EPEAT Requirements of PREs Published 26 January 2015 By The Green Electronics Council EPEAT Requirements of PREs Page 1
Context This EPEAT Requirements of PREs document is part of a set of documents that describe the EPEAT green electronics product registration system or scheme. It should be read in the context of the other documents. EPEAT Program Guidelines EPEAT Standards Development EPEAT Product Registration System EPEAT Promotion and Messaging EPEAT Requirements of Manufacturers EPEAT Requirements of PREs ISO/IEC 17020 EPEAT Requirements of PREs Page 2
Contents Context... 2 1 Introduction... 4 2 Effective Date... 4 3 Purpose, Scope, References and Definitions... 4 3.1 Purpose and Scope... 4 3.2 References and Definitions... 4 4 Requirements of Product Registration Entities (PREs)... 5 4.1 Application Phase... 5 4.2 Requirements of Approved PREs... 6 4.3 General Requirements of Approved PREs... 6 4.3.1 Scope... 6 4.3.2 Terms and Definitions... 7 4.3.3 General Requirements... 7 4.3.4 Structural Requirements... 7 4.3.5 Resource Requirements... 8 4.3.6 Process Requirements... 8 4.3.7 Complaints and Appeals... 9 4.3.8 Complaints and Appeals Process... 9 4.3.9 Management System Requirements... 9 4.4 Assuring Conformance of PREs... 10 4.4.1 PRE Audit Methodology... 10 4.4.2 PRE Audit Schedule... 11 4.4.3 PRE s Role in Supporting Audits... 11 4.4.4 PRE Audit Reporting and Corrective Actions... 11 4.5 Advertising and Communicating about EPEAT PRE Services... 11 5 Amendments, Modifications and Revisions... 12 6 For More Information... 12 EPEAT Requirements of PREs Page 3
1 Introduction EPEAT is a comprehensive environmental rating system that helps purchasers identify greener electronic equipment. General information on EPEAT is contained in EPEAT Program Guidelines. More specific information about product registration and the conformity assurance program are contained in EPEAT Product Registration System. Product Registration Entities (PREs) play a key role in the EPEAT system: They are the gateway through which products appear on the registry. They support participating manufacturers to understand the requirements and how to prove conformance, and they contribute to the maintenance and assurance of the accuracy of the registry. EPEAT approves organizations to work as PREs within the EPEAT system. This document identifies EPEAT s requirements of PREs. 2 Effective Date This version of this EPEAT Requirements of PREs shall be effective for all approved PREs on January 1, 2016. 3 Purpose, Scope, References and Definitions 3.1 Purpose and Scope This document specifies the requirements and provides guidance for the approval of PREs under EPEAT. It supplements the requirements of ISO/IEC 17020, by tailoring the requirements of ISO/IEC 17020 to the PRE requirements covered by EPEAT. ISO/IEC 17020 and this document constitute the collective body of requirements that must be met by a PRE seeking approval for the EPEAT program. This document applies to all organizations approved by EPEAT as a PRE. 3.2 References and Definitions The following documents are indispensable for the application of this EPEAT Requirements of PREs, in some cases with amendments as identified. Definitions within these documents are included by reference. Undated references indicate that the latest edition of the referenced document applies. Product environmental standards implemented in the EPEAT system EPEAT Program Guidelines developed and maintained by the Green Electronics Council EPEAT License and Subscriber Agreement between EPEAT and each participating manufacturer EPEAT Product Registration Agreement between an EPEAT approved PRE and a participating manufacturer EPEAT Requirements of PREs Page 4
EPEAT Essential Terms for Agreements between an EPEAT approved PRE and a participating manufacturer EPEAT PRE Agreement between EPEAT and an EPEAT approved PRE Appropriate Use of the EPEAT Name and Marks as developed and maintained by the Green Electronics Council ISO/IEC 17000, Conformity assessment Vocabulary and general principals ISO/IEC 17025, General requirements for the competence of calibration and testing laboratories ISO/IEC 17020, General requirements for the competence of inspection bodies Other definitions that apply to this EPEAT Product Registration System include: Conformance Consistent with the definition of conformity assessment in ISO 17000, Conformance means that the manufacturer meets the requirements of (conforms to) the EPEAT Scheme, including that they can prove the accuracy of their declarations within 30 days of EPEAT s request following the rules of the scheme. 4 Requirements of Product Registration Entities (PREs) To become a functioning PRE in the EPEAT system an organization progresses through stages as follows: Applicant The organization has applied to be a PRE in the EPEAT system. Approved The organization has signed a PRE agreement with EPEAT, and EPEAT has accepted it. On execution of a PRE contract the new PRE may offer EPEAT PRE Service to client manufacturers. An approved PRE becomes qualified to support registration to specific criteria of a specific standard by receiving training and support from EPEAT. This process is largely behind-the-scenes between EPEAT and the PRE and is not apparent to the market. The general processes to progress through these stages are shown in flow charts contained in the EPEAT Product Registration System document. EPEAT s requirements of PREs in these stages are described below. 4.1 Application Phase Organizations may apply to EPEAT to become an EPEAT Approved PRE. The application form and further details on applying may be found here. The following are eligibility requirements to apply to be a PRE: The applicant body is accredited to ISO 17020 or 17065 (or Guide 65) by an IAF-member AB or, if the body is part of a larger organization, the larger organization must have bodies that are so accredited. EPEAT Requirements of PREs Page 5
The applicant body must identify the countries in which they plan to support registration and how they will do that. The applicant must commit to signing the PRE Agreement, receiving PRE training, and to acquire and maintain the services of at least two trained QVs. On EPEAT s approval of an applicant, EPEAT will offer the applicant a contract to be a PRE in the EPEAT system. On EPEAT s acceptance of the contract, EPEAT and the applicant may make a coordinated public announcement and the PRE may begin to solicit business as an Approved PRE. 4.2 Requirements of Approved PREs Before a PRE may provide EPEAT PRE Service and in order to continue providing service, they must meet the following requirements: I. PRE personnel responsible for providing EPEAT PRE Service shall attend PRE training provided by EPEAT, per requirement 4.3.8 below. II. The PRE must qualify and maintain at least 2 Qualified Verifiers (QV) based on the QV s education, experience and training, per requirement 4.3.8 below. The training must be passed within the last year, or if the training was taken longer ago than one year prior the PRE shall demonstrate that the QV has regularly applied their QV training by functioning as a QV for a PRE. III. The PRE must prepare, and EPEAT approve, a plan for how they will evaluate conformance of a manufacturer s declarations to the criteria of the standards that they plan to support in the countries they plan to support, paying special attention to the criteria that may vary by country. EPEAT can provide additional guidance. IV. The PRE must develop a contract for PRE service that must be executed with their client manufacturers. The contract must include EPEAT Essential Terms. If the contract includes EPEAT Essential Terms verbatim it is not necessary for EPEAT to approve the PRE s contract for EPEAT PRE Service. If the PRE wishes to reformulate EPEAT Essential Terms then EPEAT must approve the PRE s contract before it is offered to manufacturers. The contract that EPEAT reviews and approves shall not contain pricing information. When the PRE meets these requirements in EPEAT s judgment, EPEAT may give the PRE a password to access the registry and the PRE may provide EPEAT PRE Service to their client manufacturers. 4.3 General Requirements of Approved PREs Within one year of being approved as an EPEAT PRE and continuously thereafter, approved PREs must meet the requirements of ISO/IEC 17020, General criteria for the operation of bodies performing inspection, with the following application notes and exceptions. If no exceptions or application notes are identified then the requirement stands without modification. 4.3.1 Scope There are no requirements additional to those set forth in ISO/IEC 17020. EPEAT Requirements of PREs Page 6
4.3.2 Terms and Definitions Throughout ISO 17020, when the standard refers to inspections they shall include assessments of conformance performed in the course of providing EPEAT PRE Service, specifically Desk Review and Verification investigations. Throughout ISO 17020, when the standard refers to the client, both EPEAT and the body s client manufacturers are considered the client. Body refers to a defined organization that performs EPEAT PRE service. A body may be a company in its entirety, or may be part of a larger organization or company. 4.3.3 General Requirements 4.3.3.1 Impartiality and Independence The body shall be a Type A inspection body and shall meet the criteria of annex A of ISO 17020, or a Type C inspection body and shall meet the criteria of annex C of ISO 17020. If the body is a Type C, it shall not be part of a company that registers products in EPEAT. 4.3.3.2 Confidentiality The body shall meet the confidentiality requirements in the EPEAT PRE Contract. These allow the PRE to share with EPEAT information collected from participating manufacturers in the course of provision of EPEAT PRE service, but prevent other disclosure. 4.3.4 Structural Requirements 4.3.4.1 Administrative requirements The body shall be or be part of the legal entity that signs the PRE agreement with GEC. The body s documented scope shall include provision of EPEAT PRE service as defined in the EPEAT PRE Contract. 4.3.4.2 Organization and Management The body shall include in the list of positions that affect the quality of EPEAT PRE services the positions responsible for: o conducting Desk Reviews and for taking a manufacturer off, or placing them on, Desk Review; o conducting Verification investigations; o reviewing and or approving changes of Desk Review status or Investigation Reports related to Verification investigations; o selling EPEAT PRE service; o developing and/or providing communications related to provision of EPEAT PRE service. EPEAT Requirements of PREs Page 7
4.3.5 Resource Requirements 4.3.5.1 Personnel The training requirements of personnel conducting Desk Review and Verification investigations shall include passing EPEAT Qualified Verifier Training covering all the standards that the QV will support, and other training as required by EPEAT, provided or approved by EPEAT. The qualifications for personnel conducting Desk Review and Verification investigations shall include appropriate training, education and experience related to the nature of the specific criteria of the standard. See guidance provided by EPEAT. The training requirements of personnel responsible for selling EPEAT PRE services, for supporting participating manufacturers, and for communicating regarding EPEAT shall include attending EPEAT PRE Training provided or approved by EPEAT. The guidance provided by the body to its staff shall include communicating to staff applicable guidance from EPEAT, including relevant Clarifications and Conformity Assessment Protocols published by EPEAT. 4.3.5.2 Facilities and Equipment If an investigation assigned by EPEAT requires the body to perform laboratory analysis or testing, the work shall be performed by a laboratory that is accredited to ISO/IEC 17025 by an IAF member accreditation body. 4.3.5.3 Subcontracting If an investigation assigned by EPEAT requires the body to subcontract laboratory analysis or testing, the work shall be performed by a laboratory that is accredited to ISO/IEC 17025 by an IAF member accreditation body. 4.3.6 Process Requirements 4.3.6.1 Inspection Methods and Procedures There are no requirements additional to those set forth in ISO/IEC 17020. 4.3.6.2 Handling Inspection Items and Samples From time to time EPEAT may assign to the PRE investigations that require the PRE to independently purchase specific products for inspection, disassembly and/or testing. The requirements of section 11 apply to such investigations. If an assigned investigation includes laboratory testing of a part or component, the PRE shall have documented procedures and appropriate facilities to prevent possible contamination of the samples to be sent to the lab. Further, best efforts shall be made to retain and appropriately identify and protect additional samples from the same part or component to enable re-testing in the event the original samples are misplaced or there is a dispute or question about the lab testing. If an investigation requires disassembly of a product the body shall maintain a photographic or video record of the disassembly process and results. EPEAT Requirements of PREs Page 8
The disassembled product, including packaging, shall be retained by the body for at least six months following filing of the related Investigation Report(s). The visual record shall be retained by the body for at least three years following filing of the related Investigation Report(s). 4.3.6.3 Inspection Records There are no requirements additional to those set forth in ISO/IEC 17020. 4.3.6.4 Inspection Reports and Inspection Certificates The requirements of 7.4.1 apply to Investigation Reports completed following Verification Investigations assigned to the body by EPEAT. 4.3.7 Complaints and Appeals There are no requirements additional to those set forth in ISO/IEC 17020. 4.3.8 Complaints and Appeals Process There are no requirements additional to those set forth in ISO/IEC 17020. 4.3.9 Management System Requirements There are no requirements additional to those set forth in ISO/IEC 17020. 4.3.9.1 Options There are no requirements additional to those set forth in ISO/IEC 17020. 4.3.9.2 Management System Documentation There are no requirements additional to those set forth in ISO/IEC 17020. 4.3.9.3 Control of Documents There are no requirements additional to those set forth in ISO/IEC 17020. 4.3.9.4 Control of Records The requirements of sections 7.4 and 8.4 apply to all records associated with conformity assessment activities performed in the course of providing EPEAT PRE Service, including: o Records associated with Desk Review of specific declarations which result in the body allowing a manufacturer s declaration of conformance to appear on the EPEAT registry. These records shall be retained at least three years after the declaration is approved. o Records associated with evaluating a manufacturer s competence at demonstrating conformance, resulting in a decision to change Desk Review status for specific criteria. These records shall be retained for at least three years after the change in Desk Review status; o Records associated with assigned Verification investigations of conformance resulting in the body recommending conformance or nonconformance on an Investigation Report. These records shall be retained for at least three years after filing of the Investigation Report with EPEAT. EPEAT Requirements of PREs Page 9
Records of personnel qualification involved in providing EPEAT PRE service shall be retained for at least three years after they provide that service. Other business records associated with provision of EPEAT PRE service shall be retained for three years after termination of the applicable contract. 4.3.9.5 Management Review There are no requirements additional to those set forth in ISO/IEC 17020. 4.3.9.6 Internal Audit There are no requirements additional to those set forth in ISO/IEC 17020. 4.3.9.7 Corrective Action There are no requirements additional to those set forth in ISO/IEC 17020. 4.3.9.8 Preventative Action There are no requirements additional to those set forth in ISO/IEC 17020. 4.4 Assuring Conformance of PREs A PRE s conformance with EPEAT Requirements of PREs may be assured in either of three methods at PRE option, as follows. One of these options must be taken and the first audit must occur within 13 months of the PRE s approval by EPEAT: 1. The PRE may obtain and maintain accreditation to ISO/IEC 17020 or 17065 and EPEAT s specific requirements as identified in section 4.3 above by an accreditation body approved by EPEAT. Provision of EPEAT PRE Service must be included in the accreditation scope statement on the certificate. In this case accreditation shall be at the PRE s expense, the PRE shall provide to EPEAT the accreditation certificate on request, EPEAT reserves the right to witness the audits, and the rest of the requirements in this section 4.4 do not apply. 2. The PRE may obtain accreditation to ISO/IEC 17020 or 17065 by an IAF-member accreditation body and EPEAT will audit the PRE to assure conformance to the EPEAT-specific requirements identified in this document. In this case accreditation shall be maintained at the PRE s expense, EPEAT s provision of the audit to EPEAT s requirements is at the PRE s expense as agreed in the PRE service agreement, the PRE shall provide their ISO 17020 certificate on request, and the rest of the requirements in this section 4.4 apply. 3. The PRE may be audited by EPEAT to EPEAT Requirements of PREs including the requirements of ISO/IEC 17020. In this case EPEAT s provision of the audit is at the PRE s expense as agreed in the PRE service agreement and the rest of the requirements in this section 4.4 apply. 4.4.1 PRE Audit Methodology Unless other mutually acceptable arrangements are made the audits shall be of the primary location(s) where PRE service is provided. The first two annual audits must be on-site. Additional audits may be on-site or performed remotely at EPEAT s sole discretion. EPEAT Requirements of PREs Page 10
All records associated with audits are covered by the non-disclosure clause of the contract between EPEAT and each PRE. 4.4.2 PRE Audit Schedule EPEAT audits PREs on the following schedule: The initial audit shall be within 13 months of the date the PRE is approved; The second audit shall be within 13 months of the initial audit; Audits after the first two shall be scheduled based on the results of each previous audit, not to exceed 25 months since the previous audit. 4.4.3 PRE s Role in Supporting Audits PREs are responsible for: Coordinating with EPEAT to plan the audit; Making available the necessary personnel, records, and facilities for EPEAT to conduct the audit; Providing a knowledgeable audit guide who is fluent in English to act as a liaison to help EPEAT obtain and interpret the necessary audit evidence; Developing corrective action plans in response to each identified nonconformance, and implementing the plan. 4.4.4 PRE Audit Reporting and Corrective Actions If the PRE chooses to have EPEAT conduct audits, EPEAT shall provide a draft audit report to the PRE in English within 30 days of completing each audit. The reports shall identify: The audit scope; Audit methodology, duration and resources; Evidence obtained and evaluated; Decision of conformance or nonconformance for each requirement. If the PRE chooses to have a third-party accreditation body conduct audits then the PRE shall provide to EPEAT those audit reports as they relate to provision of EPEAT PRE service. Within 30 days of receiving the audit report, in response to each identified nonconformance the PRE shall propose a corrective action and its timeframe. Within 15 days of receiving the corrective action plan EPEAT shall communicate to the PRE the acceptability of the proposed action and the method and timeframe for follow up. These will typically include the PRE emailing evidence of correction for EPEAT review and approval, or EPEAT simply evaluating it at the next scheduled audit, but may include a required whole or partial re-audit to assure conformance. 4.5 Advertising and Communicating about EPEAT PRE Services EPEAT s mission includes a commitment to promote EPEAT registered products, make the public more aware of the benefit of purchasing EPEAT registered electronics, and EPEAT s role as a sound way to identify greener electronics. EPEAT wants to see the PREs be successful. To enable coordination and EPEAT Requirements of PREs Page 11
consistent messaging toward the goal of mutual success, PREs shall obtain EPEAT s approval of any communications related to EPEAT, EPEAT registered products, and their role as a PRE. 5 Amendments, Modifications and Revisions Amendments, modifications and revisions to this document will be made by EPEAT re-issuing the entire document and updating the effective date. 12 Jan 2015 Original issue. 26 Jan 2015 Revised to add applicant PRE eligibility requirements in section 4.1, to accept accreditation to ISO 17065 in section 4.4, and adjusting section 4.4.4 to accommodate the possibility of an AB conducting the PRE audits. 6 For More Information Contact the Green Electronics Council at: Green Electronics Council 227 SW Pine St., Suite 300 Portland, OR USA 97229 Main phone: (503) 279-9383 EPEAT Requirements of PREs Page 12