Using the proper names to identify equipment is essential to R2 conformance and legal compliance. Electronics are not commodities – processing is required to recover the various materials that will ultimately be sold as commodities. For example, it would not be accurate to classify a refrigerator as “ferrous metal” -- it is a refrigerator until the freon, plastics, and insulation are removed. Although the process of recycling a refrigerator yields ferrous metal, classifying a refrigerator as ferrous metal does not take into account the special management needed for its other hazardous components. In the same way, a cable box should not be called “irony aluminum.” It is a cable box with a circuit board, and sometimes a battery or hard drive, until it has been processed to separate those components from the irony aluminum part.
Words and categorizations matter because they determine how material will ultimately be managed and processed. Electronic equipment and components contain “Focus Materials” that require special processing. Focus Materials must be removed so that the base materials are free of hazards and ready to use as feedstock. Classifying whole electronics or their components as “scrap plastic” or “scrap metal” would be wrong because it does not take into account the special management needed for the Focus Materials contained in the electronics.
Provision 7 of the R2 Standard requires tracking throughput of all material and components that pass through an R2 certified facility. Provisions 5 and 6 require special management of electronic equipment and components containing Focus Materials. Improper identification of equipment, components, and material impacts the recycler’s ability to accurately track and manage throughput onsite and throughout the recycling chain.
During an R2 audit, the auditor will look for the type of equipment received by the recycler by evaluating shipping and other records, evaluating the processes used by the recycler, and evaluating the outputs from processing. It is imperative for a facility to properly identify material so that the inputs and outputs are consistent with the type of equipment received and the processes used.
Bottom Line: The words that are used to identify materials and equipment matter. Inaccurately identifying or labeling electronic equipment will cause problems during the audit and also impact a facility’s ability to comply with legal requirements for management and/or shipment of equipment and materials – ultimately jeopardizing a company’s R2 certification.