The R2 Technical Advisory Committee (TAC) has been regularly meeting via conference call to consider possible revisions to the R2 Standard. The TAC is comprised of representatives from regulatory and public interest entities, recyclers/refurbishers, corporate users of electronics recycling services, and technical advisors with broad-ranging expertise in the industry who share SERI’s vision for safe and sustainable electronics reuse and recycling. The first draft of the revision is currently planned for late 2017, with the release of the final version in 2018, and full implementation by 2020.
The TAC held an in-person kick-off meeting in February 2016 which was open to the public. Attendees discussed mercury in LCDs, CRT Glass, closure plans and financial assurance, and developed a preliminary list of these and other issues for consideration during the R2 Standard revision process. An important element of the review and revision process is input from the public, electronics manufacturers, regulators, NGOs, the recycling community and others who share our goal of safe and sustainable electronics reuse and recycling. Comments and suggestions from the public will be welcomed by the TAC throughout the process. The public will also be invited to review the future draft(s) and provide comments.
Some of the questions and topics that have been or are being considered -
Are collection sites within the scope of the R2 Certified facility? After considering many viewpoints and variables regarding this question, the TAC decided that a Formal Interpretation of Provision 5.a was necessary to clarify the meaning of “control” as it is used in Provision 5. The 5.a Formal Interpretation has been ratified by the R2 Consensus Body and is currently under consideration by the R2 Board of Directors for final approval.
Eligibility for Certification - Should the Broker Allowance (as defined in the R2 Code of Practices) continue, and should R2 certification should be facility based or company based? Should the R2 Standard be divided into sub-categories with endorsements for specific types of activities, such as refurbishment?
Reuse/Recover Hierarchy of Provision 2 - Discussion of CRT management options such as beneficial use, alternative daily cover, and retrievable storage cells. Also under consideration is creating another level of hierarchy for “beneficial use.”
In response to a formal interpretation request, the definitions of recycling and viability were re-examined. After discussion, the R2 Consensus Body decided that the information currently provided on viability is clear. The TAC will continue to consider the definition of recycling and determine whether changes or clarifications should be included in the next version of the R2 Standard.
Should the scope of the R2 Standard be expanded to include white goods (large appliances) and small appliances? This type of equipment is currently not included in the Standard’s definition of “electronic equipment,” which is limited to information and communication technology (ICT).
Should R2 requirements for Focus Materials be applied to all categories of used electronics?
Additionally, Small workgroups of TAC members have been formed to work on specific questions and potential proposed changes to Provisions 5, 6, 7, and 11. These workgroups are discussing in detail ways to clarify and strengthen each provision, and will make recommendations to the full TAC for further review. Small workgroups currently in place:
Provision 5 workgroup is considering recommendations to improve and strengthen the FM Management Plan requirements, as well strengthen downstream due diligence, communication, and transparency.
The Provision 6 workgroup is currently discussing ways to clarify and improve the language of the requirements to test and repair equipment for reuse.
Provision 7 workgroup is exploring ways to strengthen and improve the transparency of tracking throughput. Another topic under consideration is a time limit for processing and shipping received equipment and materials.
Provision 11 workgroup was tasked with clarifying and/or strengthening closure plans and financial instruments. The workgroup recommended changes to the R2 Guidance Document regarding the parameters by which pollution liability insurance could be effective as financial instrument for unplanned closures; and further guidance regarding assets used for financial assurance, and corporate guarantees. The workgroup also made recommendations about how to ensure closure plans are communicated to the proper people/entities in an abandonment situation.
Throughout 2017, the full TAC will continue to focus on big picture questions with far-reaching potential impacts, and also consider the recommendations of each small workgroup. The next in-person TAC meeting is scheduled for February 22-23 in Orlando, Florida. Please contact SERI (sharada@sustainableelectronics.org) if you would like to attend and observe this meeting. The public is also encouraged to contact TAC members or SERI with suggestions for improving, clarifying or strengthening the R2 Standard. Suggestions may be submitted via the SERI website https://sustainableelectronics.org/r2-standard/standards-development. On the Standards Development web page, you will also find the list of TAC members if you would like to contact them directly.
TAC Members have volunteered their valuable time and expertise for the purpose of strengthening and improving the R2 Standard. The issues are difficult and complex. We want to thank each of them for their participation, and for their willingness to consider different viewpoints and discuss the complexities of each. Reaching consensus is often long and difficult, but the resulting benefit is a final product that is thoroughly vetted and agreeable to the broad community of stakeholders.