What Does R2v3 Mean For You in 2021?
The R2 Standard, which is currently the leading standard for the electronics repair and recycling industry, has gone through a major reboot. Sustainable Electronics Recycling International (SERI), the non-profit organization that is the housing body and the ANSI-accredited Standards Development Organization for the R2 standard, recently released a revised version of the R2 standard on July 1, 2020. The latest version, R2v3, will replace R2:2013, which was previously the most recent version of the standard. Starting on January 1, 2021, all business seeking to become R2 certified will be audited to the R2v3 standard.
What is the R2 Responsible Recycling Standard?
The Responsible Recycling (R2) Standard establishes recycling best practices for the electronics repair and recycling industry that focus on environmental, health, and safety procedures. Businesses that wish to obtain or maintain R2 certification must go through an independent audit process and are subjected to documentation requirements to ensure transparency and accountability. Over 800 facilities in 31 countries currently hold R2 certifications.
The R2 Standard was originally adopted in 2008 after a lengthy collaboration process with major stakeholders including the United States Environmental Protection Agency, various state regulators, original equipment manufacturers (OEMs), customers, and electronics recyclers and their trade associations.
R2 went through its first major update in 2013 to improve its readability, provide additional best practices, and bolster the quality of certification, which resulted in the R2:2013 Standard. This update was developed by a multi-stakeholder group, the R2 Technical Advisory Committee (TAC), and involved a public comment period.
In 2015, the TAC began the process of reviewing R2 for another update. The TAC then released drafts for public comment in April and December 2019. The final revision, known as R2v3, was released on July 1, 2020. R2v3 is the product of feedback from multiple stakeholders, including customers, the public, and industry insiders.
Key Differences Between R2:2013 and R2v3
Although many of the R2v3 requirements are largely the same as R2:2013, R2v3 has been revised to reflect recent changes in customer demands, regulations, and the electronics industry in general.
Two Section Approach: Core Requirements and Process Requirements
The most notable difference is that R2v3 is reorganized into two sections to better reflect the specialization and diversity of facility types and the changing business models in the industry. For example, some facilities do not engage in the full scope of R2 processes. They might just be involved in one or two R2 processes. As a result, R2v3 has a section called Process Requirements that will apply to any R2 processes performed by a facility. The Core Requirements section applies to all R2 certified facilities. By breaking these requirements into two sections, R2v3 hopes to
- Clarify the capabilities and expertise of each R2 facility for customers; and
- Make certification more achievable, affordable, and scalable for small and start up facilities as they grow and add more specialties.
Stronger Data Protection Requirements
R2v3 also strengthens data protection requirements by, among other things, explicitly defining the approved methods for removing and destroying data from data storage devices and enhancing the requirements for verifying non-R2 downstream vendors for data sanitization. R2v3 also requires that each R2 certified facility assign a Data Protection Representative who will have overall responsibility and authority for the facility’s data security and legal compliance.
More Oversight of Downstream Process and Environmental and Health Requirements
An R2 certified facility must track and demonstrate the complete downstream recycling chain of all R2 controlled streams to final disposition or register their portion of the chain with SERI and stop tracking at the first R2 certified facility. By requiring R2 certified facilities to register their portion of the chain, SERI can track the rest of the downstream recycling chain.
R2v3 also has new and more extensive requirements for tracking throughput, including for managing and maintaining records for all equipment managed by the R2 certified facility. An R2 certified facility can only maintain a total inventory level that conforms with its legal requirements, closure plan and financial assurance. An R2 certified facility cannot store materials with a negative value (i.e. equipment that has a cost to recycle), for more than one year unless it qualifies for an exception. Further, an R2 certified facility that handles equipment, components or materials that have negative value must maintain pollution liability insurance addressing these risks.
New Legal Requirements
R2v3 also contains some new legal requirements. For example, it prohibits R2 certified facilities from using child labor and forced labor. It also requires all R2 certified facilities to adopt and maintain non-discrimination policies that ensure equal opportunity for their workers and detail a process for workers to report discrimination and for investigating and responding to complaints.
Timeline of Implementation for the R2v3 Standard
Fortunately, there is a long runway for already certified businesses to adhere to the R2v3 standard. SERI will not require facilities to transition to the R2v3 standard until at least January 2022. However, beginning January 1, 2021, all new certifications will be audited to R2v3.
If a business has an R2:2013 certification that expires on or before December 31, 2021, it will be able to recertify to the R2:2013 standard. If the R2:2013 certification expires on or after January 1, 2022, the business must recertify to the R2v3 standard.
On July 1, 2023, all R2:2013 certificates expire, and all businesses will be required to adhere to R2v3 at that time.
SERI will be offering on-demand training videos that will cover each section of R2v3. There is also a companion document to R2v3, which is called R2 Equipment Categorization (Rec), which can be used to help businesses standardize the categorization of electronic equipment for resale and recycling and determine the applicable R2 processes for each piece or batch of equipment.
Are you a business looking to sell or recycle your IT equipment? Do you want to ensure that any facilities that handle your equipment are R2 certified? Dispoteca can ensure that your equipment only goes to resellers or recyclers with a valid and current R2 certification.