R2 FACILITY NEWSLETTER I MARCH 2023

FEATURE STORY:

CLARIFYING APPENDIX E

The R2 Technical Advisory Committee (R2 TAC) that drafted R2v3 understood the benefits of separating the R2 Standard into two parts; Core Requirements, which all R2 Facilities need to conform to, and Process Requirements or the Appendices, which are only applicable to an R2 Facility if that facility conducts specific processes. For example, those R2 Facilities that do not perform logical data sanitization do not need to certify to Appendix B for Logical Sanitization. However, while this example is fairly straightforward, there are some instances where the applicability of a Process Requirement is not always as clear. In an attempt to clarify the applicability of Process Requirements, SERI published two guidance documents to the R2 Knowledge Base in January 2022 (R2v3 Appendix Determination Tool and R2v3 Appendix Applicability Guidance).

Since publishing those documents, the feedback SERI has received is that there is existing confusion surrounding when Appendix E applies. After a thorough review of the January 2022 guidance, SERI has determined that while accurately aligned with the R2v3 Standard, the language in those two guidance documents did not create the desired clarity, and in fact, may have created additional confusion. The use of the terms “non-destructive de-manufacturing" and “destructive dismantling” was meant to differentiate when R2 Facilities gently de-manufacture electronics to harvest components for reuse (de-manufacturing). When not intended for reuse, dismantling components to separate materials quickly for various recycling streams without regard to preserving their integrity is generally employed in a more destructive manner. Thus, the central premise of the applicability of Appendix E is whether processes are intended for component reuse or for materials recovery, Core 6(d)(5). 

With the R2 hierarchy of responsible management strategies that prioritizes reuse, R2v3 promotes a circular approach for used electronics. To this end, R2v3 does not prohibit the harvesting of components for reuse, and in fact, allows it without requiring Appendix E or even Appendix C. Furthermore, with R2v3’s strong emphasis on data security, the R2 Standard also allows the harvesting of components for data sanitization in Core 6(d)(2) without requiring Appendix E. 

To highlight the priority of reuse and data security in R2v3, the SERI team, along with input from the R2 TAC, has created new guidance to clarify the applicability of Appendix E, and added it to the R2 Knowledge Base. You can find the new Clarification on Appendix E and Appendix E Applicability Flowchart Guidance in the R2 Knowledge Base. Additionally, SERI has revised the two existing guidance documents that were originally published in January 2022 in order to provide additional clarifications, R2v3 Appendix Determination Tool and R2v3 Appendix Applicability Guidance. SERI will work with Certification Bodies (CBs) and Auditors to understand this guidance through established channels such as scheduled bi-monthly calls, Auditor Newsletters, and training videos.

TRANSITION TO R2V3:

RESOLVING YOUR NCs 

As we come down the home stretch of the transition to R2v3, we know there are many facilities going through the transition audit process. As is true during any transition to a new version of a standard, receiving nonconformities (NCs), while admittedly not ideal for the facility, is common.

As a reminder, open NCs will delay getting your R2v3 Certificate, so we know you’ll want to resolve your NCs as quickly as possible.

SERI wants to be as helpful as possible through the transition and beyond. While we can’t intervene in the process between an R2 Facility and Certification Body (CB), we’re here to be a resource.

We’ve heard from many people that the R2 Knowledge Base has been a helpful addition for R2v3, and we continue to add new resources to make it even more valuable. If you haven’t used it before, or if it’s been a while, check out the R2 Knowledge Base today. There are lots of articles, videos, Q&A’s, and other guidance that will help you understand the requirements so you can correct your NCs as quickly as possible so you can receive your R2v3 Certificate in a timelier manner.  

AVAILABLE R2v3 TRAINING CLASSES

NEW TO R2: INTRO TO R2 WEBINAR 

If you want to learn more about R2, join us on our Intro to R2 Webinars. They are held 3-4 times per month and are offered to accommodate time zones on all continents.

R2 AUDITOR TRAINING CLASSES

Looking for in-depth, online, and interactive training on R2v3? These classes are open to auditors, consultants, and facilities. Sign up for the class today!

IN-PERSON TAC MEETING  

SCHEDULED FOR APRIL 11th-12th IN DENVER 



The R2 Technical Advisory Committee (TAC) will hold an in-person meeting on April 11-12, 2023, in Denver, Colorado.  The R2 TAC will discuss recommendations for adding a new Appendix G to incorporate Photovoltaic Modules (also known as Solar Panels) in the R2 Standard.  

The meeting will be held from Noon to 7 p.m. MST Tuesday and from 7 a.m. to Noon Wednesday.   

Interested parties are invited to observe the meeting and comment during open commentary periods. The R2 TAC is the multi-stakeholder group that develops and updates the R2 Standard and can be comprised of up to 45 volunteer members (representing entities covered by the standard, their customers, and regulatory/public interest/other stakeholders). The R2 TAC works to bring consensus during the standard development process, and the smaller sub-group of a balanced Consensus Body votes on issues, like Appendix G. If you are interested in attending the in-person meeting, please let us know here and we will provide more information as it is finalized.  

SERI’s mission is to create a world where electronic products are reused and recycled in a way that results in resource preservation, the well-being of the environment, and the health and safety of workers and communities. To accomplish our mission, we look for opportunities to engage with various stakeholders on electronics sustainability and the value of R2 Certification and working with R2 Certified partners.

This past month, Corey Dehmey attended the Remade Circular Economy Tech Summit and Conference in Washington D.C. and Roger Greive presented on the topic of Sustainable ITAD at ITAM Review Wisdom NA23 in St. Petersburg, FL.

Here's we're headed next:

• ISRI 2023, Nashville TN, April - R2 Director, Mike Easterbrook will participate on the panel “The Growing Data Security and Destruction Movement” on April 18th and Roger will moderate the panel “Reuse and Recycling in a Changing World of IoT” on April 20th.

• IAITAM Ace, Nashville TN, May - Roger will be moderating a panel, and SERI will have a booth to promote R2v3 for Sustainable ITAD.

• Going Green CARE Innovation Conference, Vienna, Austria, May - Corey and Macy Toal will each be presenting, and SERI will exhibit to promote R2 in Europe.