertain to the country for

which the criteria is claimed.

Documentation showing legal relationship with initial service providers

1680.3 4.6.2.1

Company Name

Company XThis invoice indicating that a customer account has been created establishes a

legal business relationship with this initial service provider. Evidence of a

legal relationship must be provided for ALL initial service providers.

Evidence of certification to qualified recycling standard for each initial service provider

1680.3 4.6.2.1

For each initial service provider,provide a current certificate to the qualified recycling standard.

For initial service providers that are not certified to a qualified recycling standard, a second or third party audit to the criterion requirements (a-i) can be provided instead. This option is available for 18 months after initial registration in EPEAT.

For exempt programs, evidence of legal compliance with export/import and transit countries

1680.3 4.6.2.1

It is helpful to provide a list of the exempt programs, which of three types they are, and which import/export or

transit country is involved.

Program Type Program Name Country

Product Servicing and/or Warranty Returns

Exchange Depot Transit only within Canada

Product Servicing and/or Warranty Returns

Parts Return Depot Transit only within Canada

In this example, since products are only shipped within the same country, this requirement does not apply. If the

products were exported to other countries, then evidence of legal compliance with export/import country might include

an audit report or an export/import certificate indicating compliance with that countries’ legal requirements. Likewise,

because all residual or scrap materials are only shipped within the same country, no evidence is needed to prove

legal compliance.

Conformity Guidance 1680.3: 4.6.2.2Optional: Certification of programs exempt from end-of-life processing requirements

1680.3 4.6.2.2

Applicable Interpretations,Clarifications, Outcome Reports

Document/Evidence Request Document Review Standards Common Conformity Issues and Details to Remember

EPEAT ClarificationsClarification 17Clarification 21Clarification 24Clarification 34

Outcomes ReportsNever been verified (as of December 2016)

Provide a list or map of exempt1 programs and/or facilities claimed in 4.6.2.1 for the declared country/region and the qualified recycling standard2

that they meet in the specific country

For each of the exempt1 programs and/or facilities, provide a certificate for the qualified recycling standard from on independent certification body. In countries where no exempt program providers are certified to a qualified recycling standard, provide second or third party audit reports to the declared qualified recycling standard2

List or map should include all exempt programs/facilities claimed in 4.6.2.1 for the declared country/region for the organization and the qualified recycling standard that they meet in the specific country

Certificate must be current and be from an independent certification body that is accredited by an IAF accreditation body.

The list or map must include ALL EXeMPTPROGRAMS. If a manufacturer meets the requirements for two of the exempt programs but also has a third exempt program that does not meet this requirement, then this criterion may not be claimed.

If a manufacturer meets the requirements for all exempt programs, then this criterion may be claimed.

This is an annual corporate criterion. This criterion is only applicable in those

regions or countries for which products are declared on the EPEAT Registry.

1The following programs are exempt: management of leased product where the manufacturer (or contractual agent) retains legal ownership; trade-in/exchange programs where the customer surrenders the product to the manufacturer (or the contractual agent) in return for compensation or replacement product; product servicing and/or warranty programs, operated by the manufacturer or their contractual agent, where a product is returned to a customer. Manufacturers may choose not to exercise these exemptions and instead can certify these programs. 2EPEAT has determined qualified recycling standards that meet the criterion requirements. They can be found here: http://www.epeat.net/resources/recycling/#tabs-1=imagingequipment

Very difficult to

demonstrate conformance

Sample Conformity Packet

1680.34.6.2.2: Optional– Certification of programs exempt from end-of-life processing requirements

1680.3 4.6.2.2

The following data samples and explanation are intended to illustrate examples of acceptable data. Other types or forms of data may also be acceptable in conformity documentation.

List of exempt programs and qualified recycling standard certificate

1680.3 4.6.2.2

Program Type Program Name

Product Servicing and/or Warranty Returns

Exchange Depot

Product Servicing and/or Warranty Returns

Parts Return Depot

Provide a list of the exempt programs, and which of three types they are.

If a manufacturer has even one exempted program that does NOT

meet the requirements of this criterion, they may not claim it.

For each exempt program, provide a current certificate to the qualified recycling standard.

For exempt programs that are not certified to a qualified recycling standard, a second or third party audit to a qualified recycling standard can be provided instead. This option is available for 18 months after initial registration in EPEAT.

Note: Three exempt programs per 4.6.1.2:

1. Management of lease products 2. Trade-in / exchange programs

3. Product servicing and / or warranty programs.

* See criterion 4.6.1.2 for more information.