[Note: “Text in italics and quotes” below are quoted directly from the R2v3 second draft standard.]
In Part 1, we covered the Introduction the second draft of the R2v3 standard. It contained a lot of critical information that we should be aware of. If you’re finding this post and haven’t read Part 1, I encourage you to go back and see the key points to be aware of.
In this section, we’re going to cover the key highlights of the Definitions. While some definitions haven’t changed, others have been added or deleted. Please refer to the second draft for the complete list of definitions – this post only covers critical changes.
There are several clarifications in the definitions – here are some key ones:
- Control has been updated – where it used to talk about ‘material’ it now covers ‘electronic equipment, components, or materials’ – making it clear that it covers multiple types of materials.
- “Control” of electronic equipment, components, or materials begins at the point where and when the R2 Facility takes title, physical possession, or contractual obligation for the electronic equipment, components, or materials, regardless of ownership.”
- Recycling has been clarified to describe it as “a series of activities during which obsolete, previously used, off-specification, surplus or incidentally produced materials are processed into specification-grade commodities, and consumed as raw-material feedstock, in lieu of virgin materials, in the manufacturing of new products, whether for the original use or other purposes, but does not include energy recovery or the reprocessing into materials that are to be used only as fuels or only for land disposal operations. Hazardous characteristics of the material must be removed in the recycling process or provide a desired benefit in the manufacturing or characteristics of new products. Materials are not considered recycled until in the form of raw materials or products.”
- Scope now reads “Scope” is the extent of the R2 Certification covering all processes; electronic equipment, components, and materials managed; and activities related to the collection, refurbishing, repair, resale, demanufacturing, asset recovery, brokering and recycling of electronic equipment, components, and materials both at its facility and under its control, such as in the case of outsourced activities.
Although the operations of an R2 Facility may be physically separated, all certifiable activities at the facility must be included in the scope of the R2 Certification regardless of any subdivision into rooms, units, suites, buildings or otherwise, with the use of fences, walls, or any other dividers. Where there are multiple buildings on a site that share the same physical address, each must be included in the scope.
Where there is more than one business at the site that is involved in the processing of used electronic equipment, components, or materials, each business and all operations must be R2 Certified, unless the Certification Body can verify that legally each business is:
- A separate legal entity, and
- Completely separated physically from the other businesses, that are independently owned and
- Independently operated, and
- Free of any commonality in ownership, workers, and services, and
- Any interaction between the businesses or their processes is traceable, documented, and conforms with the R2 Standard.
- Other activities that are not related to the processing of used electronic equipment, components, or materials may also be performed at the same site, but are not eligible for R2 Certification, and therefore not included in the scope of certification.
- Where the businesses R2 Facility undertakes activities related to the certifiable activities, but at a separate site with a site without the other different physical address, the R2 certification may be extended to the related site through a campus or multi-site certification. Otherwise, R2 Certification is limited to the operations related to the single physical address.”
The scope has been revised to provide additional clarity on what must be included in the scope of R2 certification, as well as what is out of scope.
Furthermore, SERI TAC (Technical Advisory Committee) states that “There are two key aspects of scope: control; and association with certifiable activities. “Control” begins at the point where an R2 Facility takes title, physical possession, or otherwise contractually manages any R2 Controlled Streams. Once under its control, the R2 Facility must manage all R2 Controlled Streams in accordance with the R2 Certified processes. And, where certifiable activities are taking place at an R2 Facility, those activities must be included in the scope of certification.”
The definitions for the following have been deleted:
- Evaluation Stage Category
And the following definitions have been added:
- “Evaluate” refers to a variety of activities designed to assess various aspects of equipment or components to determine reuse potential.
- OEM (Original Equipment Manufacturer)
“OEM” is the organization that produces and brands the electronic device or component, whether manufactured by the organization, or by a contract manufacturer.
- R2 Controlled Streams
“R2 Controlled Streams” as defined in Table 1 of the REC, are electronic equipment, component, or material streams that are subject to the requirements of the R2 Standard for processing and disposition.
“Supplier” includes any upstream entity that provides used electronic equipment, components, or materials to the R2 Facility.
- Test and Repair
“Test and repair” is the processing of used electronic equipment and components to produce reusable products and define the category of functionality.
- Unrestricted Streams
“Unrestricted Streams” as defined in Table 1 of the REC, are electronic equipment, component, and material streams that do not require R2 processing or downstream vendor verification.
The real changes, however, are in the area of Focus Materials. The definition for Focus Materials now has a helpful table, including a description of when the tracking requirement stops, as shown here:
The table below provides further information about each FM and when tracking the FM in the recycling chain may stop.
|When tracking requirement stops*
|Polychlorinated biphenyls (PCBs)
|When received at a government licensed or permitted hazardous waste landfill or hazardous waste incinerator; or when received by a downstream R2 certified facility.
|When retorted and distilled; or when received at a licensed or permitted hazardous waste storage facility; or when received by a downstream R2 certified facility.
|Glass from Cathode Ray Tubes (CRTs), except for the panel glass that has been separated from funnel glass and cleaned of phosphors, CRT fines, coatings, and frit: and is demonstrated to leach less than 5 part per million lead.
|When the CRT glass has been processed for use in its entirety in a new product with a known end use and existing market; or when received at a government licensed or permitted smelter; or when received by a downstream R2 certified facility.
|All battery chemistries from electronic equipment except alkaline batteries that do not contain mercury.
|When received at a facility that will recover metals, and where practical, other materials from batteries; or when received by a downstream R2 certified facility.
|Whole, partial, or shredded circuit boards regardless of lead and/or mercury content.
|When received at a facility that will recover metals, and where practical, other materials from circuit boards; or when received by a downstream R2 certified facility.
* Tracking requirement stops because the Focus Material is either transferred to another R2 Facility for further R2 processing (and will therefore be subject to another audit of that downstream R2 Facility), or has reached the final process in the recycling chain, after which the material has reached final disposition and is no longer considered an FM.
Electronic equipment, components, or materials (whole or shredded) that have undergone safe and effective mechanical processing or manual dismantling to remove FMs, yet still retain de minimis amounts of FMs, are not subject to the R2 requirements that are triggered by the presence of FMs.
So, while one definition has been eliminated, and several others have been clarified, we also should take the new definitions into account, as well as ensure that we are tracking our Focus Materials through to the requirements. As we talked about in Part 1, if we don’t have evidence or records (in this case, that tracking is complete), we are at risk for losing our certification or not receiving certification!
But wait – we’re not done yet!
Next up: Core Requirement 1 – Scope and Core Requirement 2 – Hierarchy of Responsible Management Strategies
There’s a lot of information in these posts! Can’t wait for the entire series and want to engage with us now? Contact us to start the process!