Transparency vs. Downstream Vendor Qualifications — Avoid this common mistake

A common area of misunderstanding about downstream vendor requirements has to do with two very important – but different – aspects of Appendix A:  Transparency vs. Downstream Vendor Qualifications.  The requirements for both downstream vendor qualifications and transparency must be satisfied.  A common mistake is qualifying downstream vendors but not completing the transparency requirements.

Transparency

Transparency is about tracking and demonstrating the complete recycling chain to final disposition or to the first R2v3 facility.  This requirement is found in Appendix A (4):

An R2 Facility shall:

(a) Track and demonstrate the complete downstream recycling chain of all R2 Controlled Streams to final disposition, OR

(b) Register with SERI, the portion of the downstream recycling chain that it manages, including all R2 Controlled Streams to final disposition or the first R2 Facility, to enable mapping of the entire chain, and register any changes prior to shipment.

A common mistake that facilities make when they stop tracking at the first R2 facility is failing to Register their downstream recycling chain with SERI.

The process to register the downstream recycling chain is completing a simple form and uploading your Downstream Vendor Flowchart.   The flowchart must show each R2 Controlled material stream leaving your facility and the entire downstream chain for each materials stream – or until the first R2v3 Certified facility in a particular downstream chain.  The name and location of each downstream vendor on the flowchart should also be included.  View Sample Downstream Vendor Flowchart and Instructions.

To complete the Downstream Recycling Registration Form and upload your flowchart, you will need to have your facility’s Account Key, which is included on your SERI License Acknowledgement and on your License invoice.   Each time your downstream recycling chain changes, you will need to update your Downstream Recycling Flow Chart,  complete a new Downstream Recycling Registration Form and upload the updated flowchart.    If you need help obtaining your Account Key, please email Licensing@SustainableElectronics.org  and include your facility’s name and address.

Downstream Vendor Qualifications

Qualifying your downstream vendors is about performing due diligence on both R2v3 and Non-R2v3 to determine whether they are qualified to process the R2 Controlled material stream(s) you are sending to them.

• The qualifications for an R2v3 Certified downstream vendor are found in Appendix A(7).  The verification process for R2v3 downstream vendors is streamlined since they have already been through the scrutiny of the R2 audit and certification process.
• The qualifications for a Non-R2v3 downstream vendor are found in Appendix A(8) and are much more comprehensive since the Non-R2v3 facility has not gone through the scrutiny of the R2 audit and certification process.

Important to Remember…

Using R2v3 Certified facilities can streamline the requirements for qualifying downstream vendors and for tracking the downstream recycling chain.  However, when facilities choose to stop tracking at the first R2v3 Certified facility, they must be sure to REGISTER THEIR DOWNSTREAM recycling chain with SERI.