IEEE 1680.1 Conformity Assessment Protocols
Introduction
Version 1.3 – January 2011
INTRODUCTION
IEEE 1680.1 Conformity Assessment Protocols
1. Instructions
These verification protocols are derived from and consistent with the Verification Requirements
included for each criterion in the IEEE 1680.1 Standard. The protocols elaborate on those requirements
in order to provide more specific guidance to subscribers about what the Product Verification
Committee (PVC) considers to be adequate evidence to demonstrate conformance. Subscribers may
provide conformance evidence that is different from but equivalent to the data submission items
called out in these protocols.
The overarching purpose of these protocols is to provide consistency and predictability in the
verification process. It is essential in the IEEE 1680.1 self-declaration and after-market verification
system that the evidence provided by subscribers be adequate for a verifier to fully and accurately
assess conformance of the product. The requests in these protocols for submission of evidence are
provided with that intent.
These protocols relate specifically to level 1 investigations. The verification system includes three levels
of investigations:
Level 1 investigations are based on the desk inspection of evidence for conformance provided by
the subscriber. These are by far the most frequent level of investigation.
Level 2 investigations are empirical investigations of conformance with the Standard that may
include interviews with 3rd parties (contract recyclers, suppliers, purchasers, technical experts, etc.),
product examinations possibly with partial disassembly, etc., and may also include a level 1
investigation. Often they are conducted when level 1 investigations are not definitive.
Level 3 investigations are a fully analytical investigation of conformance with the Standard that may
include destructive disassembly, lab tests, etc. and may also include a level 1 and/or level 2
investigation.
Protocols for specific types of level 2 and 3 investigations will be developed.
This document is intended to be used as a companion guidance document to the IEEE 1680.1 Standard.
Please refer to the IEEE 1680.1 Standard for the exact product criterion wording and details.
In addition the Verification pages on www.epeat.net outline verification policies and procedures.
This is a living document that will be updated periodically. Please ensure that the most current version
is being utilized.
2. Verification Paperwork
The subscriber shall provide requested verification data to the Qualified Verifier upon request and
within 30 days. For most criteria, more than one Verification Requirement is specified in the Standard.
All of the Verification Requirements must be provided, except where an “or” specifically provides a
choice.
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The subscriber shall provide an index or inventory of the verification data provided. The index or
inventory shall identify and explain each item and how it contributes to demonstration of conformance
with the criterion in question.
English Language – Verification data shall be provided in English wherever possible, except when a
mutual arrangement can be made with the Verifier to obtain translation of other-language material.
3. Items Included in the Verification Protocols for Each Criterion
This section defines the contents of the specific sections in the protocol tables for each criterion.
Request for data submission to subscriber – This is text that a Verifier may use, or adapt and use, in
communicating with the subscriber to request the submission of verification data within 30 days.
Examples of potential evidence for conformance – generally more than one item of evidence may be
provided such that conformance is adequately demonstrated – This provides examples of the data or
documents that the subscriber may provide to the Verifier in response to the request. The subscriber
has flexibility in what documents they provide. The key principle is that whatever is provided
adequately demonstrate conformance. The examples provided are not comprehensive, and though all
of them need not be provided, in general the verification system will require multiple documents to
adequately demonstrate conformance.
Questions to assess conformance – These are the key questions that the provided data must address.
The Verifier will need to be able to answer these questions based on the data provided when providing
their recommendation to the PVC.
Evaluation guidance – This section simply includes comments based on verification investigations that
may be valuable for the Verifier, or subscriber.
4. Annexes 1 & 2 – Plastics and Packaging Materials Forms
Attached to this Verification Protocols document are two forms that are provided for the convenience of
subscribers in submitting conformance evidence for certain criteria relative to plastics and packaging –
the EPEAT Plastic Materials Form and the EPEAT Packaging Materials Form. Each form is linked to the
protocols of specific criteria, as noted in the protocols and on the forms. Note the following about those
two forms:

The subscriber need only fill out a form if and when being verified for a criterion that references
the form.

The subscriber need only fill out either form once per verification round, even if being verified
on more than one criterion referenced on the form.

The subscriber need only fill out the specific columns where the criterion being verified is listed.
5. Annex 3 – Summary Checklist for U.S. EPA’s Plug-In to eCycling
Guidelines for Materials Management
Annex 3 of the protocols is the checklist for the U.S. EPA Plug-in Guidelines which are referenced in
criteria 4.6.1.1 and 4.6.1.2. As a result conformance to these criteria can be demonstrated by the use of
any recycler standard or certification system or audit system that includes all the elements of the U.S.
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EPA Plug-Guidelines and is equivalent with the items in the checklist in Annex 3. The PVC will determine
whether the use of any proposed standard assures that the requirements of Plug-in would be met.
Criteria 4.6.1.1 and 4.6.1.2 reference specifically conformance with the U.S. EPA Plug-In to eCycling
Guidelines. However, with the advent of the two new recycler standards – R2 and eStewards – the U.S.
EPA has discontinued use of Plug-in, and references to R2 have replaced it on the EPA web site.
Increasingly recyclers are moving to one of the new standards. There has been considerable stakeholder
debate (continuing up to the adoption of these new protocols) in the IEEE 1680.2 and 1680.3 standard
development processes regarding what should be the new recycler standard for take-back of imaging
equipment and televisions. This evolving situation makes it unviable for the 1680.1 standard to either
require exclusively the use of Plug-in or to go at this time to something new through an amendment.
Therefore these protocols take a middle approach in which either the use of Plug-in or the use of an
equivalent standard are accepted. The Plug-in Guidelines are posted on www.epeat.net and are fully
functional to be used for conformance with these criteria.
An equivalent standard may also be allowed. Of course each standard is unique in its own wording and
therefore the determination of “equivalence” involves both an assessment and a decision process.
“Equivalence” is defined as being “functionally equivalent”. The evaluation of functional equivalence
includes a clause-by-clause analysis to determine whether the standard accomplishes the same type and
degree of environmental and health and safety protections, even if it does so in somewhat different
ways. The PVC then has the authority to determine if any standard is equivalent to Plug-in for use for
these criteria.
R2 and eStewards are considered equivalent to Plug-in and are therefore accepted in demonstrating
conformance to 4.6.1.1 and 4.6.1.2. Other recycler standards can be offered for similar determination
and the Annex 3 checklist provides for a critical first step in performing the required analysis.
6. Verification Data
Flexibility – Subscribers may provide evidence in support of conformance that differs from those items
identified in these protocols. Verifiers shall use these protocols to evaluate if the evidence provided by a
subscriber meets the following criteria:
1. It is consistent with the Verification Requirements in the Standard.
2. It is as effective in demonstrating conformance as the evidence requested in the protocols.
As it is stated in the Verification Protocol for each criterion in the section where examples of potential
evidence are provided: “generally more than one item of evidence may be provided such that
conformance is adequately demonstrated”. The key test is that the evidence provided must be fully
adequate to demonstrate conformance.
Data Demonstrating Conformance at Time of Registration – Consistent with Clarification 3-2, the
verification data provided by the subscriber must demonstrate that the product was in conformance at
the time of declaration, through dated materials or other means.
7. Definitions and Explanations
Following are some terms, documents, or concepts that are used repeatedly in these protocols.
7.1.
Conformity Assurance System (CAS)
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The CAS is intended to be an implemented process that consistently ensures conformity to the design
requirement being met, where the key consideration for conformity is control of the supply chain of
components, parts, plastics, packaging and/or services, and can also include recyclers, test laboratories
and even internal designers. A CAS should be based on the plan-do-check-act process (PDCA).
Again, as applies for all elements of these protocols, a CAS is optional. It is not the only adequate
system that a subscriber may use for assuring conformity across the supply chain. It is offered here to
provide a good indication of the types of components and the level of detail that a Verifier would expect
to see in a subscriber’s system to assure conformance.
The scope of information collected through a CAS will be based upon the type of relationship the
subscriber has with the supplier. Generally, the supplier provides components, parts, plastics, packaging
and/or services. A CAS can address two different relationships between the subscriber (OEM) and the
supplier:
1. Where the subscriber has a contractual relationship with the supplier, and
2. Where the subscriber simply purchases components or services “off the shelf” from suppliers.
An example for RoHS compliance: In a contractual relationship, the subscriber should be collecting
documentation of RoHS compliance directly from the supplier; in a purchasing relationship without a
contract, the subscriber should have a process for purchasing only those parts meeting RoHS and
collecting component self-declarations from where they are purchasing parts.
Regardless of the type of relationship with the supplier, there are common parts to any CAS that, at a
minimum, must be adequately demonstrated as part of the Verification Requirements.
Common Elements of a CAS
Plan:

Description of the requirement

How the requirement is being communicated and updated to the supplier

What is required to be provided, collected or otherwise used to show the requirement is being
met

Collection of documents or other records that show conformity as defined by the subscribers
processes (examples of records include, but are not limited to, supplier letters, declarations of
conformity, analytical test data, tech sheets, certificates, purchasing records, online declarations
etc.)
Do:
Check:

Demonstration of how the program provides assurance of conformance that includes, or is
equivalent to the following:
a. Inspection: Description and details of an audit, monitoring and/or sampling program of
some percentage of parts in support of the declaration of conformity for the specified
requirements, and which defines its frequency and identifies corrective action procedures
for findings. That process can be conducted by the subscriber and/or an identified 3rd party
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such as an ODM, distributor or supplier, and typically will include the gathering of analytical
test data that supports the requirements being checked.
b. Samples of test results from auditing/monitoring/sampling program
Act:

Description of corrective action plans regarding meeting the requirement and (if applicable)
evidence of actions that have been taken in the past
The CAS may consist of different kinds of elements, in some cases, for the two different relationships
between the subscriber and the supplier.
Different Elements of a CAS for Contractual versus Purchasing Relationships
Plan:

Contractual: Identification of the supplier and of the contractual relationship

Contractual: An ongoing contractual commitment to meeting conformance requirements
including actions to take when changes occur in production

Purchasing: Identification of the method of selection of conforming items that assures that the
requirements are met

Contractual: Ongoing collection of documents of conformity. Documents are typically provided
directly from the supplier to the OEM and specific to the part or family of parts being purchased
as part of the contract with the OEM.

Contractual: Parts are typically sourced over a period of time and the supplier is obliged to
provide updates to documents of conformity if the part changes during the span of the contract.

Purchasing: Point in time collection of documents of conformity. Documents are typically
posted on supplier’s websites, or obtained by request, and may be specific to the part or family
of parts being purchased and/or may be a more generic statement of conformance for “all
products.”

Purchasing: Parts are typically bought in bulk at one time therefore a “point in time” document
collection is done. If parts are bought again at a later date, documentation supporting that
purchasing effort would need to be conducted.
Do:
Check:

Methods of checking parts for conformance are similar for contractual as well as purchasing
relationships.
Act:

Contractual: Evidence of corrective action procedure. This includes, if a part is found to not
meet requirements, the stopping of use of the part and switching to an alternate part or vendor
that is providing parts that are shown to meet requirements. This may also include procedures
for bringing the part/supplier into conformity through engineering changes or other similarly
effective means.
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
Purchasing: Evidence of corrective action procedure. Evidence that an alternative supplier is
used to provide parts that are in with the requirement.
CAS tests for conformance are identified for each of the applicable criteria, and may vary slightly
depending on the criterion. When a CAS is identified in these Protocols, the subscriber is required to
provide the above details specific to the particular criterion being verified.
7.2.
Empirical and analytical data
Several criteria in section 4.1 require the subscriber to provide “evidence … that is based on either
empirical data demonstrating compliance or analytical test data demonstrating compliance.“ The
following Interpretation by the IEEE and Guidance provided by the Product Verification Committee
explain these requirements.
Interpretation 1-6
It was the intent of the Standard developers that either empirical or analytical data would be
adequate to demonstrate conformance for several criteria in clause 4.1 which call for the
elimination of intentionally added environmentally sensitive materials. Those criteria all state in the
verification requirements: “either empirical data demonstrating compliance or analytical test data
demonstrating compliance”, or equivalent language. Empirical data may include supplier assurance
of conformance, and must include component sampling or data collection that is evaluated within a
quality control system that demonstrates conformance. It shall not be required that analytical test
data also be provided to demonstrate a substance level below the threshold. Of course, such
analytical test data of itself would also demonstrate conformance.
Guidelines for Subscriber Verification Data from the PVC
Several Verification Requirements include the provisions of evidence based on “empirical data
demonstrating compliance” and/or “analytical data demonstrating compliance”. Demonstration of
a quality control program by the manufacturer or its suppliers that assures conformance with the
requirement of the criterion will satisfy this Verification Requirement.
The demonstration of a quality control program should include the following, or an equivalent:

Description of program, including frequency of monitoring

Demonstration of how the program provides assurance of conformance for all manufacturing
operations and/or all suppliers as appropriate to the criterion

A spot testing program of incoming components or raw materials with at least one sample of
test results measured to a threshold sufficient to verify conformance to the applicable criterion
7.3.
Supplier Letter
This is the document – called for in Verification Requirements for certain criteria in the Standard – that
is to be provided to the subscriber by a supplier that indicates that supplier’s conformance to a specified
requirement. It may also be considered a “Supplier Declaration of Conformity.” It is acceptable for the
subscriber either to draft a letter detailing the requirements a supplier must meet and have the supplier
sign it or to use a declaration that has been created by accredited standards bodies. A supplier letter is
also frequently provided as part of the requirements of a CAS. Supplier letters (or equivalent) must
meet the following minimum criteria to be adequate evidence of conformance for IEEE 1680.1:
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1. Clearly state the criteria that the supplier letter applies to and indicate conformance to said
criteria
2. Signed by a responsible corporate authority (such as a quality control manager or engineer) that
provides assurance of conformance to the subscriber; emails with electronic signatures are
acceptable
3. Dated within a reasonable time based on the longevity of the part or product.
Supplier letter tests for conformance are included with each of the applicable criteria, and may vary
slightly depending on the criterion.
7.4.
Product definition and scope of verification
As defined in the standard a “product” includes an electronic product and all the peripherals that are
integral to its operation. For example, the following would be the product:
 The desktop computer together with the keyboard, the mouse, and the power cord
 The notebook computer together with the power cord and external power supply
 The display together with the power cord, cables and cable adapters
As such, verification documentation and calculations will also need to include those peripherals that are
integral to the operation of the product. Examples of verification documentation that would need to
include these items would be, but are not limited to, the plastic parts form (list of parts, recycled
content calculation etc), the packaging form (list of peripheral packaging materials, recycled content
declarations, etc), CAS/auditing systems, supplier letters, BOM etc.
7.5.
Geographic Verification
During the process of declaring a product on the Registry, a manufacturer may designate for certain
criteria one or more specific geographic countries or regions for which the product declaration is
applicable. In order to be conformant in a designated country or region, each unit of the product that is
sold in that country or region must satisfy all of the applicable requirements provided in the IEEE 1680.1
standard. The criteria consist of three types:
1) Criteria that are independent of country or region and therefore are applicable wherever the
product is sold
This is the default type and no specific text is included in the criterion to identify it as such
2) Criteria that are applicable only in the country or region for which the product is declared
The following text is included in the criterion: “This criterion is applicable only in those
regions or countries for which the product is declared on the MSE’s Registry.”
The following criteria are of this type:
4.6.1.1 (Required) Provision of product take-back service
4.6.2.1 (Required) Provision of rechargeable battery take-back service
3) Criteria for which the subscriber’s declaration may vary by country or region. In the case of
certain optional criteria a subscriber shall declare conformance (or not declare conformance) by
country or region for each of these criteria. In the case of certain required criteria the
subscriber may declare different values in a text field (e.g. how the criterion is met).
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The following text (with possible slight variations) is included in the criterion. For the case of
optional criteria: “This criterion is dependent on the region or country and may be declared
by a manufacturer differently in different regions or countries”. For the case of required
criteria: “A manufacturer may provide different information for different regions or
countries regarding the recycled content.”
The following criteria are of this type:
4.5.2.1 (Optional) Renewable energy accessory available
4.5.2.2 (Optional) Renewable energy accessory standard
4.6.1.2 (Optional) Auditing of recycling vendors
4.8.4.1 (Optional) Provision of take-back program for packaging
4.8.5.1 (Optional) Documentation of reusable packaging
4.6.2.1 (Required) Provision of rechargeable battery take-back service
4.8.3.1 (Required) Declaration of recycled content in packaging
For criteria that vary by country or region, during the request for verification data, the manufacturer will
be told for which country or region the claimed criteria is being verified, and the manufacturer will need
to supply data to show conformance for the identified country or region.
For criteria that are independent of country or region, verification documentation will need to show
how that criterion is met wherever the product is sold, not just in the current list of designated IEEE
1680 countries and regions.
8. Overarching Clarifications and Interpretations
The protocols include a listing of the PVC Clarifications and IEEE Interpretations that have been adopted
relative to each criterion. These are also listed on www.epeat.net and are critical information both for
subscribers and Verifiers.
Though most Clarifications and Interpretations apply to specific criteria – and are provided in the
protocol tables for those criteria – some are global and apply generally to all criteria. The global
Clarifications and Interpretations are listed below. Note that Interpretation 1-6 was discussed in section
7.2 of this Introduction and is not repeated here.
8.1.
Interpretation 1-2: Use of the exceptions field for product configurations and
other purposes
Clause 1.3 stipulates that every configuration of a product declared to the Standard must fully
conform with the Standard, with the exception of special configurations that are reported as nonconformant to the Product Registration Entity. These are clearly intended to be “specific
configurations” amongst “every configuration” that is available, and the non-conforming
configurations are intended to be specifically identified. The Product Registration Entity is expected
to provide for purchasers some method to easily and unambiguously identify non-conforming
configurations that are reported by subscribers. This may be a text description of non-conformant
options, a list of configuration-specific identifiers (such as manufacturer part number or UPC), a
reference or link to an available search function or product configurator tool, or other method.
8.2.
Clarification 2-1: Regarding use of the exceptions field
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The exceptions field on www.epeat.net implements the IEEE 1680 provision for subscribers to
report to EPEAT “special configurations that do not conform to the Standard”. Though the term
“configurations” is not defined in the Standard, the examples of “configuration”, and the obvious
intent of the Standard, are that “special configurations” are specific hardware or software variations
of the product that can be specified by a customer at time of order. The use of the exceptions field
for other than customer specifiable hardware or software configurations of the product is not in
conformance with the Standard. Such non-conformant uses include conditions on the sale of the
product such as geographic limitations on the availability of certain required services or features,
conditions on the quantity of products included in a sale in order to receive services required by a
criterion, or conditions on the type of customer.
Moreover, it is expected that the exceptions field will “report such special configurations that do not
conform to the standard”. In other words, it will not be considered conformant for the exceptions
field to simply state that un-specified configurations may, or may not, conform to the standard, nor
that purchasers must specify that they wish to purchase EPEAT-conformant configurations. It is the
intention that all units of the product defined by the product name meet the criteria as declared
with few and narrowly and clearly defined exceptions, if any. The intention is that if a customer
orders the product name listed in the registry, they will receive a product that meets the criteria as
declared unless they have specified some special hardware or software configuration that is clearly
described as an exception. That is, conformance with the declared criteria is the default – it need
not be specified.
The PVC issues this Verification Clarification because the EPEAT Registry’s exceptions field has
apparently been used by some subscribers in ways not intended in the 1680 Standard.
8.3.
Interpretation 1-3: Geographic extent or limits of product declarations
The 1680 Standard, specifically the language in section 1.4, does not limit nor define the geographic
areas within which a product declaration, or an optional criterion declaration, is valid. Therefore,
there is nothing that restricts a Product Registration Entity from designating geographic areas, or
allowing manufacturers to designate geographic areas, within which a product declaration or an
optional criterion declaration is valid.
8.4.
Clarification 1-1: Wording of criterion prevails over wording of the criterion title
The wording of the criterion prevails over the title of the criterion wherever there is a conflict or
inconsistency.
9. Attachments
The following attachments are reference in this document and are attached as Appendices to these
protocols:
1. EPEAT Plastics Materials Form
2. EPEAT Packaging Materials Form
3. U.S. EPA Plug-in Guidelines Checklist
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