When evaluating for reuse, are Appendix C and QMS required?

Q.    Is certification to Appendix C – Test & Repair required for the evaluation process under Core 6.(c) when determining capability of reuse? And, is a certified Quality Management System (QMS) required for those facilities that only evaluate items for reuse?

If an R2 Facility only ‘evaluates’ equipment or components to determine the capability for reuse, then certification to Appendix C is not required nor is the certified QMS. However, equipment and components that are determined to be capable of reuse must be directed to one of the approved reuse options as identified under Core Requirement 6.(d)(4) or Core 6.(e)(3).

Evaluating for reuse can include a variety of activities such as simple power-on verifications, visual inspections and even some basic level testing.  However, these evaluations are not considered part of the functionality testing under Appendix C or the verifications under Appendix D.

Products that are sold for reuse must meet the criteria of one of the Functioning Product Categories in the REC (Table 4).  Assignment of any F3 through F6 Functioning Product Categories requires that the device be tested and verified functioning through Appendix C.

For more detail on which operations the R2v3 Process Requirements apply to, consult the R2v3 Appendix Applicability Guidance.

Q.   What are some examples of activities that are considered ‘repair’ and would require certification to Appendix C – Test & Repair?

Repair operations generally involve the fixing or replacing of parts to produce a functioning product or part. This can include a wide variety of operations from the replacement of hard drives, memory or embedded batteries, all the way to specialized board level repairs.

Activities that are generally not considered repair would include the replacement of consumables or other user-replaceable items.