By Patty Osterberg, Director of Education & Outreach
Ensuring the legality of exports is a fundamental principle of the R2 Standard – as is promoting responsible reuse of electronics around the world, including in developing countries. This article describes how each of these principles plays out in R2:2013, how they are interrelated, and why they make the R2 Standard the choice of so many discerning customers of electronics recyclers.
R2:2013 and Exports
Provision 3(a)2 requires that “Prior to shipment [of Focus Materials (FMs) that have passed through a certified recycler’s facility or control], the recycler shall identify the countries that are receiving or transferring such shipments, obtain documentation demonstrating that each such country legally accepts such shipments, and demonstrate compliance of each shipment with the applicable export and import laws.”
This requirement applies to all FMs, including FMs still in any piece of equipment or component that has not been tested to verify that, at a minimum, all key functions are working properly (see Provision 6(c) and (e) regarding reusable equipment and components).
The R2:2013 language set forth above is clear that documentation showing legality is required prior to each shipment that contains FMs, unless the entire shipment is equipment that has been tested and key functions are working. This requirement applies to the certified recycler, all of its downstream vendors, and all of their downstream vendors, etc. The certified recycler must have this documentation available for its auditor (see Provision 13) regardless of whether the recycler or a downstream vendor made the shipment. For some suggested steps that can help companies comply with Provision 3(a)2) click here.
Emphasis on Reuse in R2:2013
It is widely agreed that extending the life of reusable products is the most environmentally beneficial option for electronics. Responsible reuse also has significant positive social and economic impacts, especially in developing countries. Reuse allows such countries to more quickly bridge the digital divide, improve education, and participate in a global economy. Making affordable, reusable equipment available to a wider array of consumers, where it is legal and can be responsibly managed at end of life, is undeniably a good thing.
Additionally, responsible reuse reduces the need to mine raw materials for manufacturing and reduces the carbon footprint of manufacturing. From an environmental perspective, when reused electronics are responsibly managed at end of life, reuse is the most environmentally sustainable option. For these reasons, R2:2013 strongly promotes reuse as the best approach to managing used electronics (see Provision 2).
While the social, economic, and environmental benefits of reuse are clear, the R2 Technical Advisory Committee recognized the challenges that promoting reuse presents. One of which is stopping the flow of illegal shipments that are exported under the guise of “reuse.” Although they represent a small minority, too many recyclers are willing to illegally mislabel shipments of electronic junk as “reusable” in order to get the shipment through customs.
To combat this behavior, SERI is requiring all R2 auditors to undergo new training that focuses on ways of identifying such shipments. Furthermore, SERI is conducting more of its own international spot audits, in conjunction with its domestic spot audits, to identify such shipments and the recyclers that ship and receive them. There is no place for such recyclers in the R2 certification program.
A second critical challenge, particularly in developing countries, is establishing the responsible management of reused electronics once they reach the end of their useful life. In many such countries, the problem is no longer so much about managing electronic junk from richer nations as it is about responsibly managing end-of-life electronics generated within their country.
As part of its mission, SERI is conferring with NGOs and recyclers in places such as India and South America about the ways in which SERI can assist with education and capacity building to increase responsible recycling in these areas of the world. SERI, the R2 Leaders, and a number of R2-certified companies are helping make safe and sustainable electronics repair and recycling more accessible worldwide.
Of course much more needs to be done. SERI and other like-minded organizations and companies are working to play our part. It’s not just about exports anymore, it’s time to focus on increasing capacity for safe and sustainable electronics recycling in all parts of the world.