By Patty Osterberg, Director of Education & Outreach
How can a R2 company – and their downstream vendors – obtain the required documentation and comply with Provision 3(a)2 of R2:2013? Below are some steps that can help.
- Identify each type of equipment or material being exported, including exports by downstream venders to determine which contain FMs – almost all will except for shipments of only plastic or metal. (This is an element of the FM management plan required in Provision 5.)
- Identify the legal requirements of the recipient country and any transit countries through which material may pass through. Helpful resources for identifying legal requirements:
- Obtain the legal documentation that R2:2013 requires you to verify and maintain from each downstream vendor that exports FMs. A few examples of acceptable documentation:
- An approval letter from the importing country’s Competent Authority.
- A copy of or link to the importing or transit country’s law that states the material you, or your downstream vendor, are sending is legally permitted to enter the country.
- A license or permit issued to a downstream vendor by the recipient country that states the equipment or material actually contained in the shipment (we have seen instances of falsified manifests) can be imported for reuse or materials recovery.
- Make sure that you and your downstream vendors have procedures in place for regularly updating legal requirements as the types of materials shipped, and laws, can change.