SERI has been reviewing the R2 certification process and has identified some key areas that will benefit from increased standardization and uniformity:  (1) the documentation provided by recyclers to auditors during audits, (2) auditing procedures employed by auditors, and (3) auditors' reports to their Certification Bodies.  SERI will work with the R2 Certification Bodies on this effort, which will improve quality and create a more level playing field for recyclers getting certified.

The R2 Standard sets forth the documentation required from a recycler undergoing an audit.  However, neither the Standard nor the R2 Guidance provides a single, comprehensive list explaining all the necessary content of the required documentation.  SERI is considering ways of providing more detailed direction to recyclers - possibly by providing templates or even software in which to enter the required information.  Such standardization at the front end of the auditing process will better enable increased standardization throughout the auditing process. 

Building on this, the auditing procedures that each auditor employs can be further standardized so that all auditors are asking for and reviewing the same core documentation and information (of course recognizing that no two facilities are exactly alike).  Finally, some additional standardization of auditor reports will help provide Certification Bodies with all the critical information needed to consistently make fully-informed certification decisions.

One of the strengths of the R2 Certification is that it allows opportunities for reusing electronic devices and components.  That said, the R2 Standard has very strict requirements and limitations governing the sale of untested and non-working equipment and components.  These ensure that all electronics are responsibly managed by a qualified refurbisher with the ability to safely repair or recycle the electronic devices or components they receive. 

Provision 6 states that R2 Certified companies may not sell untested or non-working used electronics (including non-working electronics sold for parts) without first "qualifying" the buyer.    Sales over the internet are generally not acceptable because these anonymous buyer transactions typically do not include qualifying the buyer.

Under Provision 6(c)(3), R2 Certified companies are permitted to partner with qualified refurbishers that have the expertise necessary to test and repair specific types of equipment.  This is particularly helpful when testing "specialty" electronics such as UPS units or medical equipment.   Such downstream vendors must demonstrate their conformance to the 6(c)(3) requirements prior to an R2 company sending them electronics for testing or repair.  Qualifying a downstream vendor that is R2 certified is less involved, although non-certified refurbishers may be used if they meet all the 6(c)(3) requirements.   Provision 6(c)(3) holds downstream vendors that receive untested and/or non-working used electronics or parts to the same rigor that is required of R2 Certified companies.  

A downstream refurbisher that is not R2 certified must qualify to meet two requirements:

1. They must be able to test and repair equipment or components to meet the criteria for R2/Ready for Reuse (6(c)(1)), or R2/Ready for Resale (6(c)(2)).  This includes establishing detailed records that show the devices or individual parts have passed functionality testing.  Untested or non-functioning used electronics may not be resold to another downstream refurbisher.
    
2. They must recycle unsold, non-tested, and/or non-functioning equipment in conformance with Provision 5(e). 

Bottom Line:  Used electronics must be controlled until each unit or component can be qualified as R2/Ready for Reuse, R2/Ready for Resale, or if they are Specialty or Collectible electronics, meet the requirements outlined in Provision 6(d).  

Q.   We are trying to gather the names and locations of all the downstream vendors in the recycling chain that handles our Focus Materials, but are having trouble obtaining this information from one of our downstream vendors.  Any suggestions for us?

A.   If a company is absolutely unwilling to provide downstream names and locations, unfortunately you will need to find a new downstream vendor.  Sometimes when companies realize that they will be losing your business, they will work with you to provide the information you need.    

If your prospective downstream vendor is R2 certified, they are required under Provision 7  (Tracking Throughput) to provide the names and locations of all downstream vendors in the recycling chain­­ to other R2 certified companies or candidates for the purpose of conducting due diligence.  It is permissible for them to require non-disclosure agreements. 

Occasionally conflicts arise when a company requests more information than what is required by the R2 Standard.  Ensure that your conflict is regarding the specific information required by the Standard.  If that is the case, and your downstream vendor will not provide the names and locations of downstream vendors that manage your focus materials, you can file a non-conformance complaint with their Certifying Body. 

Excerpt from R2:2013 Provision 7(b):

An R2:2013 electronics recycler shall provide, to each customer that is R2 certified or in the process of R2:2013 certification, upon request and with appropriate intellectual property and commercial controls as legally appropriate and required by the discloser, the names and locations of all downstream vendors in the recycling chain that handle said customer's FMs.

Excerpt from the Guidance Document:

R2 recyclers may take appropriate steps to protect their confidential business information, such as requiring auditors, CB's and customers to sign Non-disclosure Agreements prior to reviewing Provision 7.