We’ve compiled some of the key issues, most commonly asked questions, and opportunities for improvement observed during SERI spot audits. Does your team have a complete understanding of what’s required regarding the following issues to maintain conformance to the R2 Standard?
- Focus Materials – Virtually all electronic devices that are not tested or not working are considered Focus Materials because virtually all contain one or more of the five Focus Materials (PCBs, mercury, CRT glass, batteries, whole or shredded circuit boards) listed in the R2 Standard. Examples of equipment containing Focus Materials include desktops, laptops, servers, network equipment, Uninterruptible Power Supplies (UPS), AC adapters, computer mice, thumb drives, barcode scanners, cell phones, TVs, VCR and DVD players, CD-ROM Drives, Floppy Drives, external batteries, etc.
- Provision 3.a.2 – You are responsible for demonstrating the legality of any export of Focus Material exported by you or any company below you in the recycling chain. For resources to assist you in determining import/export restrictions, visit the References & Resources page of the SERI website.
- Provision 5.e – SERI/R2 does not select or approve downstream vendors. The R2 Standard establishes minimum requirements and it us up to each R2 certified company to decide who to work with. Evaluating a completed downstream vendor questionnaire is a good first step in determining if the vendor meets Provision 5.e requirements. You must also provide evidence that supports your determination – a completed questionnaire in and of itself is not sufficient evidence. You should be evaluating your downstream vendors in much the same manner your certification body auditor is evaluating you, and producing an audit report of your findings.
- Provision 5.g – You are responsible for demonstrating that your R2 Certified downstream vendors are conforming to your FM management plan. This means knowing their capabilities, and knowing what your vendors, at each tier in the recycling chain, are doing with the material they receive (directly or indirectly) from you.
- Provision 5.e.6 – You must know the destination of all Focus Materials that go through your facility, throughout the entire downstream recycling chain – including material going to R2 Certified downstream vendors. It is important to note that R2 certified companies are only required to disclose downstream information for the types of Focus Materials you send them. If a vendor will not provide this information (i.e. company name and address), you cannot use that vendor. If R2 certified companies refuse to disclose this information, you may file a complaint with their certification body.
- Provision 7.b – As an R2 certified company, you must disclose to your R2 certified upstream suppliers (or those in the process of becoming R2 certified), the names and locations of each downstream vendor that handles the Focus Materials that the R2 supplier sends you. Not complying with this requirement is a non-conformance that could threaten your R2 certification.
For more information on issues relating to Focus Materials, refer to the Implementation Guide and the Intermediate Training Module for Provision 5.
TESTING AND REUSE
- Provision 6.c.2.B – To sell a product as a working device, you must test for every key function and maintain a record of the test results. This is not a list of technical specs such as CPU speed, screen size, or RAM, but a “pass/fail” test for each key function. Without legitimate records of testing results, you cannot label a product as working. For more information about key function testing refer to the Implementation Guide for Provision 6.
- Provision 6.c.3.B.ii – If you are sending ready to repair electronic equipment to a downstream refurbisher who is not R2 Certified, they must test/repair the equipment and resell it for reuse, or they must recycle equipment they cannot repair. They are not permitted to resell non-working equipment to another refurbisher.
- Provision 6 – you cannot sell “As-Is” or “For Parts Only” electronics to anyone.
- Provision 6.c.3.C – you cannot co-mingle reusable equipment with old, damaged, or non-useable equipment for a “take all” sale.
For more information about testing and reuse, refer to the Implementation Guide and the Intermediate Training Module for Provision 6.
OTHER REQUIREMENTS TO NOTE
- Provision 8.h – You are responsible for all data destruction. If you use a subcontractor to wipe or physically destroy data for you, you still bear the responsibility to ensure and prove it is properly destroyed. For more information about data destruction, refer to the Implementation Guide and the Intermediate Training Module for Provision 8.
- Provision 11.a – You are required to have pollution liability insurance– unless an environmental risk assessment conducted by a qualified environmental professional determines that pollution insurance in not needed for your facility. More information is available in the April 2015 R2 Update newsletter.