Many R2 certified companies – and their customers – do not fully understand the significance of the scope statement on an R2 certificate. It is the scope statement that tells customers exactly what services and activities taking place at a facility have been fully audited and conform to R2 requirements.
The first thing to note is that the scope statement on an R2 certificate must fall within the scope of the R2 Standard. The R2 Standard establishes responsible recycling (“R2”) practices for the recycling of electronic equipment and components that are designed primarily to store or convey information electronically, and any accessories to such equipment. For example: computers and peripheral equipment, printers, scanners, copiers, fax machines, storage devices, servers, networking systems, mobile devices, telephones, televisions, DVD recorders, camcorders, digital cameras, and game systems and accessories.
Non-R2 related activities cannot be included in an R2 scope statement. If an R2 certified facility engages in activities that are outside the scope of the R2 Standard, such as a recycling center that accepts computers, but also accepts appliances, the non-R2 related activities must not be included in the R2 Scope statement. For example:
Unacceptable R2 Scope: “The repair and recycling of electronic computers and appliances.” (This wrongly implies that activities relating to repair and recycling of appliances have been audited and meet R2 requirements)
Acceptable R2 Scope: “The repair and recycling of used and end-of life computer equipment.”
Other examples of unacceptable R2 scope statements:
- “Reuse and recycling of end-of-life (EOL) electronic equipment, metals, and plastics.”
(Metals and plastics must not be included because they fall outside the scope of R2 activities.)
- “Collection, and Consolidation and Shipping of Precious Metal Scrap and Copper Scrap”
(Scrap metals must not be included because they fall outside the scope of R2 activities.)
- “Dismantling, Data Destruction, Testing, Repair, and Resale of New and Used Mobile Phones”
(New equipment must not be included because it is outside the R2 scope of “used and end-of-life equipment.” The reference to new equipment in Provision 6(e) affirms this by specifically excluding new equipment from the resale requirements of Provision 6.)
All activities related to electronics refurbishing/reselling/recycling occurring at a facility must be included in the R2 scope statement. The R2 scope will not always mirror the company’s scope for RIOS, ISO 14001 or OHSAS 18001. Activities related to electronics recycling may be only a small portion of the company’s total business operations. So, the scope statement included on the company’s RIOS, ISO 14001 or OHSAS 18001 certificate(s) may include additional activities not included on their R2 certificate.
The scope statement must be consistent with any Allowances (as defined in the R2 Code of Practices) that are stated on the R2 certificate. For instance, a facility with a Broker Allowance listed on its R2 certificate must not have a scope statement that includes “shredding of printed circuit boards.” (Shredding circuit boards is incompatible with the Broker Allowance, which applies only to companies that do not physically handle equipment or materials and have no physical storage or processing at their location.)
Another example of incompatible scope and allowance – A battery recycling facility with a Focus Material Processor Allowance must not have a scope statement that says, “the recycling of batteries, computers and printers.” (“Recycling batteries” is acceptable, but including “computers and printers” is incompatible with the Focus Material Processor Allowance, which applies to organizations that only provide specific processing of a Focus Material in the recycling chain (such as batteries) but does not provide full recycling or refurbishment of electronics (that may contain batteries.)
An unacceptable scope statement will delay a company’s listing on the SERI website directory of R2 certified recyclers. Certificates with unacceptable scope statements must be sent back to the certifying body for revision before they can be accepted by SERI and posted on the website. (Prior to accepting a new candidate for R2 certification, a certifying body must ensure that the candidate’s scope of business and activities can reasonably be audited for conformance to the R2 Standard.)
Things to remember when evaluating an R2 certified company as a potential downstream vendor:
- Make sure the services and activities they are performing for you match the scope statement on their R2 certificate. For example, an R2 certified refurbisher with a certificate that lists the scope of activities as: “the sorting, repair, and dismantling of computers and cell phones” is not certified as a processor of CRT monitors or batteries.
- Don’t assume all R2 certified locations within the same company have the same scope statement. Each facility may offer different products and services – which means the scope will be different for each facility.