A common misconception among recyclers and refurbishers is that new facilities can be R2 certified from day one. The R2 Code of Practices requires candidates for certification to have at least three months of records in order to move past the Stage 1 audit. Furthermore, for a facility to be recommended for R2 certification, the auditor must review and document evidence that the company is operating in conformance with all 13 provisions of the R2 Standard. A company cannot be R2 Certified based on a “planned” process that is not currently implemented.
A common question is whether a facility can be R2 certified if it has not yet accumulated enough material to ship, but has completed the due diligence requirements of Provision 5. The answer is no. Shipping records are required in order to meet the tracking throughput requirements of Provision 7.
Also important to note: a company cannot be considered a downstream vendor without evidence of a shipment to that vendor. The downstream vendor requirements under Provision 5.e require “shipments.” If shipments of Focus Materials (FM) have not yet been made, you will not have objective evidence to show an auditor that you are conforming to the requirements of Provision 5. Due diligence, followed by an actual shipment to the downstream vendor, are both necessary to fulfill Provision 5.e requirements.
In some instances, the question is not whether the recycler has made any shipments of FMs, but whether they must make shipments of each type of FM. In order to meet the tracking requirements for Provision 7, an auditor will need to see evidence that the company is in full operation with sufficient records to substantiate the flow of the various types of equipment and materials that would typically pass through the recycler’s facility. This also includes tracking of reusable products under Provision 6. A recycler does not need to show material flow for materials they do not receive. For example, a refurbisher who only sources mobile devices would not likely receive or ship CRT Glass, but would be expected to ship working mobile devices, mobile devices that need to be recycled, and batteries. The mix of FMs will vary from facility to facility, and the auditors will need to determine if sufficient evidence is available to substantiate conformance to Provision 5.e and 7.a.
Bottom Line: Written policies and procedures are not considered evidence of conforming to most R2 requirements. An auditor will need to see records that demonstrate those policies and procedures are implemented and adhered to. Without such records, a facility is not ready for R2 Certification and must wait until material is processed and shipped, and sufficient evidence is generated to show the facility is conforming to all 13 provisions of the R2 Standard.