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Product Category Rules for preparing an environmental product declaration (EPD) for PRINTERS AND MULTI-FUNCTION PRINTING UNITS To print black or color text and images onto paper or paper-like media. The product group includes Copiers, digital duplicators, fax machines, multifunction devices (MFDs), and printers that use high-temperature technologies such as Electrophotography (EP) and Solid Ink (SI), and others that provide comparable functionality VERSION December 12th, 2012 VALID THROUGH December 12th, 2017

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Printers and Multi-Function Printing Units Product Category Rule Number E101.1 According to ISO 14025

Versions overview Version Description History

1 Version by UL Environment with input from a coalition was accepted by the review panel.

December 12, 2012

Editor’s Note This proposed PCR is based on revisions made to existing PCRs from other countries that address laser printers and other imaging devices. In an effort to harmonize this PCR with existing PCRs, the Laser Printers (EDP 2004-26[0]) PCR from Korea and the Electro-photographic and Inkjet Printer PCR from JEMAI were used as references. These PCRs were expanded to reflect global manufacturing data availability, conformity with existing imaging equipment environmental standards, and conformity with reference standards (PAS 2050, ISO 14065). Revisions/discussion points to make this PCR applicable to the U.S. include: units, functional unit, impact assessment methods, testing methods and requirements, use phase options, references, and standards. This PCR is intended to serve the global B2B and B2C markets, reflecting the global manufacturing and distribution networks for these products. It is expected that region-specific versions of these PCR will not differ significantly.

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Program operator: UL Environment

The PCR has been prepared by UL Environment with input from a coalition of the following interested parties:

PE International Hewlett-PackardCompany

Xerox Corporation Lexmark International, Inc.

Samsung Massachusetts Institute of Technology (MIT)

Rochester Institute of Technology (RIT)

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The PCR review, was conducted by:

Chairperson Lise Laurin EarthShift, LLC 31 Leach Road Kittery, Maine 03904 [email protected]

Panel Member Marcos Esterman, Ph.D. Associate Professor Rochester Institute of Technology Industrial and Systems Engineering Kate Gleason College of Engineering 81 Lomb Memorial Drive Rochester, NY 14623-5603 [email protected]

Panel Member Tim Strecker Environmental Program Manager Hewlett-Packard Company 3000 Hanover Street Palo Alto, CA 94304-1185 [email protected]

Table of Contents

Introduction to the Product Category Rule........................................................................................................................ 8 1.1 Purpose of this PCR ........................................................................................................................... 8 1.2 Scope of Validity this PCR .................................................................................................................. 8 1.3 Content of the PCR ............................................................................................................................ 8 1.4 Harmonization .................................................................................................................................... 8

2.0 Life Cycle Assessment Criteria ................................................................................................................................... 9 2.1 System Boundaries ............................................................................................................................ 9 2.2 Declared/Functional Unit .................................................................................................................... 9 2.3 Product Lifetime ................................................................................................................................ 10 2.4 Energy Consumption ........................................................................................................................ 10 2.5 Paper and Media Consumption (Optional) ....................................................................................... 11 2.6 Consumable Use .............................................................................................................................. 11 2.7 End-of-life stage ............................................................................................................................... 12 2.8 Maintenance stage ........................................................................................................................... 12 2.9 Transportation .................................................................................................................................. 13 2.10 Background data ............................................................................................................................ 13 2.11 Cut-off Criteria ................................................................................................................................ 13 2.12 Allocation Criteria ........................................................................................................................... 14

3.0 Rules for the Creation of the Environmental Product Declaration ............................................................................ 16 3.1 Summary of the EPD ........................................................................................................................ 16 3.2 Product Description .......................................................................................................................... 17

3.3 Life Cycle Assessment Results ................................................................................................................................ 18 3.3.1 Life Cycle Inventory ....................................................................................................................... 18 3.3.2 Life Cycle Impact Assessment ...................................................................................................... 19 3.4 Standards and Laws ......................................................................................................................... 22 3.5 Additional Environmental Information ............................................................................................... 22 3.6 Additional Life Cycle Scenarios ........................................................................................................ 23 3.7 References ....................................................................................................................................... 23 3.8 Verification ........................................................................................................................................ 23

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Terms and Definitions

Automatic Duplexing: The capability of a copier, fax machine, MFD, or printer to produce images on both sides of an output sheet, without manual manipulation of output as an intermediate step. A product is considered to have automatic duplexing capability only if all accessories needed to produce duplex output are included with the product upon shipment. [Energy Star, 2006]

Consumable: A consumable is a replacement product integral to the functioning of the imaging equipment product with the intent, when depleted or worn, to be replaced or replenished by the user during the normal usage and life span of the imaging equipment product. Note: Consumables may include: toner, toner containers, toner bottles, toner cartridges, waste toner cartridges, ink cartridges, ink heads, ink sticks, ribbon ink, thermal paper, copy paper, imaging units, transfer belts, transfer roller, fusers, drum maintenance units, and other associated items. Items not intended to be replaced or replenished by the user would be not be considered consumable supplies, but rather "spare parts". [IEEE 1680.2:June 2011]

Consumer: individual member of the general public purchasing or using goods, property or services for private purposes. [ISO 14025:2006]

Continuous Form: Products that do not use a cut-sheet media format, and that are designed for applications such as printing of bar codes, labels, receipts, banners, and engineering drawings. Continuous form products can be of small, standard, or large format. [Energy Star, 2012]

Copier: A product whose sole function is to produce paper duplicates from paper originals. This definition is intended to cover products that are marketed as copiers, and upgradeable digital copiers (UDCs). [Energy Star, 2006]

Electro-photographic (EP): A marking technology characterized by the illumination of a photoconductor in a pattern representing the desired output image via a light source, development of the image with particles of toner using the latent image on the photoconductor to define the presence or absence of toner at a given location, transfer of the toner to the final print media, and fusing to cause the output to become durable. For purposes of this specification, Color EP products simultaneously offer three or more unique toner colors, while Monochrome EP products simultaneously offer one or two unique toner colors. This definition includes Laser, Light Emitting Diode (LED), and Liquid Crystal Display (LCD) illumination technologies. [Energy Star, 2012]

Environmental impact: any change to the environment, whether adverse or beneficial, wholly or partially resulting from an organization's environmental aspects. [ISO 14001:2004]

Functional unit: quantified performance of a product system for use as a reference unit. [ISO 14040:2006]

Facsimile (Fax) Machine: A product whose primary functions are (1) to scan paper originals for electronic transmission to remote units, and (2) to receive electronic transmissions for conversion to paper output. A fax machine may also be capable of producing paper duplicates. Electronic transmission is primarily over a public telephone system, but may also be via a computer network or the Internet. This definition is intended to cover products that are marketed as fax machines. [Energy Star, 2012]

Ink Jet (IJ): A marking technology characterized by the deposition of colorant in small drops directly to the print media in a matrix manner. For purposes of this specification, Color IJ products offer two or more unique colorants at one time, while Monochrome IJ products offer one colorant at a time. This definition includes Piezo-electric (PE) IJ, IJ Sublimation, and Thermal IJ. This definition does not include High Performance IJ. [Energy Star, 2012]

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Large Format: Products designed for A2 media and larger, including those designed to accommodate continuous-form media greater than or equal to 406 mm wide. Large-format products may also be capable of printing on standard-size or small-format media. [Energy Star, 2012]

Life cycle: consecutive and interlinked stages of a product system, from raw material acquisition or generation from: natural resources to final disposal. [ISO 14040:2006]

Multifunction Device (MFD): A product that performs two or more of the core functions of a Printer, Scanner, Copier, or Fax Machine. An MFD may have a physically integrated form factor, or it may consist of a combination of functionally integrated components. MFD copy functionality is considered to be distinct from single-sheet convenience copying functionality sometimes offered by fax machines. This definition includes products marketed as MFDs, and “multi-function products” (MFPs). [Energy Star, 2012]

Packaging: All products made of any materials of any nature to be used for the containment, protection, handling, delivery and presentation of goods, from raw materials to processed goods, from the producer to the user or the consumer. 'Non-returnable' items used for the same purposes shall also be considered to constitute packaging. 'Packaging' consists only of a) sales packaging or primary packaging, i.e. packaging conceived so as to constitute a sales unit to the final user or consumer at the point of purchase; b) grouped packaging or secondary packaging, i.e. packaging conceived so as to constitute at the point of purchase a grouping of a certain number of sales units whether the latter is sold as such to the final user or consumer or whether it serves only as a means to replenish the shelves at the point of sale; it can be removed from the product without affecting its characteristics. [IEEE 1680.2:June 2011]

Printer: A commercially-available imaging product that serves as a hard copy output device, and is capable of receiving information from single-user or networked computers, or other input devices (e.g., digital cameras). The unit must be capable of being powered from a wall outlet or from a data or network connection. This definition is intended to cover products that are marketed as printers, including printers that can be upgraded into MFDs in the field. [IEEE 1680.2:June 2011]

Product category rules (PCR): set of specific rules, requirements and guidelines for developing Type III environmental declarations for one or more product categories. [ISO 14025:2006]

Product category: group of products that can fulfill equivalent functions. [ISO 14025:2006]

Product Family: A group of product models that are (1) made by the same manufacturer, (2) subject to the same ENERGY STAR qualification criteria, and (3) of a common basic design. Product models within a family differ from each other according to one or more characteristics or features that either (1) have no impact on product performance with regard to ENERGY STAR qualification criteria, or (2) are specified herein as acceptable variations within a product family. For Imaging Equipment, acceptable variations within a product family include: a) Color, b) Housing, c) Input or output paper-handling accessories, d) Electronic components not associated with the marking engine of the Imaging Equipment product. [Energy Star, 2012]

Scanner: A product whose primary function is to convert paper originals into electronic images that can be stored, edited, converted, or transmitted, primarily in a personal computing environment. This definition is intended to cover products that are marketed as scanners. [Energy Star, 2012]

Small Format: Products designed for media sizes smaller than those defined as Standard (e.g., A6, 4”x6”, microfilm), including those designed to accommodate continuous-form media less than 210 mm wide. [Energy Star, 2012]

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Solid Ink (SI): A marking technology characterized by ink that is solid at room temperature and liquid when heated to the jetting temperature. This definition includes both direct transfer and offset transfer via an intermediate drum or belt. [Energy Star, 2012]

Standard Format: Products designed for standard-sized media (e.g., Letter, Legal, Ledger, A3, A4, B4), including those designed to accommodate continuous-form media between 210 mm and 406 mm wide. Standard-size products may also be capable of printing on small-format media. [Energy Star, 2012]

Third party: person or body that is recognized as being independent of the parties involved, as concerns the issues in question. “Parties involved” are usually supplier (“first party”) and purchaser (“second party”) interests. [ISO 14024:1999]

Type III environmental declaration: environmental declaration providing quantified environmental data using predetermined parameters and, where relevant, additional environmental information. The predetermined parameters are based on the ISO 14040 series of standards, which is made up of ISO 14040 and ISO 14044. The additional environmental information may be quantitative or qualitative. [ISO 14025:2006]

Typical Electricity Consumption (TEC): For the purposes of this specification, a method of comparing product energy performance via an evaluation of typical electricity consumption (measured in kilowatt-hours) during normal operation over a specified period of time, as specified in Section 8 of the ENERGY STAR Imaging Equipment test method. [Energy Star, 2012]

Verification: confirmation, through the provision of objective evidence, that specified requirements have been fulfilled. [ISO 9000:2005]

Verifier: person or body that carries out verification. [ISO 9000:2005]

Symbols and Abbreviations

AF&PA American Forest & Paper Association EP Electro-photographic EPD Environmental Product Declaration EPEAT Electronic Product Environmental Assessment Tool FEFCO European Federation of Corrugated Board Manufacturers IJ Inkjet ISO International Standards Organization JEMAI Japan Environmental Management Association For Industry LCA Life Cycle Assessment LCI Life Cycle Inventory LCIA Life Cycle Inventory Assessment MFD Multi-Function Device PCR Product Category Rule SI Solid Ink TEC Typical Electricity Consumption UL Underwriters Laboratories Inc. USB Universal Serial Bus WiFi Wireless Fidelity

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References

Bauprodukte [Guideline for Setting Up the Product Category Requirements of AUB Declarations (Type III) for Construction Products], Institut Bauen und Umwelt e.V. www.bau-umwelt.com

BBS 1997, Bundesverband Baustoffe, Steine und Erden (Hrsg.): Leitfaden zur Erstellung vonSachbilanzen in Betrieben der Steine-Erden-Industrie [German Building Materials Association (ed.): Handbook on the creation of life cycle inventory analyses in companies of the non-metallic mineral processing industry], Frankfurt, 1997.

Ecoinvent, 2007. The Swiss Centre for Life Cycle Inventories, ecoinvent V2.01, www.ecoinvent.ch.

ELCD, 2012. European Commission, ELCD II, http:// http://lct.jrc.ec.europa.eu/assessment/data

ENERGY STAR, 2011. Program Requirements Product Specification for Imaging Equipment Test Method for Determining Imaging Equipment Energy Use, http://energystar.gov/products/specs/sites/products/files /ENERGYSTAR_Imaging_Equipment_Version_2.0_Draft_Test_Method.pdf.

ENERGY STAR, 2012. Product Specification for Imaging Equipment Eligibility Criteria Draft 2 Version 2.0

Frischknecht, R., 2010. LCI modeling approaches applied on recycling of materials in view of environmental sustainability, risk perception and eco-efficiency. International Journal of Life Cycle Assessment (2010) 15:666–671.

GaBi 2006, GaBi 4: Software and Database for Life Cycle Engineering, IKP [Institute for Polymer Testing and Polymer Science] University of Stuttgart and PE Europe GmbH, Leinfelden-Echterdingen, 1992 – 2006.

IBU, 2006, Leitfaden Umwelt-Produktdeklarationen (Ausgabe 20.01.2006) für die Formulierung der produktgruppen-spezifischen Anforderungen der Umwelt-Produktdeklarationen (Typ III) für

ISO 14025: 2007-10, Environmental Labelling and Declarations - Type III - Environmental Declarations - Principles and Procedures (ISO 14025:2006); German and English version

ISO 14040:2006-10, Environmental management - Life cycle assessment - Principles and framework (ISO 14040:2006); German and English version EN ISO 14040:2006

ISO 14044:2006-10, Environmental management - Life cycle assessment - Requirements and guidelines (ISO 14044:2006); German and English version EN ISO 14044:2006

ISO 14065:2007. Greenhouse gases -- Requirements for greenhouse gas validation and verification bodies for use in accreditation or other forms of recognition

ISO/TR,14049:2000. Environmental management -- Life cycle assessment -- Examples of application of ISO 14041 to goal and scope definition and inventory analysis

PAS 2050:2011 Specification for the assessment of the life cycle greenhouse gas emissions of goods and services

REACH, 2006. Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), establishing a European Chemicals Agency, amending Directive 1999/45/EC and repealing Council Regulation (EEC) No 793/93 and Commission Regulation (EC) No 1488/94 as well as Council Directive 76/769/EEC and Commission Directives 91/155/EEC, 93/67/EEC, 93/105/EC and 2000/21/EC

ReCiPe Mid/Endpoint method, version 1.05 July 2010

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VDI 2243: 2002-07, Recycling-oriented product development

Introduction to the Product Category Rule

1.1 Purpose of this PCR

These Product Category Rules aim to create a common platform for communication of the life cycle impact assessment results for laser printers and multi-function devices, for business-to-business or business-to-consumer communication. This information is intended to complement existing environmental impact metrics for imaging equipment (i.e. EPEAT, Energy Star, Blue Angel). For example, this product category rule facilitates the creation of Environmental Product Declarations that will satisfy optional criteria within the IEEE 1680.2 for imaging equipment to be released in (INSERT DATE).

1.2 Scope of Validity this PCR

This product category rule is applicable to output devices: copiers, digital duplicators, fax machines, multifunction devices (MFDs), and printers that use high-temperature technologies such as Electrophotography (EP) and Solid Ink (SI), and those that provide comparable functionality. It is not intended for low-temperature technologies such as conventional Ink Jet (IJ) or Impact, nor for Large-format or Small-format products. Not included are EP printers using continuous form paper or printers using paper sizes larger than A3 or printers with speeds greater than 75 ppm.

For purposes of this PCR, the speed of the product that was used to determine the job size for the TEC in section 2.4 will be used (the manufacturer’s reported maximum claimed simplex speed in images per minute (ipm) for making monochrome images on standard-sized paper (8.5” x 11” or A4), rounded to the nearest integer)

This PCR is valid for 5 years and is subject to annual review by UL Environment.

1.3 Content of the PCR

This PCR determines the product group specific rules for: − the creation of an Environmental Product Declaration (EPD) − the calculation of a Life Cycle Assessment (LCA) and the creation of a project report on the LCA

Further requirements are given in UL Requirements for Product Category Rules and Environmental Product Declaration

1.4 Harmonization

In an effort to harmonize this PCR with existing PCRs, the Laser Printers (EDP 2004-26[0]) PCR from Korea and the Electro-photographic and Inkjet Printer PCR from JEMAI were used as references. These PCRs were expanded to reflect global manufacturing data availability, conformity with existing imaging equipment environmental standards, and conformity with reference standards (PAS 2050, ISO 14065).

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This PCR is intended to serve the global B2B and B2C markets, reflecting the global manufacturing and distribution networks for these products. It is expected that region-specific versions of these PCR will not differ significantly.

2.0 Life Cycle Assessment Criteria

A life cycle assessment, complying with ISO 14040/14044, describing the declared product and based on plausible, transparent and credible data, must be presented in support of the EPD. Model assumptions with a relevant influence on the declared results must be clearly stated in the EPD. Comparative descriptions with other products are inadmissible.

For the respective product, an LCA complying with ISO 14040 and based on plausible, transparent and credible data must be submitted. All model assumptions with a decisive influence on the result should be specified. The report structure complies with the structure of this document, following ISO 14040.

The background report must address all building material-specific stages of the life cycle. The stages which are taken into account in the assessment must be thoroughly presented in relation to the considered processes. That is to say, the production (cradle to gate) must always be thoroughly presented. If use and/or recycling/disposal are part of the analysis, these stages must also be addressed. If use and/or disposal are not considered, this fact has to be justified. In this case, the processes must be documented in detail. As the use stage generally depends on the construction and environment, it is not required within this PCR. If desired, a hypothetical use stage scenario may be included. Assumptions and key parameters must be clearly stated. The following sections must be carefully considered for any form of comparative decision-making.

2.1 System Boundaries

The description of the system boundaries shall follow the definitions of the key life cycle phases as referenced below: 1. Raw Material Extraction and processing 2. Product Manufacturing 3. Product Distribution 4. Product Use

a. Generation and delivery of consumed electricity b. Toner/cartridge manufacturing, transportation, and disposal c. Paper manufacturing, transportation, and disposal

5. Product Maintenance 6. Product End-of-life

Waste flows and their resulting treatment and transportation shall be handled in each life cycle phase. Credits resulting from waste flows (i.e. recycling or incineration), shall be outside the system boundary.

All packaging (except for packaging that is used repeatedly in general application) and accessories for performing functions include printer drivers provided on floppy disks, CD-ROMs, or other media, and manuals provided in printed form, CD-ROMs, or other forms are also included.

2.2 Declared/Functional Unit

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The functional unit is defined as a 1000 page simplex job.

Print Pattern − If printer product has color printing capabilities use pages 1 – 4 as specified in Annex A of INCITS/ISO/IEC

24712:2007[2008]. Note that this will result in 250 submissions of this 4-page job in order to fulfil the 1000-page job specified above.

− If a printer product does not have color printing capabilities (monochrome), use the print pattern as specified in Annex C of ISO/IEC 19752[2004]. Note that this will result in 1000 submissions of this 1-page job in order to fulfil the 1000-page job specified above.

It is important to take note that these print patterns were selected because they are deemed to be representative of pages that are printed by consumers and they have been vetted through an ISO review process. It should be further noted that these pages are not intended to be used when making energy consumption measurements during the use phase. The TEC method and test pattern (as described below) have been deemed the most appropriate for that purpose.

This method is in harmonization with the Japanese PCR for EP/IJ printers which also specifies a 5% coverage color test page and is more representative of the ‘typical’ marking material consumption.

2.3 Product Lifetime

The lifetime of the product is assumed to be 5 years for all products defined in Section 1.2 Scope of Validity of the PCR.

2.4 Energy Consumption

Calculation criteria conform to the conditions for the test procedure for the Typical Electricity Consumption (TEC) method for the most current version of the ENERGY STAR Imaging Equipment (IE) specification . The procedure is to be used to obtain and evaluate the TEC of Standard-size IE products such as copiers, digital duplicators, fax machines, multifunction devices (MFDs), and printers that use high-temperature technologies such as Electro-photography (EP) and Solid Ink (SI), and those that provide comparable functionality. It is not intended for low-temperature technologies such as conventional Ink Jet (IJ) or Impact, nor for Large-format or Small-format products. The key result of this test procedure is a value for typical weekly electricity consumption.

The Typical Electricity Consumption (TEC) method for the most current version of the ENERGY STAR Imaging Equipment (IE) specification is available at: http://www.energystar.gov

To calculate the energy consumption that should be allocated to the print job, use the following procedure:

�� 1000 ∗ ��

5 ∗ �� Where, �� !"��#��$��%�� as defined in the job table in the TEC test procedure. See the job table which presents the number of images per day as a function of the reported printer speed.

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2.5 Paper and Media Consumption (Optional)

If paper and media consumption is chosen to be added to the assessment, AF&PA life cycle inventory shall be used in the modelling for paper consumption based. The FEFCO dataset may be used as an alternative dataset. Calculation criteria for Paper and Media Consumption conform to the conditions for the test procedure for the Typical Electricity Consumption (TEC) method for the most current version of the ENERGY STAR Imaging Equipment (IE) specification1. If the product declared does not have an automatic mechanical duplexing feature, assume no duplexing and account for the printing of 1000 pages as specified by the functional unit. If the product has an automatic mechanical duplexing feature, assume a 50% rate of duplexing and scale the simplex results by 75% (750 pages).2

2.6 Consumable Use

The consumption of marking material (e.g. toner cartridges) will be reflected in the model for the product’s use phase. Manufacturing, transportation, and disposal of the consumables will be reflected in this product life cycle. The following guidelines are intended to create the most accurate use phase model possible.

Method for measuring Consumable yield

Consumable use will be modelled on the calculation of average consumable use per 1000 impressions. This will be based on the number of impressions per consumable, as measured in accordance with INCITS/ISO/IEC 19798:2007[2008] for color printing equipment and ISO/IEC 19752[2004] for monochrome printing equipment. (impressions/cartridge). Both of these test standards prescribe printing of a test proptocol with approximately 5% average coverage per color per page. For black consumable cartridges, with Lifeblack being the yield as tested in ISO/IEC 19752[2004], the number of cartridges that will be consumed per the defined functional unit will be:

&'()* � 1000/,� �'()*

For color consumable cartridges, with Lifecolor being the yield as tested in INCITS/ISO/IEC 19798:2007[2008], the number of cartridges that will be consumed per the defined functional unit will be:

&*-(-. �1000

,� �*-(-.

1 The PCR committee understands that this method tends to overestimate energy consumption but has chosen to use the TEC method because it ensures consistent assumptions across studies. The PCR committee believes that using TEC still delivers LCA results that correctly prioritize the opportunities for improvement in the printer lifecycle. The energy consumption model should be considered for improvement in future revisions of the PCR if doing so substantially benefits the users of the EPD. 2 This method gives credit to for the reduction of paper consumption and allows for ease in comparison between simplex and duplex results.

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High-Capacity Cartridges

If high-capacity cartridges are available with the printer model, the cartridge life will be based on the yield standards defined above. In order to determine the number of cartridges of each type, the number of cartridges N (defined above) will need to weighted in proportion with its market share (i.e. its usage rate). The following example assumes two cartridge types to illustrate the procedure 3

��/012)3)*405 � 1000,� �/01

6��70)81).1 � 1000,� �/01

�1 9 6��:4;�2)3)*405� And

��:4;�2)3)*405 � 1000,� �:4;�2)3)*405

6��:4;�2)3)*405

2.7 End-of-life stage

This phase is classified into recycling, incineration and landfill, depending on the materials and disposal method of the product. A disposal scenario shall be developed and applied. Recycling shall be considered using the cut-off method (Frischknecht 2010):

− If the wastes resulted from the manufacturing or end-of-life phase are recycled into other product systems, i.e. an open loop recycling system, it shall be excluded from the system boundaries.

− When the materials recycled through the open loop recycling system are used as inputs into any process, the recycling process shall be included within the system boundaries, but no burden taken for virgin material.

− The incineration process shall be included within the system boundaries. When recovered heat is used for the system, it shall be deducted from the total environmental impact. Electricity and heat production from incineration used outside the system it shall be outside the system boundary.

The end-of-life stage shall include the following Information modules:

− Transportation of the product, e.g. to recycling site and transportation of waste e.g. to disposal, − Collection of waste fractions from the deconstruction and waste processing of material flows intended for

reuse, recycling and energy recovery. Waste processing shall be modelled and the elementary flows shall be included in the inventory.

− Final disposal.

In principle, waste processing is part of the product system. In the case of materials leaving the system as secondary materials or fuels, such processes as collection and transport before the end-of–waste stage are, as a rule, part of the waste processing of the system under study. However further processing may also be necessary in order to replace primary material or fuel input in another product system. Such processes are considered to be beyond the system boundary and considered in an optional analysis for recycling/reuse credits.

2.8 Maintenance stage

3 This method allows for the credit for having high-capacity consumables based on documented use assumptions.

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Expected replacement of consumable parts (i.e. parts not designed to last the full life of the products, such as: rollers, fusers, intermediate transfer bands) must be considered, including any consumables or transportation of service personnel associated with servicing the product.

2.9 Transportation

The transportation of the product from the manufacturing sites to the regions of use must be considered. Representative models for average logistics providers (air, sea, truck, and rail freight) may be used, based on a production-weighted average distance between production and consumption sites.

2.10 Background data

In general, consistent background data shall be used to guarantee the comparability of results. − Generic data shall be checked for plausibility by the verifier of the EPD. This verification process is simplified

when pre-verified generic data is used. − Datasets originating from databases (e.g. ELCD, GaBi, ecoinvent) must be indicated in the project report,

including the year for which the dataset is representative. The representativeness of the datasets that are used has to be documented.

− The background data that is used and its sources shall be indicated in the EPD on a general basis.

2.11 Cut-off Criteria

The cut-off criteria which are used shall be declared. When cut-off criteria are applied clear reasons shall be stated to support the criteria. The sum of all excluded flows shall be judged to be less than 5% of mass, energy, or environmental impacts in any criteria.

− All inputs and outputs to a (unit) process shall be included in the calculation, for which data are available. Data gaps may be filled by conservative assumptions with average or generic data. Any assumptions for such choices shall be documented.

− In case of insufficient input data or data gaps for a unit process, the cut-off criteria shall be 2 % of renewable and non-renewable primary energy usage and 2% of the total mass input of that unit process. The total sum of neglected input flows shall be a maximum of 5 % of energy usage and mass. Conservative assumptions in combination with plausibility considerations and expert judgment can be used to demonstrate compliance with these criteria.

− The total sum of neglected impacts per life cycle stage shall be a maximum of 5 % of energy usage and mass. This applies particularly to material and energy flows known to have the potential to cause significant emissions into air and water or soil during the life cycle of the product; it also applies to processes that are known to be resource intensive. Conservative assumptions in combination with plausibility considerations and expert judgement can be used to demonstrate compliance with these criteria.

− The project report shall contain: − Description of the application of cut-off criteria and assumptions; − List of excluded processes.

Example: Standard ISO 14040 cutoff criteria have been assumed. All flows above the following thresholds are included in the model: <2% of product mass, provided environmental relevance is not a concern

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<2% of total energy production, provided environmental relevance is not a concern <2% of total impact for any impact category

2.12 Allocation Criteria

Allocations (assignment of burdens to several products) relevant for the calculation must be indicated, at least: − allocation for the input of recycled material and secondary raw material, − allocation of the utilities, auxiliary materials and supplies used to the individual products of a plant,

2.12.1 Attribution of plant data to the declared products

If other products than the ones being declared are manufactured in a plant facility where primary data is being collected, then the attribution of the plant data (production energy, raw material, additives and auxiliary substances, wastes, etc.) has to be described.

Energies, auxiliary substances, and fuels used in the plant that cannot be unambiguously allocated to a specific product in terms of processes or a formulation shall be allocated by economic values. The attribution of the plant-wide data to the declared products must be documented.

2.12.2 Allocation of co-products

Allocation shall be avoided as far as possible by dividing the unit process to be allocated into different sub-processes that can be allocated to the co-products and by collecting the input and output data related to these sub-processes.

− If a process can be sub-divided but respective data are not available, the inputs and outputs of the system under study should be partitioned between its different products or functions in a way which reflects the underlying physical relationships between them; i.e. they shall reflect the way in which the inputs and outputs are changed by quantitative changes in the products or functions delivered by the system;

− In the case of joint co-production, where the processes cannot be subdivided, allocation shall respect the main purpose of the processes studied, allocating all relevant products and functions appropriately. The purpose of a plant and therefore of the related processes is in general declared in its permit and should be considered. Processes with very low contribution to the overall revenue may be neglected. Joint co-product allocation shall be allocated as follows:

• Allocation shall be based on physical properties (e.g. mass, volume) when the difference in economic value from the co-products is low.

• In all other cases allocation shall be based on economic values. • Material flows carrying specific inherent properties, e.g. energy content, elementary composition (e.g.

biogenic carbon content), shall always be allocated reflecting the physical flows, irrespective of the allocation chosen for the process.

• Contributions to the overall economic value of the order of 1% or less may be regarded as very low. A difference in value of more than 25 % is regarded as high.

2.12.3 Allocation on multi-input processes

Various products are processed simultaneously within one process, e.g., in a solid waste incineration plant, a biomass power plant, or a landfill. The allocation method should be documented. Where appropriate, the environmental impacts linked to the inputs are distributed depending on how they influence the subsequent production process.

2.12.4 Allocation at open and closed-loop recycling on the input side

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When recycled material is used in manufacturing, the current plant’s specific material use and fate must be assessed. The system boundary for recycled material is set according to the rules described under system boundary (Section 2.1). As a conservative assumption and for practical purposes, the system boundary can be assumed at collection of the recycling material.

Internally re-used production waste is modeled as closed-loop recycling. In parallel, loads and benefits from reuse, recycling, and energy recovery can be presented in the Additional Life Cycle Scenarios section.

2.12.5 Selection of the waste management method

The selection of the waste management method, e.g., for the packaging or as end of life scenario, has to be based on currently used and representative technologies. For products where the manufacturer provides a takeback system, this take back system and any remanufacturing/reuse should be modelled; otherwise a representative mix of a landfilling and recycling based on best estimates of average product treatment should be used.

2.12.6 Allocation at end-of-life recycling

The system boundary at the end of an end-of-life stage of the product system under study is set where outputs, e.g., materials, products or building elements, have entered the waste stream or where the end-of-waste stage is reached. Waste processing for material flows undergoing recovery or recycling processes during the end-of-life stages of the product system (e.g., during the end-of-life stage of a building or construction work) are included up to the system boundary of the system under study as defined above.

Reuse, recycling or recovery processes leading to potential loads and benefits of secondary material or secondary fuels beyond the system boundary of the system under study can be included in a separate analysis in Additional Life Cycle Scenario section. This acknowledges the “design for reuse and recycling” concept for products through modelling of the recycling benefits and loads of secondary materials or fuels leaving the system boundary.

Where a material flow crosses the system boundary at the end-of-life stage and has a positive economic value or has reached the end-of-waste stage and if it substitutes another product or energy, the benefits or avoided loads can be calculated and declared in the additional product reuse/recycling stage based on:

− average existing technology − current practice − net impacts

In this optional second analysis, the avoided burden approach should be taken (ISO 14049). This approach provides credit for recycled product at end of life, which means that the use of recycled product essentially carries full burden of virgin production.

Net impacts in this stage are the impacts connected to the recycling or recovery processes from the system boundary as defined above up to the point where the secondary material or energy substitutes primary production, minus the impacts resulting from the production of the product or generation of energy from primary sources.

The system boundary at the end of an end-of-life stage of the product system under study is set where outputs, e.g., materials, products or building elements, have gained an economic value or where the end-of-waste stage is reached, whichever occurs first.

Explanatory example: To produce 1000 kg of a metal product, 80% primary material and 30% secondary material are used today. The production therefore comprises 800 kg metal from primary production and 200 kg metal from secondary production. Based on the assumption that for the secondary production 10% more scrap will be required (220 kg), 780 kg scrap is still available as recycling potential for the second life cycle, after

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the scrap needs of the initial product have been provided. From the 780 kg sent to recycling, a 10% loss would yield 702 kg secondary material. Thus, the recycling potential is calculated from the „avoided production“ of 702 kg of primary material.

2.12.7 Allocation of energy recovery

Energies gained from energy recovery of packaging (and production waste) or as an end-of-life scenario, are outside the system boundary. However, they can be offset by an equivalent process in the optional avoided burden analysis. Electricity and heat have to be assessed as the current average electricity grid and heat generated from natural gas, with reference to the base year.

In this optional assessment, credits gained from energy recovery of packaging and other production waste (for external recycling) shall be allocated to the material credit stage. Energies gained from energy recovery as an end-of-life scenario can be offset by an equivalence process. For a main market in Europe, electricity has to be assessed as the current average “electricity Europe” and heat as “thermal energy from natural gas”, with reference to the base year

3.0 Rules for the Creation of the Environmental Product Declaration

The creation of the EPD shall contain the following sections in the order shown below. Each section shall be titled as seen below with exception to the numbering.

3.1 Summary of the EPD

The summary must contain the following elements:

− Product name (including e.g. product code) − Declaration holder (the manufacturer completing the EPD) − Full name, logo, and website of Program Operator − Declaration number as provided by the program operator − Date of issuance − End date of validity period (5 years after issuance) − Reference PCR (name, version) − Signature of the LCA and EPD verifiers − Outline of the content in the EPD − Optional: product image

The header/footer must contain the following elements:

− Product name (product number) − Environmental Product Declaration according to EN ISO 14025 − Declaration number − Date of issuance

While conformance to this PCR minimizes that variations and deviations, there are still components that might influence the comparability of EPDs (ISO 14025, Section 6.7.2). Caution should be used when interpreting results and applying them for comparative decisions making. The declarer must, where possible, use quantitative metrics to capture the uncertainty. At a minimum, the declarer will provide qualitative guidance in relevant sections to guide users in interpreting the information contained within the EPD relative to comparability and use for decision-making.

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The declarer must state in the EPD that differences between environmental declarations are not guaranteed for comparative purposes.

3.2 Product Description

This section of the EPD covers description of the product in a manner that enables the user to clearly identify the product. This section shall contain the following criteria:

3.2.1 Scope of Validity/Applicability of the EPD

Indicate the manufacturer, product, and geographic regions for which this EPD is representative.

3.2.2 Functional Unit

The functional unit has been defined as simplex printing of 1000 pages in either monochrome or color. This must be clearly stated within this section of the EPD.

3.2.3 Product Characterization

The declared product(s) must be described. This description includes the condition in which the product is provided to the consumer, any installation services, and secondary equipment such as accessories, packaging, power supply, cabling, manuals, default settings, etc, must be indicated.

The product lifetime and intended use/application (i.e. home, office, or both) shall be clearly stated. However, the product lifetime used in the life cycle assessment shall be 5 years. If the product’s life is longer (or shorter) than 5 years, then scale the impact assessment results up/down accordingly.

Example: A multi-function color printer includes printing, copying, and scanning functionalities in one system. The laser jet engine fuses toner of different colors onto the medium for printing and copying functionalities. Network connectivity allows for printing, scanning, and faxing to/from remote locations. The intended use/application of this unit is to scan, copy, and print images or text in color onto paper or paper-like media for 5 years.

3.2.5 Technical Properties

The following technical properties of the declared products in delivery condition must be indicated: − Color options (monochrome or color) − Color print resolution (if applicable) − Color print speed (if applicable) − Color scan speed (if applicable) − Connectivity/data inputs (i.e. WiFi, Bluetooth, Ethernet, USB) − Display/interface − Duplexing capability − Duplexing setting default or optional − Energy efficiency or environmental labels (EnergyStar, EPEAT) − Energy setting (default or optional) − Functions (print, copy, scan, fax) − Marking Material Capacity Options − Maximum document print size − Maximum document scan size

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− Maximum scan resolution − Media Breadth Supported − Modules (i.e. automatic document feeder, scanner, copier, two-sided printing) − Monochrome print resolution − Monochrome print speed − Monochrome scan speed − Print Modes − Printer memory

A hyperlink to a description of the product may be provided.

3.2.6 Declaration of Basic Materials

The product content shall be described in the declaration. Information protected under US law as confidential is not required to be disclosed; in such cases, a notation that the information is confidential shall be made along with a description of the function of the compound. The product(s) must declare as hazardous materials using a safety data sheet. The declaration of material content of the product shall list as a minimum the “substances of very high concern”.4

3.2.7 Product Supply Chain

The number and nation of manufacturing sites for the final product assembly shall be indicated. Information protected under US law as confidential is not required to be disclosed; in such cases, a notation that the information is confidential shall be made.

3.3 Life Cycle Assessment Results

The following sections report the life cycle assessment results.

3.3.1 Life Cycle Inventory

The results of the life cycle inventory assessment shall be reported. The data must be interpreted, e.g. to what extent the LCA information depends on certain product characteristics (e.g. duplexing rate, toner cartridge yield, etc) or production characteristics.

3.3.1.1 Use of Material and Resources during Manufacturing5

− Use of non-renewable material resources − Use of renewable material resources − Use of non-renewable primary energy in megajoules, for example:

o Fossil fuel o Natural gas o Coal o Nuclear

4 The “substances of very high concern” are listed in annex XIV of REACH directive. Indications such as “... is free from...” shall not be used in this section of the declaration. 5 Implementation of LCIA methods Data v2.2 (2010) for guidance on classification

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o Peat − Use of renewable primary energy in megajoules, for example:

o Hydropower o Wind power o Solar power o Biomass

− Use of water

3.3.1.2 Energy Consumption during Utilization

Report energy consumption during utilization for the following scenarios as a table based on section 2.4 Energy Consumption (i.e. at-wall power consumption).6

Energy Consumption During Utilization Lifetime Per 1000 Pages Declared Unit

3.3.2 Life Cycle Impact Assessment

The life cycle impact assessment shall include:

− The LCIA procedures, calculations and results of the study for the LCIA indicators defined in part 1; mean value and data range should be stated if generic data are declared from several sources or for a range of similar products;

− the relationship of the LCIA results to the LCI results; − reference to all characterization models, characterization factors and methods used; − a statement that the LCIA results are relative expressions and do not predict impacts on category endpoints,

the exceeding of thresholds, safety margins or risks.

The following impact categories shall be assessed per declared unit AND per printer unit in the units indicated below:

Climate Change/Global Warming Potential kg CO2-equiv to air Ozone Depletion Potential kg CFC 11 equiv Acidification Potential kg SO2 equiv to air Eutrophication Depletion Potential kg P equiv to freshwater Fossil Fuel Depletion Potential kg oil equiv Mineral Resource Depletion Potential kg Fe equiv

This assessment does not include human health and eco-toxicity due to their uncertainty. A statement to this affect must be included in the declaration beside the results. See Section 3.5 for additional information on human health and eco-toxicity.

The H characterization factors of ReCiPe 2008 shall be used.

6 TEC Energy Star Power Consumption calculations

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The Impact Assessment results shall be presented in the following tabular format:

Life Cycle Impact Assessment Results

ReCiPe 2008 Results for Each Scenario

For the Declared Unit (per 1000 pages)

For the Printer Unit (per lifetime)

Impact Category Units Paper Included

Paper Excluded

Paper Included

Paper Excluded

Global Warming Potential kg CO2-equiv to air Ozone Depletion Potential kg CFC 11 equiv Acidification Potential kg SO2 equiv to air

Eutrophication Depletion Potential kg P equiv to freshwater

Fossil Fuel Depletion Potential kg oil equiv Mineral Resource Depletion Potential kg Fe equiv

Water Depletion liters

The results shall be interpreted in reference to the most important contributions in the different environmental impact categories.

Other characterization factors may be reported in the environmental product declaration in the “Additional Life Cycle Assessment Scenarios” section of the EPD. The methodology shall be clearly documented in this section using the tabular format indicated below. For example, TRACI impact factors may be reported as shown in the table below.

Life Cycle Impact Assessment Results

TRACI 2.0 Results for Each Scenario

For the Declared Unit For the Printer Unit

Impact Category Units Paper Included

Paper Excluded

Paper Included

Paper Excluded

Global Warming Potential kg CO2-equiv to air Ozone Depletion Potential kg CFC 11 equiv Acidification Potential kg SO2 equiv to air

Eutrophication Depletion Potential kg P equiv to freshwater

Fossil Fuel Depletion Potential kg oil equiv Mineral Resource Depletion Potential kg Fe equiv

Replace the Impact assessment methodology used, Impact categories, and Units with applicable information for the methodology chosen.

3.3.3 Interpretation of Life Cycle Impact Assessment Results

The interpretation shall contain: − the results; − assumptions and limitations associated with the interpretation of results as declared in the EPD, both

methodology and data related; − data quality assessment;

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− full transparency in terms of value-choices, rationales and expert judgments. − To check the declaration, a dominance analysis7 should be carried out. Primary energy and impact categories

are to be divided up according to the relevant contributing modules.

The influence of assumptions due to data gaps or other uncertainties should be assessed with a sensitivity analysis, as far as the assumptions are relevant to the result.

3.3.4 Assumptions and Estimations

Assumptions and estimations that are significant for the interpretation of the results of the LCA shall be documented:

Example: An average production scenario representing a mix of manufacturing sites has been used. Or average distribution distances and modes based on the product’s forecast sales are used.

Product BOM information has been used as the basis of modeling the production of components and subassemblies. For EPDs that declare optional scenarios (i.e. use in different countries/regions), the additional technical information related to the scenarios underlying these modules are a mandatory part of the information of the declared information modules.

3.3.5 Description of Data and Period under Consideration

The source of the specific data, background data, and the period under consideration used shall be indicated.

Example: Product production is based on BOM information, product teardowns, and collection of product yield data from manufacturing sites from 2011 through 2012.

3.3.6 Data Quality

The inventory data collected will be flow-based, complete and follow ISO 14025, ISO 21930, and EN 15804 requirements as relevant regarding data quality, e.g. reproducibility, consistency, precision, uncertainty etc. Data shall be representative of the manufacturer’s data and conditions according to the following temporal, geographical and technological requirements.

− Temporal: The obtained information from the manufacturing process will be annual approximate values, and shall be no older than 5 years from the date of use. Average background (secondary) data shall not be older than 10 years. Deviations shall be justified.

− Geographical: The geographic region of the production sites included in the calculation of representative data shall be documented.

− Technological: Data will represent technology in use and reflect the physical reality of the material and/or product. Industry average data shall be checked for plausibility by the verifier.

Example: All primary data are from CY2011 and represent average production technologies. All background data used are less than 5 years old.

3.3.7 Background Data

In general, consistent background data must be used to guarantee the comparability of results.

− Generic data shall be checked for plausibility by the verifier of the EPD. This verification process is simplified when pre-verified generic data is used.

7 See ISO 14044:2006 Section B.2.3 from additional guidance.

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− Datasets originating from databases (e.g. ELCD, GaBi, ecoinvent) shall be indicated in the project report, including the year for which the dataset is representative. The representativeness of the datasets that are used has to be documented.

− The background data that is used and its sources shall be indicated in the EPD on a general basis.

While conformance to this PCR minimizes that variations and deviations, there are still components that might influence the comparability of EPDs. Caution should be used when interpreting results and applying them for comparative decisions making. The declarer must, where possible, use quantitative metrics to capture the uncertainty. At a minimum, the declarer will provide qualitative guidance in relevant sections to guide users in interpreting the information contained within the EPD relative to comparability and use for decision-making. The declarer must state that differences between environmental declarations are not guaranteed for comparative purposes

Example: Background data is based on "GaBi 5" Software System for Life Cycle Engineering, and GaBi Databases 2011. All background data sets relevant to production, power generation, and material disposal were taken from the GaBi 5 software.

3.3.8 Allocation and Methodological Principles

Allocations (assignment of burdens to several products) relevant for the calculation must be clearly indicated. (See Section 2.15)

3.4 Standards and Laws

Standards and laws listed in the EPD must be correctly referenced

Example: DIN EN ISO 14040:2006-10, Environmental management - Life cycle assessment - Principles and framework (ISO 14040:2006); German and English version EN ISO 14040:2006

3.5 Additional Environmental Information

An assessment of human toxicity and ecotoxicity shall be included in this additional information section of the declaration to give readers an understanding that these impacts are significant for printers. This assessment may include GreenScreen, USEtox, QCAT, ReCiPe midpoint version H method, CleanGredients, etc.

The project report shall include any documentation on additional environmental information declared in the EPD. Such documentation on additional environmental information may include, e.g. as copies or references:

− Type I and/or Type III environmental label − Acquisition of ISO 14001 certification − Certificates, approvals, or awards from national or industry organizations − Information on hazardous substances − Information on recommended recycling or reuse methods at end-of life. − VOC and PM emissions during manufacturing or use − Waste Categories: Additional information on environmental aspects describing different waste categories per

declared unit, such as: Hazardous waste to final disposal, in kg, Non-hazardous waste to final disposal, in kg, Radioactive waste to final disposal, in kg, Waste to energy in kg. The tool and the dataset used to categorize the waste shall be specified when reporting this information.

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Example: GGTM.P058.GREENGUARD Test Method for Office Equipment (Hardcopy Devices)

3.6 Additional Life Cycle Scenarios

Other life cycle scenarios may be reported in this section of the environmental product declaration (e.g., avoided burden recycling approach,). Each scenario shall be based on the relevant technical information. The source of the background data used must be indicated to determine the energy consumption of the product. Additionally, an assessment of data quality must be done and provided to the program operator. If additional scenarios, the additional data and information of importance for the development of the additional scenarios shall be published in the EPD in a supplement appendix titled “Appendix: Supporting Documentation of Additional Life Cycle Scenarios”. Data and information on how the scenario was established shall also be presented in a transparent manner in the supplemental appendix.

The additional scenarios shall be realistic. Scenarios shall not include steps or procedures that are not in current use or which have not been demonstrated to be practical.

3.7 References

The literature cited in the EPD must be referenced in full (see also references in this document)

3.8 Verification

The verification of the Environmental Product Declaration shall record that the LCA-based information and the additional information as declared in the EPD meet the requirements of ISO 14025.

product category rules for preparing an environmental product … · 2014-09-23 · product...

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