GEC released its DRAFT EPEAT Criteria for its Photovoltaic Modules and Inverters (PVMI) Full Criteria Revision on November 18, 2025. The public comment period — open for 60 days — is an opportunity for all interested stakeholders to provide technical comments on the draft criteria revision. These criteria are intended to address the life cycle sustainability impacts identified in the State of Sustainability Research for Photovoltaic Modules and Inverters (PVMI) and to recognize the leaders in sustainability performance.
EPEAT registered PVMI products are required to meet applicable criteria in 2 documents: GEC-PVMI-202X (the former NSF-457 standard) and Criteria for the Assessment of Ultra-Low Carbon Solar Modules (ULCS).
Prioritized updates for the full revision of the EPEAT PVMI criteria in GEC-PVMI-202X (former NSF-457 include, but are not limited to:
- Enhanced circularity criteria for responsible end-of-life and durable product design
- Enhanced corporate responsibility criteria for supply chain tracing to confirm facilities are not in regions where independent third-party audits cannot be performed as part of a credible forced labor due diligence process in alignment with the United Nations Guiding Principles on Business and Human Rights (UNGPs).
Prioritized updates for the EPEAT PVMI criteria in the Ultra-Low Carbon Solar Modules (ULCS) document (published in March 2023) include formal Technical Committee adoption of Interim Corrections approved by a balanced voluntary consensus Interim Corrections Committee in December 2024. These corrections are intended to facilitate effective and efficient implementation and conformity assurance. Given the relative newness of this document, GEC is not proposing to change the methodological approach at this time.
NSF International manages the public comment process on behalf of GEC. Comments must be submitted by 11:59 pm ET on January 18, 2026 using the NSF Online Workspace, available here:
- PVMI for Public Comment
- ULCS for Public Comment
- NSF Public Workspace Link (can sort by “Groups”)
Please submit comments for each document separately. Instructions on submitting comments are provided on the NSF Online Workspace. To support openness and transparency, the NSF website displays all public comments and their resolution.
Please contact Cassandra Leone (cleone@nsf.org), NSF Sustainability Standards Secretariat, for assistance with the comment submittal process.
Please contact Criteria@gec.org with questions regarding the technical content of the criteria.
