The Co-Location Allowance defined in the R2 Code of Practices (section V111.C) has been rescinded. The intention of this allowance was to clarify how the R2 Standard would apply to an electronics recycler that was sharing a location with another business not engaged in electronics-related activities that fall within the scope of the R2 Standard. In some cases, however, instead of clarifying, the co-location allowance created confusion.
In the introduction to the R2 Standard, the Applicability section states that “The R2:2013 Standard shall apply to all electronics recycling related activities at a physical address.” To illustrate how this applies, consider an electronics recycler that is co-located with an automotive recycler. Because automotive recycling activities are outside the scope of the R2 Standard, the automobile recycler is not eligible for R2 certification. The electronics recycler operating at the same address, however, is eligible to pursue R2 certification for its activities related to electronics reuse/recycling/resale.
The co-location allowance was never intended to allow a co-located business processing used electronics to become R2 Certified if the other co-located business, also performing R2 certifiable activities at the same physical address, was not R2 Certified. For example, it’s not permissible for an R2 certified refurbisher to share a space with a non-R2 certified electronics recycler. Since both co-located companies are engaged in electronics-related activities that are within the scope of the R2 Standard, BOTH would have to be R2 certified. This reduces the risk of diverting used electronics and/or Focus Materials through the non-certified business.
Since the language in the Applicability section of the R2 Standard makes clear that the Standard applies to all electronics recycling activities at the physical address on the R2 Certificate, there is no need to further clarify this point using the co-location allowance. The removal of the co-location allowance does not impact the requirements of the R2 Standard. R2 Certified companies sharing a location with another business will still be required to ensure conformance to all requirements of the R2 Standard. R2 certified companies can continue to share a location with a non-certified company that does not engage in electronics-related activities included in the scope of the R2 Standard. And auditors will continue to ensure that all electronics recycling activities at the physical address on the R2 Certificate are included in the scope and audited for R2 Certification.