Form 9600-038 EPA Framework for the Assess. Of Env.

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Overview

Orientation
1. Instructions
2. Scoping Questions
3. Section I Criteria
4. Section II Criteria
5. Section III Criteria
6. Section IV Criteria
7. Attestations

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Sheet 1: Orientation

SUBMISSION TEMPLATE for EPA Framework for the Assessment of Environmental Performance Standards and Ecolabels for Federal Purchasing

For background on the purpose and history of the EPA Framework and its role in supporting EPA's Recommendations of Specifications, Standards, and Ecolabels, see: https://www.epa.gov/greenerproducts/framework-assessment-environmental-performance-standards-and-ecolabels-federal

Note that one organization should identify as the lead organization for each standard/ecolabel assessed.

To ensure adequate supply for government-wide use of a standard or ecolabel, there must be at least three (3) conforming products/services from at least two (2) different manufacturers at the time of the assessment to be eligible for EPA's Recommendations.

Under Section 1001 of title 18 of the United States Code, it is a federal crime to knowingly and willfully make a materially false, fictitious, or fraudulent statement in any matter within the jurisdiction of the executive, legislative, or judicial branch of the United States.

This collection of information is approved by OMB under the Paperwork Reduction Act, 44 U.S.C. 3501 et seq. (OMB Control No. 2070-0199). Responses to this collection of information are voluntary, as specified at 42 U.S.C 13101 and 15 U.S.C.3701. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The public reporting and recordkeeping burden for this collection of information is estimated to be 8.5 hours per response. Send comments on the Agency’s need for this information, the accuracy of the provided burden estimates and any suggested methods for minimizing respondent burden to the Regulatory Support Division Director, U.S. Environmental Protection Agency (2821T), 1200 Pennsylvania Ave., NW, Washington, D.C. 20460. Include the OMB control number in any correspondence. Do not send the completed form to this address.

ORIENTATION

This file contains the following worksheets to support implementation of the EPA Framework for the Assessment of Environmental Performance Standards and Ecolabels for Federal Purchasing located at https://www.epa.gov/system/files/documents/2022-02/updated-framework_020222.pdf :

Worksheet 1: Instructions
• Provides background, orientation, instructions, and contact details for the assessment.

Worksheet 2: Scoping Questions
• Establishes point of contact and asks questions intended to determine the scope of the assessment
• Asks questions to determine eligibility for EPA Recommendations pertaining to conforming product/service availability and adequacy of product registry.
• Additionally, questions in this section are intended to provide the federal government a general understanding of market penetration and alignment with overarching federal policy and implementation.

Worksheets 3, 4, 5, and 6
• Include the criteria for each of the four sections of the EPA Framework, a description of the associated sources of evidence, space for your organization to provide a response to each criterion, and a space for EPA to perform the assessment, where applicable.
• Applicants are required to respond to Section I Standards Development Process Baseline criterion I.1, Section II Environmental Effectiveness Baseline criteria II.1, II.2, as well as II.3 and II.4 when chemical substances of concern are a key hotspot for the purchase category, and Section III Conformity Assessment Baseline criterion III.1. These criteria are shaded in peach.
• Applicants are encouraged to respond to all other criteria for which they have information they would like to share with the federal government and the public (to be made available upon request); however, these responses will not be assessed for conformity to the criteria by EPA.
• Column [A] provides the number of each criterion.
• Column [B] notes whether each criterion (or sub-criterion) is considered a “baseline” (B) or “leadership” (L) practice.
• Column [C] provides the detailed criteria for the assessment. Column C also also provides any explanatory footnotes associated with the criteria.
• Column [D] describes some of the potential sources of evidence that could be submitted by your organization to support the response made. These are suggestions, not requirements.
• Column [E] provides space for your organization to provide a response and/or comment.
• Column [F] provides space for your organization to provide the name of the specific documents submitted as evidence with the assessment, along with the specific section or page number that supports the response(s) made in Column E.
• Column [G-K] will be used by EPA for the assessment where applicable.

Worksheet 7: Attestations
• For some criteria, and only where explicitly stated, self-attestation or a narrative response is considered sufficient evidence that an applicant meets the criteria.
• This worksheet is to be completed by the applicant and will serve as a quick summary of where attestations, in lieu of documentation, were used.

EPA Form No. 9600-038

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Sheet 2: 1. Instructions

INSTRUCTIONS

Step 1: Submit your responses to Worksheet 2: Scoping Questions to [email protected] within 2 weeks of receipt of submission template.
• This confirms your organization's interest in having your standard/ecolabel(s) assessed and allows EPA to confirm your eligibility. The rest of the workbook can be blank at this point.

Step 2: Applicant will receive confirmation of receipt and, if eligible, establishment of timeline of the assessment from EPA.
• If you don't receive an email within 5 business days of submitting worksheet 2, contact [email protected].

Step 3: Submit responses to each applicable criteria, per below, in worksheets 3 - 7 and all supporting evidence and attestations. Submit completed file and evidence to [email protected]. Please refer to the Framework as needed at: https://www.epa.gov/system/files/documents/2022-02/updated-framework_020222.pdf
• Applicants are required to respond to: Section I Standards Development Process criterion I.1; Section II Environmental Effectiveness criteria II.1 and II.2 as well as II.3 and II.4 when chemical substances of concern are a key hotspot for the purchase category; and Section III Conformity Assessment criterion III.1. These criteria are shaded in peach.
• Applicants are encouraged to respond to all other criteria for which they have information they would like to share with the federal government and the public (assessments will be made available upon request).
• Applicants should include document name and page number for each source of evidence. EPA is not expected to conduct extensive searching within lengthy documents to find specific evidence. It is within the EPA’s purview to request multiple sources of evidence or determine if multiple sources are needed for a criterion to be sufficiently assessed.
• If you are submitting individual files as sources of evidence, all file names should include the name of the organization. If you are submitting multiple standards or ecolabels for the Assessment, all file names should also include the name of the standard or ecolabel being addressed.
o Please clearly mark any confidential information (attachments or responses to criteria) as "CONFIDENTIAL" in the name of the file or in the text provided.
o The email from EPA in Step 2 will provide the deadline for submission of this material.
o Please send responses in this Excel file. A .pdf version of the Framework is available for additional information and review only.

Step 4: Receive Results of EPA Completeness check
• EPA will conduct an initial “completeness check” of the responses provided by the applicant, checking for clarity and gaps in evidence.
• EPA will note any gaps or questions in the worksheet, and send it back to the applicant point of contact, if needed.
• EPA will also establish a deadline to re-submit material.

Step 5: Re-submit Worksheets 3 - 7 (if needed)
• If EPA notes any gaps or required clarifications, submit an updated response with the additional evidence and or updated language in the worksheet(s).
• Any new text in the worksheet should be clearly marked using colored highlights and/or a different font color than the original submission.
• The first set of documents sent as evidence are not required to be re-submitted; only those that are new or that have been updated.

Step 6: Receive confirmation of receipt and establishment of timeline of the assessment from EPA
• If you don't receive an email within 5 days of re-submitting, contact [email protected].

Step 7: Receive assessment results
• EPA will review the applicant responses and sources of evidence and assign a "Yes" or "No" to indicate if each criterion is met. Where a response is left blank for a criterion that is required for the assessment, EPA will indicate "unknown," which will be considered as not meeting the criterion. A justification will be provided for each "No" determination.
• EPA will send the results of the assessment to the primary contact person via email including a report with a summary of results and information on if/how the standard/ecolabel/certification will be included in EPA's Recommendations of Specifications, Standards, and Ecolabels.
• For standards/ecolabels/certifications included in EPA's Recommendations, EPA will work with the organization(s) to develop a version of the assessment file that is publicly available (i.e., does not include confidential business information).
• Questions related to results can be submitted to [email protected].

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Sheet 3: 2. Scoping Questions

Questions to determine point of contact, scope of the assessment, and eligibility
Responses are to be submitted to this section before proceeding in order for EPA to confirm the scope of the assessment and eligibility for a full assessment and potential inclusion in the Recommendations.
Questions 8a and 8b regarding certified product/service availability and 9 regarding the product registry will be used to determine eligibility for inclusion in EPA's Recommendations; however, standards/ecolabels not yet meeting these eligibility criteria are still welcome to participate in this assessment and have the potential to be recognized by EPA as conforming to other sections of the Framework. Responses to question 10 may be used by federal purchasers when determining if/how to use the standard/ecolabel/certification to meet their agency goals and mandates.
Questions	Response/Comment	File Name
1. Name of Standard/Ecolabel		N/A
2. Lead organization for this assessment		N/A
3. Primary contact person for this assessment		N/A
4. Email address for primary contact person		N/A
5. Phone number for primary contact person		N/A
6. To what product/service category(ies) does the ecolabel or standard apply?		N/A
7. To participate, it is required to respond to: Section I Standards Development Process criterion I.1; Section II Environmental Effectiveness criteria II.1 and II.2 as well as II.3 and II.4 when chemical substances of concern are a key hotspot for the purchase category; and Section III Conformity Assessment criterion III.1. Please provide information on which additional criteria your organization/standard intends to be assessed. You may later decide to respond to more or fewer during the Assessment, but this information will help EPA's planning.		N/A
• Section I - Standards Development Process - It is required to provide a response for criterion I.1. If I.1 is not met, responses to other criteria in Section I are encouraged to inform potential federal users and other interested parties about the standard's development process.		N/A
• Section II - Environmental Effectiveness - It is required to provide responses for criteria II.1, II.2, as well as II.3 and II.4 when chemical substances of concern are a key hotspot for the purchase category. Responses to other criteria are encouraged to inform potential federal users and other interested parties about the standard's approach to addressing environmental impacts and performance opportunities.		N/A
• Section III - Conformity Assessment Process - It is required to provide a response for criterion III.1. If III.1 is not met, responses to other criteria in Section III are encouraged, where applicable, to inform potential federal users and other interested parties about conformity assessment procedures. Applicants have until December 2023 to demonstrate conformance to this Section of the Framework, at which point, conformance will be required for inclusion in EPA’s Recommendations. As of December 2023, all standards and ecolabels included in the EPA’s Recommendations will be required to demonstrate conformance to this Section of the Framework.		N/A
• Section IV - Ecolabel Program Management - It is not required to respond to this section. Where applicable, responses to this section are encouraged to inform potential federal users and other interested parties about the governance and implementation of the ecolabel.		N/A
8. Please provide any readily available documentation to demonstrate sufficient product/service availability for the federal marketplace including:
a. number of certified products/services – at least 3 are required for inclusion in EPA’s Recommendations
b. presence of competitive bidding – having more than one supplier with certified products/services is required for inclusion in EPA’s Recommendations
c. and/or percent of the products/services in the market certified to the standard/ecolabel for that product/service category.
9. Please provide links to demonstrate existence of a publicly available and current (i.e., updated in the last 3 months) registry of products/services conformant to the standard or ecolabel.
10. Please indicate if your standard includes criteria that meets or exceeds the following federal sustainable acquisition statutory mandates relevant to the product category(ies) your ecolabel or standard addresses. To see which requirements apply to the product category(ies) your ecolabel/standard addresses, go to https://sftool.gov/greenprocurement:
• Recycled content requirements per the Comprehensive Procurement Guidelines (42 U.S.C. §6962) (https://www.epa.gov/smm/comprehensive-procurement-guideline-cpg-program#products);
• Energy efficiency requirements per ENERGY STAR® or Federal Energy Management Program (FEMP) (42 U.S.C. §8259b) (https://www.energy.gov/eere/femp/search-energy-efficient-products);
• Biobased content requirements per the BioPreferred® program as indicated by the "FP" symbol. (7 U.S.C. §8102) (https://www.biopreferred.gov/BioPreferred/faces/pages/ProductCategories.xhtml); and/or
• Acceptable chemicals, products, and manufacturing processes listed under EPA’s Significant New Alternatives Policy (SNAP) program, which ensures a safe and smooth transition away from substances that contribute to the depletion of stratospheric ozone. (42 U.S.C §7671l) (https://www.epa.gov/snap)

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Sheet 4: 3. Section I Criteria

Criteria and Evidence				Applicant Submission		EPA Assessment
Criterion #	B/L	Criterion	Source of Evidence and Key Decision Parameters	Applicant Response/Comment	File Name(s) and Section or Page Number	Completeness Check	Gaps or Clarifications	Y/N	Justification	Notes
SECTION I: PROCESS FOR DEVELOPING STANDARDS Applicants responsible for developing the standard/ecolabel criteria should complete this section. It is required to provide a response for criterion I.1 indicated in peach. If I.1 is not met, responses to other criteria in Section I are encouraged to inform potential federal users and other interested parties about the standard's development process. EPA notes when a standard is not a Voluntary Consensus Standard (VCS) in the Recommendations. Section I allows two different ways to demonstrate if your standard is a VCS. 1) Per criterion I.1, the standard is an ANSI approved American National Standard (ANS) AND meets baseline criterion I.1.5 (balance of interest in decision making body) or 2) Meets all baseline criteria I.1.1 to I.1.14. Applicants are encouraged to respond to Leadership criteria I.2-I.8.
Baseline Criteria - Used to identify Voluntary Consensus Standards versus other types of standards
I.1	B	Voluntary consensus standard (VCS). The standard is a VCS as defined by OMB A-119 Section 4. If a standard is an ANSI approved American National Standard (ANS) AND meets criterion I.1.5, then the standard is considered a VCS. OR, if interested and applicable, instead demonstrate that the standard is a VCS by submitting responses to the following criteria I.1.1 to I.1.14, which are consistent with the requirements of internationally accepted protocols for standards development organizations. Notes: Other organizations’ standards development processes may also meet this definition and may be added in the future. Per the revised OMB Circular A-119 Section 5b, there is a preference for the use of VCSs. The Circular does not preclude the use of standards not built via a voluntary consensus based process in federal rulemaking, procurement, or other program activities in cases where VCSs do not exist or use of existing VCSs would be inconsistent with law or otherwise impractical, including where use of a VCS would not be as effective at meeting the agency’s regulatory, procurement, or program needs.	The evidence must include: - ANS Document number (note: ANSI accredited standards developers must also have the standard approved as an ANS to meet this criterion).
I.1.1	B	Conflicts of interest. The SDO addressed potential conflicts of interest during the standard’s development and fully disclosed funding sources for management of the development of the standard to interested parties. If significant external funding was made by one or more parties to support the standard’s development, the SDO had or put in place supplemental procedures to ensure that no conflict of interest occurred in administration of the standard development process. “Significant funding” is defined as more than $10,000 or its in-kind equivalent, or 20% or more of the anticipated funding needs of the SDO for standard development.	The evidence must include: - The policy or procedure in use when the standard was developed. - The policy or procedure should cover: conflicts of interest, separation of organizational functions necessary to address any potential conflict of interest. - Attestation that this policy or procedure was followed during the standard’s development. The evidence must also include one of the following: - Documentation that original sources of funding for standards development were disclosed to interested parties, such as a disclosure statement in the standard document, or in meeting minutes for relevant standard development working groups. - Attestation that no external funding was received. The evidence must also include one of the following: - If significant external funding was made, the SDO had or put in place supplemental procedures to ensure that no conflict of interest occurred in administration of the standard development process.
I.1.2	B	Transparency of participation procedures. The procedures or processes for participating in developing the standard were publicly available.	The evidence must include: - URL / webpage that contains the procedures or processes for participation in key standard development activities. This webpage must contain information on ways in which interested parties were able to participate in key standard development activities. - If the SDO no longer develops standards, documentation of prior procedures or processes for participation. The documentation must contain information on ways in which interested parties were able to participate in key standard development activities. The evidence must also include: - Attestation that procedures or processes for participation were transparent/publicly available at the time the standard was developed.
I.1.3	B	Announcements. Key standard development activities were announced publicly. Key standard development activities refers to the significant stages of the standard's creation, revision, reaffirmation, or withdrawal, including: 1. Initiation of standards development activity – including announcement of scope (purchase category(ies) and anticipated environmental/human health categories to be addressed; call for members/participation (voting, observing, and/or commenting) 2. convening of a decision-making body 3. availability of drafts/proposals for comment and/or vote 4. reconciliation of comments - responses to comments shared 5. adjudication of complaints and/or appeals 6. final approval/publication	The evidence must include: - Documentation of announcements for at least standard development activities 1, 3 and 6 as defined in the criteria.
I.1.4	B	Selection of membership of decision-making body(ies). Processes and procedures for selecting members of all decision-making body(ies) was transparent and non-discriminatory. Membership of any decision-making body/bodies was not unreasonably restricted on the basis of technical qualifications or other such requirements (e.g., membership in an organization). Reasonable restrictions include achieving a predefined target size of the body, achieving a balance of interests, and engaging diverse expertise.	The evidence must include all of the following: - Title of the decision-making bod(ies), who they report to, and description of the types of decisions they are responsible for. - Documentation of process/procedure for selecting members of all decision-making bodies that contains a list of restrictions (if any) on voting membership, and an explanation as to why they are reasonable. - Attestation that the process/procedure was followed during key standard development activities and available to decision-making body(ies) members and interested parties.
I.1.5	B	Balance of interest in decision-making body(ies). The SDO achieved a balance of interest in decision-making body(ies) by ensuring that no single interest category constituted more than a one-third (33%) of the membership of that body if there were 4 or more interest categories, or 40% of the membership if there were 3 designated interest categories. Note: Per OMB A-119 sect 2e(ii), “The standards development process should be balanced. Specifically, there should be meaningful involvement from a broad range of parties.” Definition of “balance of interest” may also be informed by ANSI essential requirements (2015), which defines “balance” as “a) no single interest category constitutes more than one-third of the membership of a consensus body dealing with safety-related standards or b) no single interest category constitutes a majority of the membership of a consensus body dealing with other than safety-related standards. Additional steps have been taken by a number of SDOs to further ensure a balance of diverse interests (e.g. limiting number of votes per organization, confirming accuracy of affiliations, actively recruiting additional members from other interest categories).	The evidence must include: - Guidelines and/or policy for balance of interest when the decision-making body(ies) were formed. This document should align with ANSI essential requirements 1.3 and 2.3 for balance of interest. -Attestation that these guidelines or policy was followed during the standard’s development. - Documentation that no more than one-third of the decision-making body(ies) was from one interest category, or no more than 40% if there were only three interest categories. - A roster of voting members for all decision-making bodies that clearly presents membership by interest category, and demonstrates that a balance of interests was met.
I.1.6	B	Lack of dominance in decision-making body(ies). Decision making procedures/guidance ensured that no single interest category or organization could dominate the decision-making body(ies). Note: Per OMB A-119 sect 2e(ii), there should be “no single interest dominating the decision-making.” ANSI essential requirements 1.2 defines “dominate” as “to take a position or exercise of dominant authority, leadership, or influence by reason of superior leverage, strength, or representation to the exclusion of fair and equitable consideration of other viewpoints.”	The evidence must include all of the following: - Guidelines/procedures that reflect that no organization or interest category can dominate decision-making. - Attestation that guidance/procedure was followed. The evidence must also include one of the following: - If an interested party has submitted a written complaint about dominance, documentation that it was resolved satisfactorily. - Attestation that no interested party has submitted a written complaint about dominance (see ANSI essential requirements Section 2.2).
I.1.7	B	Timely and adequate notice to participate. Timely and adequate public notice was provided to generate participation by interested parties in key standard setting development activities (as defined in I.1.3). Note: Timely and adequate notice is generally described as keeping interested parties or decision-making body(ies) (as applicable) up to date and engaged in key standard development activities, and providing sufficient time for response. For purposes of this criterion, SDOs must follow the ANSI essential requirements or provide a minimum of 30-day notice. ANSI essential requirements stipulates 30-day comment periods for proposals 5 pages or less in length, 45-days for readily available proposals (available within 1-day of a request to receive it), or 60-days if the above 2 options are not applicable.	The evidence must include one of the following: - Schedule of notifications published on two of the six key standard development activities and deadlines imposed for participation demonstrating: 1) date posted 2) Deadlines to response 3) Notification periods meets ANSI essential requirements, or a minimum of 30-day notice. - Notifications of key standard development activities indicating when posted, and that notification period met ANSI essential requirements or a minimum of 30 days.
I.1.8	B	Timely and adequate notice to participate - Decision-making body(ies). Timely and adequate notice (as defined in I.1.7) was provided to members of decision-making body(ies) to participate in the standard development process including by: - Accessing draft standards documents - Providing input to draft standards documents and supporting documents - Reviewing minutes of all meetings, comments and responses thereto, and the results of complaints and appeals made during the standard development process - Providing access to agendas with meeting times/locations.	The evidence must include: - Documentation of three instances where the SDO sent relevant information to the decision-making body(ies) in advance of decision-making body(ies) meetings and ballots per the definition of “timely and adequate notice” in I.1.7.
I.1.9	B	Consideration of interested party input. Fair and equitable consideration of input on key standard development activities (as defined in I.1.3) received by the designated due date from interested parties was documented, adjudicated, and responded to by the SDO in accordance with its procedures. Where voting/balloting was used, input was made available to the voting members and considered before a final vote was taken on the standard.	The evidence must include all of the following: - Documentation of policy or procedure for ensuring input from interested parties on key standard development activities was fairly considered. - A sample of comments from interested parties and responses to comments on draft documents.
I.1.10	B	Policies for patented technology. Standards that include patented technology are governed by Intellectual Property Rights (IPR) policies, which include provisions requiring that owners of the patented technology incorporated into a standard make that IP available to implementers of the standard on nondiscriminatory and royalty-free or reasonable royalty terms (and to bind subsequent owners of standards essential patents to the same terms). The IPR policies should be easily accessible, set out clear rules governing the disclosure and licensing of the relevant intellectual property, and take into account the interests of all parties, including the IP holders and those seeking to implement and assess the standard.	The evidence must include one of the following: - Attestation that the standard does not include patented technology. - Publicly available patent policy with an explanation of how this policy aligns to the criterion. Documentation of assertion of any standard-essential patents (SEPs) along with the RAND (reasonable, and non-discriminatory) or FRAND (fair, reasonable, and non-discriminatory) licensing commitment.
I.1.11	B	Consensus effort. Reasonable efforts to achieve consensus were made by the decision-making body(ies) with procedures to ensure that comments and objections from interested parties were considered using fair, impartial, and open processes. Note: Per OMB A-119 Section 2e(v) “Consensus is defined as general agreement, but not necessarily unanimity. During the development of consensus, comments and objections are considered using fair, impartial, open, and transparent processes.”	The evidence must include all of the following: - Documentation of a policy/procedure that lays out the decision-making process and reasonable efforts to reach it including: applicable definition of what constitutes consensus (e.g. the percentage of affirmative votes required to approve any ballot), how it is reached, and that key standard development activities included procedures for reasonable efforts including (but not limited to): registering comments, an adequate process for resolving comments and objections; commenters and/or objectors are each advised as to the reasons why the comment/objection was resolved or not resolved; and the members of the decision-making body(ies) are able to change their votes after reviewing the comments. - Attestation that the process/procedure was followed during the standard’s development. - Agenda and/or minutes of key meetings showing that efforts towards consensus were on the agenda and/or considered in letter balloting.
I.1.12	B	Technical/substantive comments and/or objections. Comments/objections regarding the standard received in writing during the standard development process were documented and made available to the decision making body. The SDO made a meaningful written response to the comment/objection and/or made a responsive change to the standard prior to the decision-making body(ies) moving forward. If a comment/objection was not resolved in the development process, commenters/objectors were advised as to their right and scope of appeal.	The evidence must include all of the following: - Policy or procedures on communication of comments/objections requiring documentation, responses, access by decision making body(ies), and notification of right of appeal. - Agenda/meeting minutes or other evidence demonstrating the policy was applied in practice, including some record of the practice of resolving specific objections prior to the decision-making body(ies) moving forward. OR Attestation that no comments/objections were received, or if comments/objectives were received, they were not sustained.
I.1.13	B	Procedural appeals mechanism. A documented appeals mechanism was published before initiation of the standard’s development to address procedural objections. The body handling procedural appeals is separate and independent from the body handling technical/substantive comments/objections. The process for initiating an appeal is straightforward, requires simple notice (articulation) of the basis for the appeal, and does not impose redundant or unnecessary costs, paperwork or documentary requirements. A reasonable time is offered between the deadline to lodge a notice of appeal and the time of the final vote/decision. A reasonable time to file an appeal is at least 15 days prior to the date of the final vote.	The evidence must include all of the following: - Documentation of a policy/procedure for appeals, and documentation that it was made public and/or available to interested parties before key standard development activities (e.g., website posting, email, etc.). - The policy/procedure must have a clear process defined in straightforward language. - Documentation of policy and/or disclosure of any financial imposition made on interested parties undertaking an appeal. - The policy/procedure must indicate that appeals must be submitted to an impartial body, for example, a panel of 5 of which at least 3 are agreeable to both sides. - The policy/procedure must indicate that a reasonable time is provided between the deadline to lodge a notice of appeal and the time of the final vote/decision. Attestation that the process/procedure was followed during the standard’s development.
I.1.14	B	Publicly available criteria. The SDO makes publicly available (free of charge or for a reasonable cost) the criteria and/or standard.	The evidence must include one of the following: - URL to webpage that contains the criteria and/or standard. - URL to webpage that contains a description of how interested parties can access the standard.
Leadership Criteria
I.2	L	Analysis of environmental/human health impacts available to participants. The SDO encouraged decision-making body(ies) members to compile and share analyses conducted, and made available to the decision-making body(ies) members any analysis conducted of the environmental and human health issues associated with the product/service category, including those that address life cycle stages, environmental and/or human health hotspots, and/or chemicals of concern under consideration. Such analysis or information provided or shared also demonstrates the methodologies that were utilized. This criterion is applicable to both multi- and single- attribute standards. Note: Standards developers should use the most appropriate types of assessment methods for the determination of the impacts or attributes addressed in the standard. Impact assessment methodologies for issues of toxicity, land use, biodiversity, water use and other spatially explicit impacts are nascent in life cycle assessment (LCA) and there is not sufficient scientific evidence to reflect their effectiveness. For those impact areas, LCA is not sufficient in determining relative importance and other methods (e.g., traditional toxicity risk assessment studies, hazard identification, biodiversity surveys/IUCN redlist threats, peer-reviewed scientific literature) should be utilized in making these determinations. Given the vast data gaps in LCA databases on these impact areas, even if new methods exist, the results of the studies cannot be relied upon to determine importance.	The evidence must include all of the following: - The analysis(es) and associated methodology(ies) provided or shared. - Documentation that demonstrates that analysis(es) and associated methodology(ies) were encouraged to be shared, and/or shared with decision-making body(ies) members, such as documentation of communication, meeting agenda or minutes discussing these analysis(es), or a policy/procedure stipulating that they were to receive these analysis(es).
I.3	L	Existing standards. At the outset of the standard development process, the SDO identified existing standards that may have been in conflict, incompatible, or overlapping in content with the draft standard and demonstrated effort to coordinate and/or resolve conflicts/incompatibilities with those standards, or merge or achieve interoperability between standards, as appropriate. Once established, the SDO continues to monitor for new standards that may overlap, and seeks to coordinate or resolve any conflicts or incompatibilities.	The evidence must include: - Attestation that at the outset of key standard development activities, the SDO searched for potentially conflicting / incompatible / overlapping in content standards in existence or under development. - Attestation that the SDO continues to monitor new standards that may overlap with the standard, and that the SDO seeks to coordinate with new standards and resolve any conflicts or incompatibilities. If such an existing standard was found at the outset of standard development activities, the evidence must also include one of the following: - Documentation of outreach to other standards developer(s) in an effort to resolve issue(s). - Rationale as to why an existing standard was not approached, including, for example, because of an insufficient level of protection, fundamental geographical factors or fundamental technological problems.
I.4	L	Interested party participation: active outreach. The SDO actively sought participation from interested parties. Note: Active outreach may include but is not limited to identifying and contacting interested parties, inviting participation, and maintaining appropriate communications with interested parties.	The evidence must include all of the following: - Outreach plan to identify and contact a diverse set of interested parties. - Evidence of active outreach such as email invitations and communications.
I.5	L	Transparency of activities. Minutes of all decision-making body(ies) meetings, comments and responses thereto, and complaints and appeals made during key standard development activities were available to interested parties for inspection with timely and adequate notice (as defined in I.1.7).	The evidence must include at least two of the following: - Documentation of a policy on posting meeting minutes, comments/responses, and complaints/appeals. - Attestation that this policy was followed during key standard development activities. - Meeting minutes of decision making body(ies) with documentation of prompt date of posting; documentation of complaints and appeals made; and comments and responses thereto posted publicly to the SDO/standards website.
I.6	L	Interested party participation: fees and travel. There was no fee or travel requirement to participate in key standard development activities. OR, if there was a fee, it was minimal or offset by a sliding scale for hardship parties, including individual/NGO/academic members of the decision-making body(ies). The SDO provided travel funds to hardship parties without financial means to attend in-person meetings, virtual access to meetings, fee waivers, and/or other mechanism to retain their ability to participate in standards activities.	The evidence must include all of the following: Documentation that membership/participation in the decision-making body(ies) was free. - Fee schedule showing sliding scale / waivers. The evidence must also include one of the following: - Travel funds policy showing funds made available to interested parties without financial means to participate. - Evidence of virtual access to meetings (e.g. webinar recordings, conference call lines).
I.7	L	Selection of leadership of decision-making body(ies). Selecting of leadership for decision-making body(ies) was based on fair, impartial and open processes, and transparent to the decision-making body(ies) members.	The evidence must include all of the following: - Written procedure for leadership selection showing fair, impartial and open process such as voting or ballots. - Attestation that this procedure was followed during standard development and provided to decision-making body(ies) members.
I.8	L	Standard updates. Standard has been opened for either revision, continuous maintenance or reaffirmation at least every five years. For a younger standard, it is scheduled to be revised or reaffirmed at least every 5 years.	The evidence must include all of the following: - Policy or procedure stating schedule for expected revision, continuous maintenance or re-affirmation of the standard. Text supplied shows that standard is scheduled to be revised/ reaffirmed every five years or less from the date of the last standard version.

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Sheet 5: 4. Section II Criteria

Criteria and Evidence				Applicant Submission		EPA Assessment
Criterion #	B/L	Criterion	Source of Evidence and Key Decision Parameters	Applicant Response/Comment	File Name(s) and Section or Page Number	Completeness Check	Gaps or Clarifications	Y/N	Justification	Notes
SECTION II: ENVIRONMENTAL EFFECTIVENESS OF THE STANDARD Applicants responsible for developing and maintaining the content of the standard should complete Section II. It is required to provide responses for criteria II.1, II.2, as well as II.3 and II.4 when chemical substances of concern are a key hotspot for the purchase category (the four criteria are indicated in peach). The results of the baseline criteria assessment will determine inclusion in EPA’s Recommendations and, if multi-attribute or single attribute, potential tiering/preference. Responses to criteria II.4-II.8 are encouraged to inform potential federal users and other interested parties about the standard's approach to addressing environmental impacts and performance opportunities.
Baseline Criteria
II.1	B	Weighting methodologies. If a weighting scheme is used, the standard, and/or other supplementary materials that accompany the standard and are available to the public, fully and transparently explains the weighting methodologies/point allocations, including identification of the number of points or credits associated with each attribute and a clear explanation of how these points were determined. Note: Care should be taken to ensure that weighting and aggregating of impacts do not introduce a level of subjectivity above and beyond the inherent uncertainty in any given impact indicator. Such approaches run the risk of reducing transparency—diminishing the opportunity to improve purchasers’ environmental literacy and hiding potential environmental and/or human health trade-offs.	The evidence must include: - URL to webpage that provides information on the number of points or credits associated with each attribute (e.g. energy reduction, EMS certification, etc.) and a clear explanation of how these points were determined.
II.2	B	Hotspots/specific lifecycle stage impacts. Standards shall strive to address all hotspots across the life cycle of the product/service or clearly indicate if they are intentionally only addressing one hotspot or a limited number of hotspots for a product/service. Pollution prevention approaches to addressing climate, toxic chemicals, and materials management are preferred. II.2.1 For standards claiming to address the pre-extraction and raw materials sourcing stages, the standard meaningfully and measurably addresses the hotspots for the applicable product /service category(ies). AND II.2.2 For standards claiming to address the manufacturing stage, the standard meaningfully and measurably addresses the hotspots for the applicable product / service category(ies). AND II.2.3 For standards claiming to address the installation/use stages, the standard incorporates by reference or aligns with the standards for the applicable product / service category(ies). AND II.2.4 For standards claiming to address the end of life stage, the standard meaningfully and measurably addresses the hotspots for the applicable product category(ies). Note: chemical substances of concern may also be identified as a hotspot. However, these issues are addressed in criteria II.3, II.4, and II.5.	The evidence must include all of the following: - Text of the standard provides a clear protocol for measuring whether a product has achieved the standard’s target level(s) of performance for the hotspot(s) addressed. Instead of stating that the organization, facility, and/or the product/service “shall” meet the criteria, unacceptably vague criteria for a hotspot would include those stating that an entity should “consider,” “be involved in,” or “promote” an activity, approach, or philosophy without specifying resulting performance or prescriptive outcomes. Note that both performance criteria and prescriptive criteria may appear in the same standard. - Applicant’s written justification (within the information collection tool), including where it is addressed in the standard, for the hotspot(s) the standard is claiming to meaningfully and measurably address. - Where the standard refers to other standards (e.g., for VOC emissions), applicants can demonstrate conformance to this criterion II.2 either by incorporating the standard specifically referenced in the criterion, or by demonstrating alignment with the referenced standard(s) (i.e., explaining how the performance requirements of their standard are equivalent to or stricter than the criterion referenced standard). International equivalencies will be accepted if the applicant can demonstrate equivalence to the US standard(s).
II.3	B/L	Reducing Toxicological Hazards. The standard includes environmental and human health protection criteria to decrease the toxicological hazard of the product through one or more of the following methods: substitution of chemicals of concern for safer alternatives; reduction or elimination of chemical substance(s) of concern; or alternative design approaches. Note: Chemical substances of concern include carcinogens, mutagens, Persistent Bioaccumulative Toxics (PBTs), reproductive and developmental toxicants, acute mammalian toxicants, repeated dose toxicants, respiratory sensitizers, and chemicals on the complete and current EPA Toxics Release Inventory (TRI) identified as PBTs or other chemicals per Appendix A.	The evidence must include all of the following: - The standard must specify at least 1 of the 3 methods listed in the criterion. - The SDO fully and transparently explains its methodology for the criteria, including an indication of the source(s) consulted in developing criteria to address chemical substances of concern. The source(s) must be one or more of the lists in Appendix A of this Framework.
II.4	B/L	Disclosure of chemical substances of concern: 0.01%. The standard requires or incentivizes public disclosure of all intentionally added chemical substances of concern present in each homogenous material in the final product at 100 parts per million (0.01%) or greater. Note: Chemical substances of concern include carcinogens, mutagens, Persistent Bioaccumulative Toxics (PBTs), reproductive and developmental toxicants, acute mammalian toxicants, repeated dose toxicants, respiratory sensitizers, and chemicals on the complete and current EPA Toxics Release Inventory (TRI) identified as PBTs or other chemicals per Appendix A. This criterion is not applicable to process and production method standards, which do not address the environmental or human health performance of a finished product. Process and production method standards address unfinished (not final) products and have a more limited focus on performance issues related to specific aspects of production or preproduction, such as (for example) extraction or transport.	The evidence must include all of the following: - Text of standard requires (via a prerequisite) or incentivizes (via an optional credit) chemical disclosure to the public at the specified threshold. - Indication of the source(s) consulted in developing criteria to address chemical substances of concern. The source(s) must be one or more of the lists in Appendix A of this Framework. OR Text of standard indicating it is solely a process and production method standard.
Leadership Criteria
II.5	L	Disclosure of all added chemicals: 0.1%. The standard requires or incentivizes disclosure (either publicly or to a third party) of all intentionally added chemical substances present in each homogenous material in the final product at 1000 parts per million (0.1%) or greater. This criterion is not applicable to process and production method standards, which do not address the environmental or human health performance of a finished product. Process and production standards address unfinished (not final) products and have a more limited focus on performance issues related to specific aspects of production or preproduction, such as (for example) extraction or transport.	The evidence must include all of the following: - Text of standard requires (via a prerequisite) or incentivizes (via an optional credit) chemical ingredient disclosure at the specified threshold. OR Text of standard indicating it is solely a process and production method standard.
II.6	L	Impact assessment disclosure. The standard requires or incentivizes the manufacturer to publicly disclose any of the following (where they may exist): - the results of existing life cycle assessments (LCAs), - an Environmental Product Declaration (EPD) pursuant to ISO standards; - the results of a chemical alternatives assessment; and/or - the results of other environmental and/or human health impact assessments.	The evidence must include: - Text of standard requires (via a prerequisite) or incentivizes (via an optional credit) public disclosure of at least 1 of the types of assessments listed.
II.7	L	Trade-offs. The standard and/or supplementary materials that accompany the standard clearly identifies any known trade-offs among approaches to address multiple impact areas. Note: Trade-offs should be between different environmental impact areas, not between environmental impacts and non-environmental concerns. Trade-offs may include requirements that proposed environmental criteria identify trade-offs, even if the standard being evaluated does not identify specific trade-offs itself. Simply addressing multiple environmental impacts is not likely to be considered trade-offs.	The evidence must include: - Documentation (in the standard and/or supplementary materials that accompany the standard) addressing trade-offs among impacts.
II.8	L	Innovation. The standard meaningfully and measurably addresses additional environmental and/or human health impacts beyond those identified in the Section II criteria.	The evidence must include: - Text of innovative criteria in standard and explanation of how the approach is innovative and how it results in improved environmental and/or human health performance. Examples of Innovations include: - Additional attributes included in standard (beyond hotspots specified). - Attributes that meaningfully address environmental human health impacts (meeting the Leadership threshold that a specific approach or measurable outcomes are required, i.e., no ‘management plan’ approach as allowed for Baseline hotspots in II.2). - Other innovations may be considered. The following are generally not considered innovations for the purposes of this criterion: - Attributes claimed as hotspots in II.2. - Generic credits within standards that provide for “innovations” that are not specified by the standard.

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Sheet 6: 5. Section III Criteria

Criteria and Evidence				Applicant Submission		EPA Assessment
Criterion #	B/L	Criterion	Source of Evidence and Key Decision Parameters	Applicant Response/Comment	File Name(s) and Section or Page Number	Completeness Check	Gaps or Clarifications	Y/N	Justification	Notes
SECTION III: CONFORMITY ASSESSMENT Applicants responsible for conducting conformity assessment or setting rules for those who conduct conformity assessments to the standard, should complete Section III. It is required to provide a response for criterion III.1 (indicated in peach). Applicants (and/or their partner conformity assessment bodies) need to meet criterion III.1 OR criteria III.1.1 to I.1.21 in order to be considered an accredited or conforming certification body for the purposes of the Framework. Applicants have until December 2023 to demonstrate conformance to this Section of the Framework, at which point, conformance will be required for inclusion in EPA’s Recommendations. Note: Section III of EPA’s Framework provides a mechanism to demonstrate that a CAB is competent to assess conformance with the standard and follows general good practice specific to conformity assessment for environmental performance standards. An alternative method to demonstrate that a CAB is competent to assess conformance to a standard is proof of accreditation by an accreditation body that is a signatory to the International Accreditation Forum Multilateral Recognition Arrangement (IAF MLA) for a scope including ISO/IEC 17065 and this applicable standard. Guidance on Federal Conformity Assessment (15 CFR Part 287) directs federal agencies to identify appropriate private sector conformity assessment practices and programs (including third-party certification) and consider the results of such practices and/or programs as appropriate in procurement activities. The Guidance stresses that responsibility for the determination of appropriateness rests with each agency.
Baseline Criteria
III.1	B	Accreditation. Demonstrate conformance to relevant standards within the ISO/IEC 17000 series, e.g., ISO/IEC 17065 (for the ecolabeling certification program scope in accordance with (ISO 17020)); 17025 (testing); 17024 (personnel); 17020 (inspection). Accreditation body must be a member of the International Laboratory Accreditation Cooperation (ILAC) or International Accreditation Forum (IAF). OR, if interested and applicable, instead demonstrate that a competent certification exists by submitting responses to the following criteria, III.1.1 – III.1.21, which are consistent with the requirements of internationally accepted standards for operations of conformity assessment body(ies).	The evidence must include one of the following: - CAB certificate(s) of accreditation to relevant standard(s) within the ISO/IEC 17000 series. Stated accreditation body must be a member body to ILAC or IAF. - If the CAB(s) are accredited to the relevant standard(s) within the ISO/IEC 17000 series for a different standard/ecolabel than is being submitted for assessment, certificate of accreditation and attestation by the CAB(s) that they follow the same procedures for the standard/ecolabel being assessed. Stated accreditation body must be a member body to ILAC or IAF. - Ecolabel program requirements for CABs to be accredited to relevant standard(s) within the ISO/IEC 17000 series by an accreditation body that is a member body to ILAC or IAF.
III.1.1	B	Information on fees. Provide general information on fees to those seeking certification and clients. Note: Reflects ISO/IEC 17065 - 4.6	The evidence must include one of the following: - Example communication from CAB(s) to those seeking certification that includes information on fees, and information on when and how this information is provided. - Ecolabel program requirements for CABs to provide information on fees to those seeking certification, including information on when and how this information should be provided. Evidence must refer to fees for certification services, not other fees such as for licensing or application to the ecolabel program, unless the fees are combined and an explanation is provided.
III.1.2	B	Independence. The CAB(s) are defined and are independent from the organization whose products/services are being assessed for conformity.	The evidence must include one of the following: - Attestation (by either the CAB(s) or ecolabel program) that the CAB(s) are independent from those seeking certification. - Organizational structure/chart of CAB entity(ies) showing independence from producers. - Ownership structure of CAB(s) explained/attested (by either the CAB(s) or ecolabel program). - Ecolabel program requirements for CABs to be independent from those seeking certification.
III.1.3	B	Impartiality of decision-making. Organizational chart and management system of the CAB(s) reflect impartiality of decision-making on conformity assessment. Note: Reflects ISO/IEC 17065 - 5.1.1	The evidence must include one of the following: - Policy, organizational chart, procedure, or quality manual for CAB(s) showing clear separation of certification from other business activities (if any) and structures (such as reporting, or separation of roles) to ensure impartiality of certification decisions. - Ecolabel program requirements for CABs to separate certification from other business activities (if any) and structures (such as reporting, or separation of roles) to ensure impartiality of certification decisions.
III.1.4	B	Impartiality risks. Periodically review risks to their impartiality, and take appropriate steps to mitigate identified risks.	The evidence must include one of the following: - Plan for periodic review of risks and steps taken to mitigate risks for CAB(s) (may be in quality procedures, advisory body minutes, management meeting minutes) - Results of reviews and actions taken by CAB(s). - Ecolabel program requirements for CABs to periodically review risks to their impartiality and steps they are required to take to mitigate identified risks.
III.1.5	B	Free from undue pressures. Commercial, financial or other pressures are not allowed to compromise impartiality, including ensuring that personnel (management and staff) are free from such pressures. Note: Reflects ISO 17065/IEC - 4.2.2	The evidence must include one of the following: - Policy / procedure demonstrating that staff and management of CAB(s) remain impartial in their CA work and are not subject to undue pressure. Policy/procedure must clearly describe risks and safeguards against them. - Ecolabel program requirements for CABs to ensure that staff and management remain impartial in their conformity assessment work and are not subject to undue pressure. Requirements must clearly describe risks and safeguards that CABs should have against them.
III.1.6	B	Conflict of interest policy. Procedure or policy in place to ensure that the personnel conducting conformity assessment have not had a professional relationship in the past two years nor on-going financial connection with the organization to which they are providing their services. Note: Reflects ISO/IEC 17065 4.2 AND 5.2	The evidence must include one of the following: - Policy / procedure for managing conflicts of interest of staff of CAB(s) that covers past and present relationships specific to the CA being undertaken. Policy/procedure must mention a two-year period. - Ecolabel program requirements for CABs to have a policy/procedure to manage conflicts of interest of staff that covers past and present relationships specific to the conformity assessment being undertaken. Requirements must mention a two-year period.
III.1.7	B	Sufficient personnel. Process to ensure that CAB(s) have sufficient personnel with the education, training, technical knowledge and experience necessary for performing conformity assessment functions. Note: Reflects 17065/IEC - 6.1.1.1	The evidence must include one of the following: - Description by CAB(s) on how they ensure that they have enough staff to conduct certifications, that their staff is qualified for conformity assessment activities, including staff qualifications (in job advertisements, records, or CVs) and description of training to assess conformance to the standard. - Ecolabel program requirements for CABs to have a process to ensure that they have enough staff to conduct certifications, that their staff is qualified for conformity assessment activities, including requirements for staff qualifications and training to assess conformance to the standard. Evidence must be specific to the particular standard submitted for assessment, rather than general procedures for any standard.
III.1.8	B	Adequate facilities & equipment. All the facilities and equipment needed to carry out their work are in place; if testing is required by the standard, competent and/or accredited laboratories are utilized. This criterion is only applicable if testing is required by the standard. Note: Broadly reflects ISO/IEC 17065 - 7.3.1	The evidence must include one of the following: - Laboratory accreditation certificate for conformance with ISO 17025 or equivalent standard. - Attestation (by either the CAB(s) or ecolabel program) that testing is not required for certification. - Ecolabel program requirements for CABs to utilize laboratories accredited to ISO 17025 or equivalent standard.
III.1.9	B	Quality objectives. Documented commitment to fulfilling quality objectives and/or an established quality management system that is implemented in the CAB(s)’s organization. Reflects ISO/IEC 17065 - 8.2.1. Note: A quality management system is a formalized system that documents the structure, responsibilities, and procedures required to achieve effective quality management (American Society for Quality Glossary, http://asq.org/glossary/q.html). An example of a standard for quality management systems is ISO 9000, see: http://www.iso.org/iso/home/standards/management-standards/iso_9000.htm.	The evidence must include one of the following: - Policy / procedure for CAB(s) indicating commitment to quality. - Quality management system manual and/or internal audit and management report for CAB(s). - Ecolabel program requirements for CABs to have a quality management system or a policy/procedure indicating commitment to quality.
III.1.10	B	Records management. Procedures for ensuring documents are identified, stored, protected, retrieved and retained and disposed of to ensure the protection of confidential information. Note: Reflects ISO/IEC 17065 - 8.4.1	The evidence must include one of the following: - CAB(s)’s policy/procedure for document control and retention to protect client confidentiality. - Quality management system for CAB(s) covering document management and client confidentiality. - Ecolabel program requirements for CABs to have a policy/procedure for document control and retention to protect client confidentiality.
III.1.11	B	Role separation. The process for making conformity decisions includes an independent review that the product/service has met the specified requirements. Note: Reflects ISO/IEC 17065 7.6	The evidence must include one of the following: - Policy/procedure for CAB(s) describing the evaluation process and who makes the conformity assessment review and decision. - Ecolabel program requirements for CABs to have a conformity assessment process that includes an independent review that the product/service has met the specified requirements. Policy/procedure must be specific to the particular standard submitted for assessment, rather than general procedures for any standard.
III.1.12	B	Documented procedures: general. Procedures are documented for conformity assessment processes. For example, procedures may be documented through a quality management system that provides general management system documentation (e.g. manual, policies, and definition of responsibilities); control of documents; control of records; management review; internal audit; corrective actions; preventive actions. Note: Reflects ISO/IEC 17065 - 8.1	The evidence must include one of the following: - List of documented relevant policies and procedures for CAB(s). - Documentation of quality management system for CAB(s), including a copy of the internal audit and management review, log of complaints and comments, and corrective actions taken. - Other relevant documentation of procedures for conducting conformity assessment. - Ecolabel program requirements for CABs to document procedures for their processes.
III.1.13	B	Documented procedures: standard-specific. Formal decision-making procedures and thresholds are documented demonstrating rules for when conformance or nonconformance is determined, and this information is publicly available.	The evidence must include one of the following: - CAB(s)’s documented procedures/verification protocols for determining conformance to the particular standard submitted for assessment. These procedures must be disclosed publicly or available upon request. - Ecolabel program requirements for CABs to document procedures for determining conformance to the particular standard submitted for assessment. Requirements must include that the CABs make these procedures publicly available or available upon request. The standard itself is generally not sufficient to meet this criterion, unless the standard includes verification protocols. Procedures must be specific to the particular standard submitted for assessment, rather than general procedures for any standard.
III.1.14	B	Take all necessary steps to evaluate conformance. Demonstrate that they take all steps necessary to determine conformance with the standard.	The evidence must include one of the following: - Policy/procedure used to evaluate the product/service for the CAB(s). Policy/procedure must clearly indicate that the CAB takes all steps necessary to determine conformance. - Ecolabel program requirements for CABs to take all steps necessary to determine conformance with the specific standard submitted for assessment. The standard itself is generally not sufficient to meet this criterion. Evidence must be specific to the particular standard submitted for assessment, rather than general procedures for any standard.
III.1.15	B	Traceability procedures. Traceability or chain-of-custody procedures are in place where this is necessary to ensure qualified products/services meet the standard. This criterion may not be applicable to all standards.	The evidence must include one of the following: - Policy/ procedure for traceability/chain of custody by CAB(s) demonstrating conformance with the criterion. - Ecolabel program requirements for CABs to have traceability or chain-of-custody procedures. - Justification of how this criterion is not applicable to the product/service category and/or the standard. Traceability/ chain of custody relates to the product /service in question or components therein, and does not relate to protection of the CAB(s) or ecolabel marks.
III.1.16	B	Certification conditions specified. Documentation of how and when conformance is maintained, extended, suspended or withdrawn is publicly available. Note: Reflects ISO/IEC 17065 - 7.6.2	The evidence must include one of the following: - Policy/procedure on how and when conformance is maintained, extended, suspended or withdrawn by CAB(s). The policy/procedure is disclosed publicly or available upon request. - Ecolabel program requirements for CABs to have a policy/procedure on how and when conformance is maintained, extended, suspended, or withdrawn, and to make the policy/procedure publicly available or available on request.
III.1.17	B	Content of declarations of conformity. Provide declarations of conformity that clearly convey information on: the name and address of the CAB; the date conformity assurance is granted; name and address of the client; the scope of the conformity assurance; the term or expiration date of conformity assurance; the signature or other defined authorization of the person(s) of the CAB assigned such responsibility. Note: Reflects ISO/IEC 17065 - 7.7.1 & 7.7.2	The evidence must include one of the following: - Example declaration of conformity by the CAB(s) meeting at least five of the six elements listed in the criterion. Required information may be located in separate documents. - Ecolabel program requirements for CABs to provide declarations of conformity that meet at least five of the six elements listed in the criterion.
III.1.18	B	Periodic evaluation of marked products/services. When continuing use of a conformity assurance mark on a product/service is authorized, the CAB(s) periodically conduct surveillance of marked products/services to ensure ongoing validity of continued conformance. This criterion is not applicable if the CAB(s) do not conduct market surveillance. (This is addressed for ecolabel programs in Section IV.) Note: Reflects ISO/IEC 17065 - 7.9.3	The evidence must include one of the following: - Policy/procedures on how long products/services can display the certification mark demonstrating conformance and policy/procedure describing CAB(s)’s surveillance activities, including how often they occur. - Ecolabel program requirements for CABs to document how long products/services can display the certification mark demonstrating conformance and to periodically conduct surveillance of marked products. - Attestation (by the CAB(s) or ecolabel program) that the CAB(s) do not conduct market surveillance, and indication of the entity that addresses this activity.
III.1.19	B	Non-conformity procedure. In the event that non-conformity is substantiated, a procedure is established that considers and decides on appropriate action such as increased surveillance, reduction in the scope of the certification to remove non-conforming products/services, suspension of the certification or withdrawal of the certification. Note: Reflects ISO/IEC 17065 - 7.11.1	The evidence must include one of the following: - Publicly available procedure on appropriate actions or steps taken by CAB(s) in cases of non-conformity. - Ecolabel program requirements for CABs to have a procedure for actions or steps taken in cases of non-conformity. Procedure must be specific to the particular standard submitted for assessment, rather than general procedures for any standard.
III.1.20	B	Suitable action for misuse. Established procedures to control the use of their licenses, certificates, marks of conformity, and any other mechanisms for indicating a product/service is conformant. Procedures describe actions to take for incorrect, misleading or un-authorized use of its mark and licenses, including suspension or removal of the mark if warranted. This criterion is not applicable if the CAB does not address misuse of marks or licenses. (This is addressed for ecolabel programs in Section IV.) Note: Reflects ISO/IEC 17065 - 4.1.3.1, 7.11.1, 7.9.3 and 7.9.4	The evidence must include one of the following: - Policy / procedure for CAB(s) to take action on incorrect, misleading, or unauthorized use of their marks or licenses. - Attestation (by the CAB(s) or ecolabel program) that the CAB does not address misuse of marks or licenses, and indication of the entity that addresses this activity. - Ecolabel program requirements for CABs to have a policy/procedure to take action on incorrect, misleading, or unauthorized use of their marks or licenses.
III.1.21	B	Dispute resolution procedures. A documented and publicly available policy/procedure for receiving, evaluating, resolving, and documenting complaints and appeals is in place. This criterion is not applicable if the CAB does not address complaints and appeals. (This is addressed for ecolabel programs in Section IV.) Note: Reflects ISO/IEC 17065 - - 7.13.1	The evidence must include one of the following: - URL to webpage containing policy/procedure for complaints and appeals for CAB(s). - Attestation (by the CAB(s) or ecolabel program) that the CAB does not address complaints and appeals, and indication of the entity that addresses this activity. - Ecolabel program requirements for CABs to have a documented and publicly available policy/procedure for complaints and appeals.
Leadership Criteria - Encouraged to Complete
III.2	L	Neutrality. The standard, ecolabel and/or SDO are neutral as to the specific CAB entity being used; any accredited/ approved CAB can assess conformance to the standard. Reference: ISO/IEC 17007 Note: the revenue from conformity assessment is often necessary to offset the significant investment in standards development and, to address any issues (perceived or real) related to conflicts of interest, organizations should separate the management and operations of conformity assessment and standards development.	The evidence must include: - Documentation that any accredited/approved CAB can provide CA services to the standard.
III.3	L	Information on financial support. Public access to, or disclosure of, up-to-date information on the means by which they obtain financial support is provided. Note: Reflects ISO/IEC 17065 - 4.6	The evidence must include one of the following: - Example description of means of CAB(s) financial support and description of where and how this information can be accessed. - Ecolabel program requirements for CABs to provide public access to, or disclosure of, up-to-date information on the means by which they obtain financial support.
III.4	L	Fees. A sliding scale of conformity assessment fees or other means to be accessible to small businesses is offered.	The evidence must include one of the following: - Documentation of CAB(s)’s sliding fee scale for conformity assessment. - Demonstration of CAB(s)’s accessibility to small businesses for conformity assessment. - Ecolabel program requirements for CABs to offer a sliding scale of conformity assessment fees or other means to be accessible to small businesses.

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Sheet 7: 6. Section IV Criteria

Criteria and Evidence				Applicant Submission		EPA Assessment
Criterion #	B/L	Criterion	Source of Evidence and Key Decision Parameters	Applicant Response/Comment	File Name(s) and Section or Page Number	Completeness Check	Gaps or Clarifications	Y/N	Justification	Notes
SECTION IV: MANAGEMENT OF ECOLABELING PROGRAMS Applicants responsible for ongoing management of the ecolabel program should complete Section IV. It is not required to respond to this section. Where applicable, responses to this section are encouraged to inform potential federal users and other interested parties about the governance and implementation of the ecolabel.
Baseline Criteria
IV.1	B	Information on fees. The ecolabel program provides general information on fees, and makes this information available to those seeking to use the ecolabel.	The evidence must include one of the following: - URL to webpage that contains fee schedule information. - Process by which those seeking to use the ecolabel and other interested parties can request information on fees (from ecolabel program, CAB or both).
IV.2	B	Free from undue pressures. The ecolabel program does not allow commercial, financial or other pressures to compromise impartiality, including ensuring that personnel (management and staff) are free from such pressures.	The evidence must include: - Policy/procedure demonstrating that staff and management remain impartial in their decisions concerning the ecolabel program and are not subject to undue pressure. Policy/procedure must clearly describe risks and safeguards against them.
IV.3	B	Quality objectives. The ecolabel program has a documented commitment to fulfilling quality objectives and/or an established quality management system that is implemented in the organization. Note: A quality management system is a formalized system that documents the structure, responsibilities, and procedures required to achieve effective quality management (American Society for Quality Glossary, http://asq.org/glossary/q.html). An example of a standard for quality management systems is ISO 9000, see http://www.iso.org/iso/home/standards/management-standards/iso_9000.htm.	The evidence must include one of the following: - Policy/procedure indicating commitment to quality. - Quality management system documentation.
IV.4	B	Disclose governance. The ecolabel program makes publicly available the names and organizations of people who are involved in the ongoing governance and/or operations of the ecolabel program Note: For example, this may include board members, funders, and members of technical committees associated with the ecolabel program.	The evidence must include one of the following: - URL to webpage with names and organizations listed. - Description of availability of information on the people who are involved in the ongoing governance and/or operations.
IV.5	B	Grant the use of the mark. The ecolabel program grants the label, mark, or registration if the product/service is demonstrated to be in conformance with the applicable standard, and the organization seeking to use the label, mark, or registration meets the administrative and technical requirements of the program (such as paying fees and accepting license agreements). This criterion is not applicable if the ecolabel program does not grant the use of the mark. (This is addressed for CABs in Section III.)	The evidence must include all of the following: - Attestation that no other conditions or limits are placed on products/services or those seeking to use the ecolabel in granting the use of the mark beyond those required by the standard and/or administrative or technical requirements of the program. - Policy or procedure stating the conditions by which the label/mark/declaration will be granted and an explanation as to its purpose and why they are reasonable. OR Attestation that the ecolabel program does not grant the use of the mark, and indication of the entity that addresses this activity.
IV.6	B	Publicly available and current registry. The ecolabel program makes publicly available a registry of conformant products/services and their brand owner. The registry is up to date, and/or has been updated in the last 3 months. The registry can be searched so that users can find conforming products/services and suppliers. For tiered standards (e.g. gold, silver, bronze, etc.), the registry identifies levels achieved by products/services that conform to the standard.	The evidence must include all of the following: - URL to webpage that contains the registry in current use by the ecolabel program and/or CAB. - Demonstration that the registry was updated in the 3 months prior to assessment, which may include: date of last update to the registry or dates of when products/services are added to registry. - Explanation or demonstration of how the registry is able to be searched. The evidence must also include one of the following: - The registry must identify levels achieved by products/services. - Text of the standard showing that it is not a tiered standard.
IV.7	B	Period evaluation of marked products/services. When continuing use of a conformity assurance mark on a product/service is authorized, the ecolabel program periodically conducts surveillance of marked products/services to ensure ongoing validity of continued conformance. This criterion is not applicable if the ecolabel program does not conduct market surveillance. (This is addressed for CABs in Section III.)	The evidence must include all of the following: - Policy/procedures on how long products/services can display the certification mark demonstrating conformance. - Policy/procedure describing surveillance activities, including how often they occur. OR Attestation that the ecolabel program does not conduct market surveillance, and indication of the entity that addresses this activity.
IV.8	B	Suitable action for misuse. The ecolabel program has established procedures to control the use of its licenses, certificates, marks of conformity, and any other mechanisms for indicating a product/service meets the standard. Procedures describe actions to take for incorrect, misleading, or un-authorized use of its mark and licenses including suspension or removal of the mark if warranted. This criterion is not applicable if the ecolabel program does not address misuse of marks or licenses. (This is addressed for CABs in Section III.)	The evidence must include: - Policy/procedure to take action on incorrect, misleading, or unauthorized use of marks or licenses. OR Attestation that the ecolabel program does not address misuse of marks or licenses, and indication of the entity that addresses this activity.
IV.9	B	Dispute resolution procedures. The ecolabel program has a documented and publicly available policy/procedure for receiving, evaluating, resolving, and documenting complaints and appeals concerning the management of the ecolabel program.	The evidence must include: - URL to webpage containing policy/procedure for complaints and appeals.
Leadership Criteria - Encouraged to Complete
IV.10	L	Information on financial support. The ecolabel program provides public access to, or disclosure of, up-to-date information on significant funding received for administering the ecolabel program. Note: “Significant funding” is defined as more than $10,000 or its in-kind equivalent, or 20% or more of the anticipated funding needs for administering the ecolabel program.	The evidence must include all of the following: - Description of the types and sources of significant funding the ecolabel program relies on to support its work. - Description of where and how this information can be accessed.
IV.11	L	Mutual recognition. The ecolabel program participates in mutual recognition activities such as equivalency assessments; formal mutual recognition of standards; and/or technical, administrative, or CA procedures.	The evidence must include the following: - Documentation of public statement in which ecolabel programs and or standards are mutually recognized and on what grounds.
IV.12	L	Disclosure of credits achieved. The ecolabel program’s public registry of conformant products/services and their brand owner (as covered in IV.6) discloses the credits achieved by products/services that conform to the standard in cases where there are tiered results with optional credits. This criterion is not applicable to standards that are “pass/fail”.	The evidence must include one of the following: - The registry (as provided in IV.6) identifies the credits/criteria achieved by products/services that conform to the standard. - Text of the standard showing that there are no optional credits. OR Explanation of why this is not applicable to the standard.
IV.13	L	Regional information in registry. The ecolabel program’s public registry of conformant products/services and their brand owner (as covered in IV.6) provides information on the regions where these products are available (e.g., information on the location of suppliers; national or sub-national regions where products/services are available on the market).	The evidence must include one of the following: - The registry (as provided in IV.6) shows supplier addresses/location information. - The registry (as provided in IV.6) shows where products/services are available (e.g. country, state, other sub-national region).
IV.14	L	Additional Functionality of Registry. The ecolabel program’s public registry of conformant products/services (as covered in IV.6) is provided in such a way that certifications can be publicly accessed and is available for other databases directly through an application program interface (API) and/or a link that provides the documentation required to demonstrate conformance to the ecolabel.	The evidence must include: - A description of the technical infrastructure used to enable database accessibility.
IV.15	L	Ecolabel differentiation. If an ecolabel is associated with more than one standard/certification, those ecolabels are markedly different from each other in application as not to confuse the marketplace or inflate a sense of compliance.	The evidence must include: - Consumer testing to ensure ecolabels associated with more than one standard are clearly interpreted as to the differences.
IV.16	L	Evaluate effectiveness. The ecolabel program has established a methodology and procedure to evaluate the effectiveness of addressing environmental and/or human health impacts covered by its standard. The ecolabel program, or a third party, has completed an evaluation within the previous five years, and the evaluation is publicly available.	The evidence must include all of the following: - Procedure for completing the evaluation including a discussion of impact categories addressed, methods, data sources, indicators, and time line. - Description of the methodology selected, including any methodology standards or norms referenced such as impact evaluation or the ISEAL Impacts code (http://www.isealalliance.org/our-work/defining-credibility/codes-of-good-practice/impacts-code). - Completed report and publication date. - Description of data sources used. The evidence must also include one of the following: - URL to webpage that contains evaluation report - Attestation that report is available on request.
IV.17	L	Market uptake. The ecolabel program conducts or participates in periodic analyses and/or publishes the uptake of the ecolabel in the marketplace.	The evidence must include one of the following: - Example analysis of marketplace uptake of the ecolabel including market share, recognition in institutional procurement policies or frameworks, or other indicators of the ecolabel’s presence. - Example of market report published.
IV.18	L	Balance of interests. The ecolabel program has rules and procedures that aim to ensure a balance of interests among people who are involved in the ongoing governance and/or operations of the ecolabel program.	The evidence must include all of the following: - Definition of interest categories relevant to the ecolabel program. - Documentation of formal rules and procedures for ensuring balance of interest.

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Sheet 8: 7. Attestations

Under Section 1001 of title 18 of the United States Code, it is a federal crime to knowingly and willfully make a materially false, fictitious, or fraudulent statement in any matter within the jurisdiction of the executive, legislative, or judicial branch of the United States.
Section I Baseline Attestations
Section I Leadership Attestations
Section III Attestations
Section IV Attestations