When customer requirements conflict with R2 requirements

Some R2 Certified facilities have recently found themselves with a difficult choice:  follow the R2 Standard requirements and lose a customer or drop R2 Certification to keep a customer contract.  Facilities that are certified to the R2 Standard are responsible for the proper management and disposition of all untested or non-working electronics that pass through their control — throughout the entire reuse-recycling chain.  The R2 Standard requires that all vendors in the downstream chain must be verified prior to receiving untested or non-working electronics from an R2 certified facility to ensure the downstream vendor(s) meet the necessary R2 Provisions (3.a.2, 5.e, 6.c.3, 8.h).   The conflict arises when a customer requires an R2 Certified facility to return or send untested or broken electronics to an unverified downstream vendor. 

Full reuse and recycling of electronics requires a network of specialized vendors.  One of the core tenants of R2 is controlling the disposition of non-working electronics throughout the entire network of downstream processors and vendors.  This begins the moment the equipment enters the R2 Certified channel and continues throughout the flow of processing — whether the electronics are fully processed in the R2 Certified facility or by other vendors further down the reuse-recycling chain.  The R2 Standard has no provision to allow for customer requirements to override these downstream vendor due diligence requirements.

Conflicts between customer requirements and R2 requirements typically occur in returns processing, warranty repairs, and trade-in programs.  The customer will contract with an R2 Certified facility to service electronics that the customer continues to own.   In some cases, the customer requires the R2 facility to return non-functional equipment (usually called BER for Beyond Economic Repair) to them or to send it to a downstream vendor of the customer’s choice that may or may not conform to the R2 downstream vendor requirements. 

Company decision makers are often the drivers of policies that require using R2 service providers, but other departments within the company sometimes impose requirements that prevent R2 providers from exercising the necessary control and due diligence over the downstream chain.  While the customer should be able to decide what to do with the BER equipment they own, the R2 Certified facility also has a responsibility to ensure BER equipment is directed to a downstream recycling chain that conforms with the R2 downstream vendor requirements.   Consequently, this situation can result in a non-conforming activity which may jeopardize the R2 facility’s certification.

The R2 Consensus Body (the stakeholder group with authority to change the R2 Standard) has considered this conflict in great depth for more than a year, looking for a way to balance the customer’s wishes with the R2 provider’s responsibility to ensure responsible control of BER electronics through the entire recycling chain.  They have proposed a possible compromise in the next version of the R2 Standard that will still ensure due diligence for each downstream vendor.   If a customer requests the return of BER equipment or directs where their R2 certified provider is to send the equipment, as long as the next processor is R2 certified, that will satisfy R2 due diligence and tracking requirements.  Due diligence is still required for each vendor in the recycling chain, but each R2 Certified service provider can stop tracking the flow of equipment when it reaches the next R2 Certified downstream vendor.  In order to maintain transparency and accountability of the recycling chain, R2 Certified facilities will be required to register their recycling chains with SERI to the first R2 Certified downstream vendor, or to the final processor when using a downstream vendor that is not R2 certified. 

This trade-off will not resolve all conflicts and it will still require the cooperation of customers.  There may still be occasional customers with requirements that conflict with R2 requirements.  In such cases, facilities must keep in mind that R2 Certification is facility based, not process based, and exceptions cannot be made for specific customers or processes.    Due diligence is required for all streams of untested or non-functioning electronics—regardless of the product type or customer requirement to the contrary.  Due diligence of downstream vendors is essential to mitigate the risks of legal non-compliance, data breaches, and pollution liability in the downstream vendor network.  Eliminating the due diligence to satisfy customer requirements is not a solution that the R2 Consensus Body supports. 

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SERI – Sustainable Electronics Recycling International