4.8.1 Toxics in packaging EPEAT CONFORMITY ASSESSMENT PROTOCOLS 4.8.1.1 Required Reduction/elimination of intentionally added toxics in packaging Verification Guidance IEEE Interpretations and PVC Verification Clarifications Clarification 6-2 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. References and Details This criterion is drawn from the Model Toxics in Packaging legislation (referred to as Act below) developed by CONEG, which is available online. Incidental presence, as defined in 3.1, is specified in CONEG s Model Toxics in Packaging Legislation. Recycled content exemption is specified in CONEG s Model Toxics in Packaging Legislation as the following: packages and packaging components that would not exceed the maximum contaminant levels set forth in subsection c of Section 4 of this Act but for the addition of recycled materials; and provided that the exemption for this subparagraph shall expire 1 January 2010. This exemption shall not apply to any cadmium, lead, mercury, or hexavalent chromium that has been recovered and/or separated from other materials for use as a metal or metallic compound. 4.8-1
Verification Requirements 1. Declaration from manufacturer (See 4.0 Verification Requirement Declaration from manufacturer) 2. Supplier Letter 4.8.1.1 Verification Requirement Supplier letter that is demonstrated 3. Questions to assess The Supplier Letter shall provide the following information: 1. EPEAT Packaging Material Form 2. Supplier letters and/or declarations of conformity documenting for each supplied packaging piece that heavy metals are not intentionally added to any packaging or packaging component and that supplier has a method for the assurance of that claim, e.g. a Conformity Assurance System (CAS See Introduction Definitions and Explanations) a demonstration of the method of assuring that incidental presence levels are not exceeded If the recycled content exemption is used, the percentage of recycled content in the packaging that may contain heavy metals and a calculation to show that if the heavy metals exceed the incidental presence levels that the excess could reasonably have come from the recycled content. Supplier records/letters or declarations of conformity with a s restricted materials program Details of a restricted materials program and auditing program that indicates packaging is under the threshold limits Analytical data/test reports Percentage of recycled content showing that the amounts of heavy metals in the packaging are reasonable given the percentage of recycled content Is the requirement being communicated at least equal to the EPEAT Criterion? Is the process or procedure described adequate to provide communication of changes and updates? Is the supplier providing information demonstrating commitment to meeting 4.8-2
the criteria? Does the program provide checks at a reasonable frequency to assure compliance to the criteria? Does the program described provide assurance of to the criteria? Does the supplier letters clearly state the requirement, indicate, and is appropriately signed and dated? If applicable, has documentation been provided for incidental presence and/or recycled content as contributes to meeting the criteria? 4. Evaluation guidance If the heavy metal content is part of a s overall restricted materials program, details of the program, including evidence that the level of restriction is at least a strict as the EPEAT requirement, is needed. Third party analytical test data for the specific packaging pieces could be provided in lieu of the supplier letter or declaration as long as details of an audit program are also provided that indicate how this data is systematically verified over the life of the product. 4.8-3
4.8.2 Recyclable packaging materials 4.8.2.1 Required Separable packing materials Verification Guidance IEEE Interpretations and PVC Verification Clarifications References and Details Verification Requirements Interpretation 1-13 The wording of criterion 4.8.2.1 requires that the packaging materials can be segregated without the use of tools. The wording segregated without the use of tools is the operative requirement. In spite of the apparent requirement in the Verification Requirements that materials not be glued, if glue is used but the materials can be segregated into like materials without the use of tools, then the product (that is, its packaging) is in with the criterion. None available. 1. Declaration from manufacturer (See 4.0 Verification Requirement Declaration from manufacturer) 2. Documentation stating that dissimilar materials are separable and are not glued together 4.8.2.1 Verification Requirement Documentation stating that dissimilar materials are separable and are not glued together 1. Completed EPEAT Packaging Materials Form 2. Documentation that: All non-reusable packaging components over 25g is separable without the use of tools and not glued together, and All packaging is able to be segregated into like materials 4.8-4
that is demonstrated 3. Questions to assess Drawings or specifications of the packaging materials showing only single materials or the use of a means of joining that is separable by hand, such as post-it type glues Photographs of packaging material showing the same Has sufficient documentation been provided that shows that all non-reusable packaging materials are separable without tools and all packaging materials are able to be segregated into like materials? 4. Evaluation guidance Verify with that no stickers, tape or glue are used if they create a combination of unlike materials that pose a problem for recycling for packaging larger than 25g. For example, paper stickers on plastics that are not easily removed create a combination of unlike materials that are a barrier for recycling. Or if stickers, tape or glue are used, verify how they are adhered to a different material such that they are separable without tools. For segregated into like materials, it is not sufficient to be able to separate into materials that could be recycled together; they must be like materials. 4.8-5
4.8.2.2 Optional Packaging 90% recyclable and plastics labeled Verification Guidance IEEE Interpretations and PVC Verification Clarifications Clarification 6-2 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. Clarification 13 The standard specifically states that the labeling requirements do not apply to plastic protective or stretch wraps. The PVC has determined the following as it applies to wraps and bags: A wrap is formed from a sheet or roll of plastic film that is wrapped or fitted to a product or accessory for the purpose of containing or protecting the part or accessory, but not permanently altered through further manufacturing other than cutting. All other use of plastic packaging to enclose or encase a product that does not meet the above description of a wrap is not considered to be a wrap and is thus subject to the labeling requirements of this optional criterion. In determining the applicability of the labeling requirements to such packaging, the presence of a visible mechanism for closure (e.g. a zip lock) or a heat seal will be evidence that such packaging is NOT a protective wrap, and thus labeling requirements shall apply. This latest clarification is consistent with Clarification 7.1, which among other things established that a part is defined by its form at the time of sale, rather than its raw material constituents. 4.8-6
References and Details Verification Requirements For the definition of recyclable as applied to packaging refer to Section 260.7(d) of the FTC Guides for the Use of Environmental Marketing Claims [B12]. For some specific packaging materials, the presence or lack of an infrastructure at a regional level will need to be considered by the manufacturer wishing to demonstrate compliance with this criterion. Since this Standard will be used without regional variations, if a product is declared to this criterion, the manufacturer will need to provide a recycling vendor option in certain areas if the recycling infrastructure is not generally available in a region where the product will be used. [B12] U.S. FTC, Guides for the Use of Environmental Marketing Claims. 1. Declaration from manufacturer (See 4.0 Verification Requirement Declaration from manufacturer) 2. Demonstration that material is normally recyclable or, if not, that there exists a market/use 3. Record of visual inspections 4.8.2.2 Verification Requirement Demonstration that material is normally recyclable or, if not, that there exists a market/use that is demonstrated 3. Questions to assess 1. EPEAT Packaging Materials Form 2. Information on how each material is normally recyclable, the market for the material as is, or details of its reuse 3. Calculation showing that the total amount of packaging is 90% or more recyclable by weight Letters from recyclers or manufacturers stating recyclability status Plastic association (SPI, DIN, ISO) guidelines for recyclability for certain material types Details of reuse/take-back programs for existing markets for materials Spreadsheets showing calculations for total recycled content percentage Has evidence been provided that the materials used are normally recyclable or if not, that a market exists for use and total amount recyclable is above 90%? 4.8-7
4. Evaluation guidance Information on the structure of the material, especially foams, is important. An engineered or block EPS is not able to be recycled because it is not commonly accepted in most recycling programs, whereas EPS packaging peanuts can be because they can commonly be delivered to shipping stores for reuse. Verify with that packaging material is not coated with another material, or if it is that the coating doesn t inhibit recycling. Mixed plastics and foams are inherently difficult to recycle and additional information showing recyclability will need to be provided. This documentation should come from the recycler rather than the manufacturer of that material. 4.8.2.2 Verification Requirement Record of visual inspections 1. Description of the packaging inspection Conformity Assurance System (CAS See Introduction Definitions and Explanations) used by or s suppliers for all relevant manufacturing operations and/or suppliers. Documentation which includes visual inspections to insure that plastic packaging over 25g or with a surface area greater than 50cm 2 is correctly marked by material type. Protective plastic, stretch wrap, labels and plastic pieces that are shaped such that labeling is not possible are exempted. Samples of records of visual inspections that is demonstrated 2. Questions to assess Engineering drawings specifying the correct markings and the associated audit program that verifies the packaging part meets the drawing Incoming Quality Control (IQC) reports. Article inspection information that includes packaging audit for marks Actual photographs of the packaging material with the marks visible on the photograph Factory audit programs with audit checklists that include packaging marking Is the requirement being communicated at least equal to the EPEAT criterion? Is the process or procedure described adequate to provide communication of changes and updates? 4.8-8
Is the supplier providing information demonstrating commitment to meeting the criteria? Does the program provide checks at a reasonable frequency to assure compliance to the criteria? Does the program described provide assurance of to the criteria? 4. Evaluation guidance Subscribers need to provide details of a systematic and/or auditing system that checks for the correct identification on the packaging material for packaging over 25g or with a surface area greater than 50cm 2. Protective plastic, stretch wrap, labels and plastic pieces that are shaped such that labeling is no possible are exempted. Records of at least one completed inspection of this type should be provided to show compliance (does not have to be for packaging material used for the product being verified). Confirmation that these types of inspections are routinely carried out. 4.8-9
4.8.3 Recycled content 4.8.3.1 Required Declaration of recycled content Verification Guidance This criterion will be verified for of the declaration of recycled content in geographic regions or countries. Subscriber will be notified during the verification process to provide verification information that supports in a specific region/country that is specified by the Verifier. IEEE Interpretations and PVC Verification Clarifications References and Details Verification Requirements Interpretation 1-4: In use of the term postconsumer, as defined in section 3.1 as having served its intended use and has been discarded for disposal or recovery, and in consideration of uses of the term postconsumer elsewhere, which generally require that the material has completed its life as a consumer item, equipment that has been manufactured into a product, stocked for sale or delivery to a consumer, but then liquidated before delivery to the consumer, shall not be considered as postconsumer. Such equipment therefore does not meet the definition of postconsumer. Manufacturer declares whether or not packaging contains any recycled content and must list each packaging material with the approximate range of recycled content that is in that material. For example: Corrugated Cardboard - Between 15% and 40% EPS Foam -Between 2% and 5% Molded Pulp - Between 60% and 100% postconsumer 1. Declaration from manufacturer (See 4.0 Verification Requirement Declaration from manufacturer) 2. Supplier Letter 3. Declaration of recycled content 4.8.3.1 Verification Requirement Supplier Letter The Supplier Letter shall provide the following information: 1. EPEAT Packaging Material Form 2. Supplier letters and/or declarations of conformity documenting for each supplied packaging piece the level of recycled content for each 4.8-10
specific packaging that is 3. Questions to assess Letters of from the packaging suppliers of each of the stated packaging materials Does the supplier letters clearly state the recycled content level being claimed, indicate, and is appropriately signed and dated? 4. Evaluation guidance If a single packaging material piece is supplied by multiple suppliers, there must be a supplier letter from each supplier. As this criterion specifically states Supplier Letters as the necessary verification, engineering drawings, contracts, specs and anything that is not a signed letter/email from the supplier will not be accepted however these items may be used to show that a CAS is in place. 4.8.3.1 Verification Requirement Declaration of Recycled Content that is demonstrated 3. Questions to assess EPEAT Packaging Materials Form A complete listing of packaging materials, weights, suppliers and recycled content ranges in the EPEAT Packaging Materials Form Does the list of materials and ranges match (or exceed) what is declared on EPEAT.net? 4.8-11
4. Evaluation guidance None 4.8-12
4.8.3.2 Optional Minimum postconsumer content guidelines Verification Guidance IEEE Interpretations and PVC Verification Clarifications References and Details Interpretation 1-4: In use of the term postconsumer, as defined in section 3.1 as having served its intended use and has been discarded for disposal or recovery, and in consideration of uses of the term postconsumer elsewhere, which generally require that the material has completed its life as a consumer item, equipment that has been manufactured into a product, stocked for sale or delivery to a consumer, but then liquidated before delivery to the consumer, shall not be considered as postconsumer. Such equipment therefore does not meet the definition of postconsumer. The CPG is available online. Table 1 U.S. EPA s recommended recovered fiber content levels for paperboard and packaging products Item Postconsumer fiber (%) Corrugated Containers <300 psi 25 to 50 Corrugated Containers 300 psi 25 to 30 Solid Fiber Boxes 40 Folding Cartons 40 to 80 Industrial Paperboard (e.g., tubes, cores, drums, and cans) Miscellaneous (e.g., pad backs, covered binders, book covers, mailing tubes, protective packaging) 45 to 100 75 to 100 Padded Mailers 5 to 15 Carrierboard 10 to 15 Brown Papers (wrapping paper and bags) 5 to 20 Verification Requirements 1. Declaration from manufacturer (See 4.0 Verification Requirement Declaration from manufacturer) 2. Supplier Letter 3. Designation of CPG guideline that is met 4.8-13
4.8.3.2 Verification Requirement Supplier Letter that is demonstrated 3. Questions to assess The shall provide the following information: 1. EPEAT Packaging Material Form 2. Supplier letters for all materials covered under the CPG guideline verifying that the designation of the CPG guideline is met for that material over the course of a year using a weighted average Letters of from paper packaging suppliers of boxes, cartons, paper board etc. Does the supplier letters clearly state the recycled content is from postconsumer material and the annual weighted average level being claimed, indicate, and is appropriately signed and dated? 4. Evaluation guidance Supplier letters must indicate that the recycled content is from post-consumer materials. If a packaging piece that a is claiming CPG is from multiple suppliers then a letter is required from ALL suppliers indicating the level of post-consumer recycled content on an annual basis that meets or exceeds the CPG guidelines. As this criterion specifically states Supplier Letters as the necessary verification, engineering drawings, contracts, specs and anything that is not a signed letter/email from the supplier will not be accepted however these items may be used to show that a CAS is in place. NOTE: If a packaging material is used that is not listed in the CPG Guidelines, the post consumer content requirement does not apply to that material. 4.8.3.2 Verification Requirement 4.8-14
Designation of CPG Guideline that is met that is demonstrated 3. Questions to assess 1. EPEAT Packaging Materials Form The completed EPEAT Packaging Materials Form listing all paper based packaging materials, weights, suppliers, recycled content ranges and the CPG category. Does the post-consumer recycled content range for each packaging material being claimed meets or exceeds the range listed in the CPG guideline? Does the list of materials and ranges matches what was declared on www.epeat.net? 4. Evaluation guidance The provided EPEAT Packaging Materials Form needs to match the list in the EPEAT.net database of packaging material for that product, and the post consumer recycled content range for the CPG category must meet or exceed the range stated for CPG. In the EPEAT Materials Packaging Form the must indicate which CPG category the packaging falls into. 4.8-15
4.8.4 Take-back option 4.8.4.1 Optional Provision of take-back program for packaging Verification Guidance This criterion will be verified for in geographic regions or countries. Subscriber will be notified during the verification process to provide verification information that supports in a specific region/country that is specified by the Verifier. IEEE Interpretations and PVC Verification Clarifications References and Details Verification Requirements At the time of this document, no interpretations or clarifications have been issued for this criterion. None available. 1. Declaration from manufacturer (See 4.0 Verification Requirement Declaration from manufacturer) 2. Documentation of take-back service 3. Documentation of notification of user of take-back service 4.8.4.1 Verification Requirement Documentation of take-back service 1. EPEAT Packaging Materials Form AND Provide the following information for the following countries (GEC specifies countries for verification): 2. Description of provision or participation in free packaging take-back programs for institutional purchasers. 3. Indication of a business relationship with the collectors contracted to provide take back. Show that the collector takes the packaging to a recycler that does recycle packaging materials. Provide details as to how the collected packaging is being recycled/reused by the recycler. 4.8-16
that is demonstrated 3. Questions to assess Recycling options for institutional purchasers: Recycling program participation/provision records Contracts with recyclers Website information Company literature Photos of recycling activities Has sufficient evidence been provided to show that a business relationship with the packaging take-back collector(s) for institutions exists and that they are working the packaging recyclers? 4. Evaluation guidance Obtain a description how each different packaging material is being recycled or reused by the or by the recycler. Confirm that the program is free for the end user, including transportation/shipping of the packaging material. A drop off program is not the same as a take back program. 4.8.4.1 Verification Requirement Documentation of notification of user of take-back service that is demonstrated 3. Questions to assess 1. Documentation of how the users (institutional purchasers) are being informed of this packaging take-back program. Product literature (user/instructions manual, inserts etc) Website information Contracts or service agreements Samples of communications with users Paper included in box indicating how to recycle packaging Notification of user that packaging take back is required in the country and how that service is provided Has adequate evidence that users are notified of take-back packaging program been provided? 4.8-17
4. Evaluation guidance Subscriber provides the text being given to the institutional purchasers about the packaging take-back program. Text should indicate that the program is free, whether it is voluntary or mandatory and where the user needs to go for additional details on how to take advantage of this take-back service (or the text may include that information directly). The will need to indicate how this information is provided to the end user. If the method for packaging take-back is on the web, the must indicate how the user is to know to look on the website for this information. There must be some written instruction to the user on how to take advantage of the program. Website only isn t sufficient, there must be direction in a user manual or the like that the user needs to see the website for details of the program. 4.8-18
4.8.5 Reuse Option 4.8.5.1 Optional Documentation of reusable packaging Verification Guidance This criterion will be verified for in geographic regions or countries. Subscriber will be notified during the verification process to provide verification information that supports in a specific region/country that is specified by the Verifier. IEEE Interpretations and PVC Verification Clarifications References and Details Verification Requirements Interpretation 1-14 Processes that remove non-conformant packaging from a product at an intermediate point between manufacture and delivery to purchaser, then deliver the product to the purchaser with conformant packaging or without packaging (i.e. using carts or other conveyances), shall not be in with this criterion unless the packaging removed at the intermediate point is reused consistent with the criterion. None available. 1. Declaration from manufacturer (See 4.0 Verification Requirement Declaration from manufacturer) 2. Documentation of packaging reuse system 4.8.5.1 Verification Requirement Documentation of packaging reuse system 1. EPEAT Packaging Materials Form AND Provide the following information for the following countries (GEC specifies countries for verification): 2. Description of how packaging is reused for same or similar product 3. Description of the method for a customer to utilize the reusable packaging 4. Description of how the packaging will be transported to a facility that will reuse it for the same or similar product 5. Explanation of how the reusable process is price-competitive 4.8-19
6. Description of how the packaging is designed to be reused for at least five times that is demonstrated 3. Questions to assess Company literature Website information Drawings of the reusable packaging Photos showing the reusable packaging reuse process or activities Price sheets Notification of the program as provided to the customer Has sufficient evidence been provided that shows the existence of a reusable packaging program that meets this EPEAT criterion? 4. Evaluation guidance The list of packaging weighing over 25g for the product system being claimed should be mapped to drawings or photos of the packaging that is being reused for ease of verification. As per Interpretation 1-14, if there is a secondary process that the product/packaging system goes through (i.e. a merge center/distribution center un-boxing and re-boxing operation), the process to do this operation must be provided as part of the verification. Bulk shipment reusable packaging is acceptable however both the incoming individual product packaging must be reused and the outgoing bulk packaging must be reused per the interpretation. Pricing for the reuse program must be provided. If this program is not free, the manufacturer is required to provide validation of the price being competitive for the same/similar type of service being provided. The following packaging elements are exempt from reusable criteria: a) Any individual packaging item < 25 grams b) Palletization material (stretch wrap, banding, and corner boards and edge protectors) c) Labels d) Security Seals, Straps, and Bands e) Protective bags, tapes, and films applied to the product or accessories f) Twist ties and small plastic fixtures 25g g) Accessory and media packaging that is intended to stay with the customer (e.g. CD cases/envelopes, "getting started" kits containing 4.8-20
accessories, spare batteries, user guides) h) Desiccant packs 4.8-21