Q. We fully vet our tier 1 downstream vendors according to the requirements in Provision 5e. However, if our tier 1 vendors send our material out for further processing, what kind of due diligence do we have to do on tier 2, 3, and 4 downstream vendors?
A. The R2 Standard does not require that you personally vet every vendor throughout the entire focus material recycling chain, but it does require that you verify that all facilities throughout the recycling chain are conforming to the due diligence requirements of Provision 5.e.
As part of your due diligence for your tier 1 downstream vendors, you are required to verify that they are holding their downstream vendors to the 5.e requirements – and that they can demonstrate that each subsequent downstream vendor in the recycling chain is doing the same (see Provision 5.e.4 ).
Section 5.15 of the R2 Guidance Document sheds additional light on this subject.