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Clarification of Standard Requirements The EPEAT PVC determined that, based on the clear wording of the relevant criteria, products could be considered upgradable if they contained an externally-accessible port through which additional capacity could be supplied to the registered product (or if they could be upgraded through physical replacement of parts). The PVC also ruled that tools required for disassembly or upgrade of registered products are deemed commonly available if they can be purchased by any individual or business on the open market, are not proprietary and do not require agreements between the buyer and seller. The PVC declined to specify precise parameters for what constitutes easy and safe disassembly or removal of components, because they noted such terms could encompass different details depending on the specifics of the product class in question and must be demonstrated in action. Comprehensive Review and Surveillance EPEAT staff performed a detailed surveillance review of all small and light products registered in the system. This review identified specific types of ultrathin construction that seemed most likely to encounter issues meeting the criteria of concern. This eliminated the majority of products under review, and left five products from four manufacturers with significant unresolved questions relating to conformance. Verification Investigation of the remaining five products was conducted through a formal verification investigation. In keeping with EPEATs standard approach, manufacturers subject to investigation were not notified in advance, and investigation was based on product registrations prior to the verification notification. (For more about verification in EPEAT, see http://www.epeat.net/learn-more/verification/) EPEAT requested standard disassembly instructions from each manufacturer for the products in question, then commissioned a technical test lab to independently purchase these devices on the open market, and disassemble them according to the instructions provided. Lab personnel were not trained recycling professionals, so they could be expected to provide more universally applicable data regarding questions of time and ease of disassembly than would a demonstration by a recycler. The lab disassembled each of the purchased products with full documentation of each disassembly process, including its overall duration. Time for total disassembly of each of the products was under 20 minutes in all cases; for the removal of batteries the time required was between 30 seconds and 2 minutes. As noted above, these times probably exceed what a skilled recycler would require. Given their findings, the lab recommended that all products be found in conformance with EPEAT requirements. About EPEAT EPEAT(R) is the definitive global registry for greener electronics, covering the most products from the broadest range of manufacturers across the widest array of countries. EPEAT combines comprehensive criteria for design, production, energy use and recycling with ongoing independent verification of manufacturer claims. The sale of more than 93 million registered products in 2010 resulted in solid waste reductions equivalent to 16,052 US households annual waste, and elimination of enough mercury to fill 437,048 fever thermometers. More than 120 million EPEAT registered products were sold across 41 covered countries in 2011. More information at: www.epeat.net