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Export Regulations R2 Evolution

R2:2013—the next generation of the R2 standard—raises the bar for electronics recyclers’ quality, environmental, and health and safety practices.
By John Lingelbach
In 2006, the U.S. Environmental Protection Agency (Washington, D.C.) convened a group of stakeholders to create a set of best practices that certifying bodies could use to assess electronics recyclers’ environmental and health and safety efforts.

Over a three-year period, the group of representatives from government regulatory agencies, original equipment manufacturers, electronics recyclers and refurbishers, trade associations (including ISRI), and nongovernmental organizations developed the Responsible Recycling (R2) Practices for Use in Accredited Certification Programs for Electronics Recyclers. In 2009, the ANSI-ASQ National Accreditation Board (Milwaukee) developed Accreditation Rule 34, which gave certification bodies—the entities that conduct audits and issue certifications—the ability to become accredited to certify electronics recyclers to the R2 standard. In 2010, the founding group established the nonprofit R2 Solutions (Boulder, Colo.) to administer and promote the standard. Since the standard’s debut, more than 275 companies around the world have achieved R2 certification.
R2 was never intended to be a static set of practices, so R2 Solutions convened another multi-stakeholder group, the R2 Technical Advisory Committee, in 2011 to improve the standard based on input from its members as well as public comments. The result is a next-generation version of the standard, R2:2013, which reinforces and builds on the foundation of the previous R2 certification program. R2 Solutions expects R2:2013 to strengthen the overall program by providing an even greater and more explicit emphasis on quality and raising the bar for several key R2 requirements. We have created the following Q&A to explain how and why the updated standard came about and describe the main differences between the old and new versions.
Why did R2 need to be revised? The multi-stakeholder group that created the original R2 standard—now called R2:2008—agreed it should be updated after three to five years based on lessons learned through real-life implementation and changes in industry practices and technologies. Also, since R2’s launch in 2008, various stakeholders have offered comments and suggestions on ways to improve the standard and make it even stronger.

How did the updating process work? The R2 Technical Advisory Committee recommended the updates after a thorough evaluation of the R2:2008 standard. Participants in the TAC deliberations included representatives from Best Buy, Dell, Microsoft, UPS, the U.S. General Services Administration, and some of the most progressive electronics recyclers and refurbishers in the industry. These entities had a strong interest in developing the most rigorous standard for the electronics recycling industry. The TAC also had nonvoting members who represented the certification bodies, auditors, and consultants. I also think it’s important to note the group was proactive about inviting public comments on the standard and suggestions for how to improve it.        

What are the main differences between R2:2013 and R2:2008? The R2 standard consists of 13 provisions. The most significant change is in Provision 1, the requirement for all R2 facilities to have an environmental and health and safety management system. Under R2:2008, a company could develop its EHS management system in accordance with a set of comprehensive but general R2 requirements. R2:2013 requires either a combination of ISO 14001, which covers environmental management, and OHSAS 18001, which focuses on health and safety management, or ISRI’s Recycling Industry Operating Standard™, which encompasses elements found in ISO 14001, OHSAS 18001, and ISO 9001 (which covers quality management). This more rigorous management system requirement substantially improves the integrity and accountability of the entire R2 certification.
Additional significant changes in R2:2013 include the following:

  • It tightens the requirements on exports, mandating compliance with the export and import laws of all exporting, importing, and in-transit countries, regardless of whether or not they are members of the Organization for Economic Cooperation and Development (Paris).
  • It clarifies existing downstream due-diligence requirements to improve the tracking of equipment containing so-called focus materials—those that could be hazardous to human health and the environment if not managed properly—through each downstream vendor until the materials are sold for reuse or as a commodity.
  • Also, it takes a comprehensive approach to data security and destruction, ensuring the security of all media until they are sanitized or destroyed.
  • When did the R2:2013 revisions take effect?

    The new standard’s effective date was July 1. A facility seeking a new R2 certification can get certified to the new standard as soon as its certification body is qualified to issue R2:2013 certifications.

    How do the changes affect R2:2008 certification holders?

    Facilities certified to R2:2008 must meet all the new provisions of R2:2013 by Dec. 31, 2014.

    What are the key differences between R2:2013 and other certification programs?

    R2:2013 differentiates itself from other certifications in numerous important ways:

  • It is the only certification developed through a transparent process by a multi-stakeholder group and with open public input.

  • It can be achieved by recyclers and refurbishers around the world—those in developed countries as well as those in emerging markets.

  • It requires applicants to have a certified environmental and health and safety management system.

  • It strongly encourages extending the life of electronics equipment through refurbishment and reuse.

  • It has comprehensive requirements regarding exports that allow socially conscious and environmentally responsible importing and exporting. These stricter requirements allow highly responsible international partnerships without hindering trade.

  • It requires recyclers to track all focus materials through each downstream vendor until they are sold for reuse as a fully functioning piece of equipment or as a commodity-grade material. The standard also prohibits the disposal of focus materials in municipal landfills and incinerators.

  • It has a strong focus on eliminating risk regarding data security, requiring complete data erasure or destruction to protect sensitive information. The new requirements mandate stricter training and credentials for employees handling data destruction as well as secure storage and tracking prior to destruction. All of these procedures must be audited.

  • It requires companies that recycle electronics using prison labor to ensure that the workers operate at the same high occupational standards for health and safety as non-incarcerated workers.

  • It does not require applicants to provide proprietary business information to earn or maintain certification.

  • It does not require recyclers to use specific technologies or practices but rather sets performance standards and then encourages innovation and improvement.

  • It has a reasonable initial implementation fee to meet the standard’s requirements, with ongoing maintenance fees.

  • The independent, nonprofit R2 Solutions administers the certification with the sole objective to promote environmentally and socially responsible electronics recycling worldwide.

  • What is the anticipated long-term effect of R2:2013?

    The overarching goal of R2:2013 is to help electronics recyclers and refurbishers optimize their systems and practices and, by certifying to its requirements, assure their upstream clients that they are fully addressing potential risks to the clients’ brands and protecting them from potential legal and/or financial liability.

    John Lingelbach is executive director of R2 Solutions (Boulder, Colo.). For more information about the R2:2013 standard, visit www.r2solutions.org. This article originally appeared in the Jul/Aug 2013 issue of Scrap magazine (www.scrap.org). Reprinted with permission.

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