R2:2013 is a standard that sets responsible recycling practices for recycling electronics globally. Those recyclers certified under the standard can assist prospective purchasers/customers make informed decisions on what happens to electronics that are used or at the end of their life. Ensuring they are disposed of correctly, in an environmentally safe manner and so all data held on the electronic devices are secure until the device is destroyed.
Yet there are a few misconceptions regarding the allowances and the exclusions depending on the business model of a recycler under R2. Many recyclers feel that particular requirements do not apply to them, however, the R2:2013 standard clearly states on page one:
“All the provisions of this R2:2013 Standard shall be conformed to by R2:2013 electronics recyclers. Whether conformed to directly, or through a contracted third party, the burden of proof resides with the R2:2013 electronics recycler to demonstrate conformity to each requirement.”
There are 13 requirements within the R2 standard that recyclers must meet. Unlike standards such as ISO 9001, both the recycler and an auditor can not ‘exclude’ a provision regardless of the recycler business model or business scope.
Top 3 Misconceptions About Allowances and Exclusions
“I only recycle not re-use, so I’m exempted from Provision 2 and Provision 6 requirements.” – FALSE
As per Requirement 2 of R2:2013 – Hierarchy of Responsible Management Strategy it is the responsibility of all recyclers to put in place a policy that ensures the recycler takes the necessary steps to either re-use or resell or repair electronics. It is also up to the recycler to dismantle electronics to remove any components that can or can not be reused or recycled and dispose of these correctly. Requirement 6.c requires all recyclers to identify the following from electronics they are due to ship:
(1) Tested for Full Functions, R2/Ready for Reuse; (2) Tested for Key Functions, R2/Ready for Resale; and/or (3) Evaluated and Non-Functioning, R2/Ready for Repair.
Therefore, it is a requirement to asses all electronics obtained to ensure they are can not be reused or resold before recycling them.
“I’m excluded from Provision 6 because my customer does not allow for reuse.” – FALSE
This is only true if there is a commercial agreement provided by the customer (not the recycler) that clearly states their electronics are not to be reused in any way. Otherwise, the recycler must adhere to provision 2.a.1 and reuse the equipment where possible. Provision 6.a clearly identifies the need for a commercial agreement to prevent the reuse of products, therefore still applicable if the customer does not want to allow the reuse of an electronic.
“My customers don’t require me to do any data destruction.” – FALSE
While provision 8.a does all for the customer to request in writing for the data not to be destroyed, like the previous point it is something that the customer must request, not the recycler making policy. The first paragraph of R2:2013 clearly states the recycler’s role in destroying data on electronic devices, and provision 8 requires recyclers to sanitize, urge or destroy any data. While keeping a track of the data they do encounter, and the actions taken. This is in line with the NIST Guidelines (the National Institute of Standards and Technology) on Media Sanitation – Special Publication 800-88. There are allowances for a downstream vendor to handle the destruction of data, however, this will still need documenting and the vendor must also adhere by provision 8.
If a company can not or chooses not to adhere to all the provisions within R2:2103, then a certificating body will not grant certification. Therefore, it is essential to ensure that all requirements are followed, and policies reflect these practices. The only allowed allowances are those made in Section VII of the Code of Practices and these will be identified on the certificate to exclude upon auditing.
Want to know more about R2? Contact McDonald Consulting Group to help. We will help you evaluate your needs, and come up with the most cost-effective solution with easy implementation for your organization.
