R2 STANDARD GUIDANCE
We only log test results for equipment that passes our testing. We do not log the test results of equipment that fails since it goes directly to our dismantling area to be broken down and sent to a downstream vendor for recycling. Are we required to log the testing records of failed equipment destined for end-of-life recycling?
ANSWER
The language under Provision 6 uses the word “effective” (...verify the accuracy of test methods and testing equipment and maintain records of effective testing methods, equipment and results as appropriate).
This means the effectiveness of your testing process and record keeping is open to some subjectivity by the auditor. If every test record is a pass, it may raise questions about whether the results are just copied and pasted, and whether the testing was actually performed. If you were using an automated testing software, for example, it would record both pass and fail records. To demonstrate the credibility of your process, it would be wise to maintain failure records as well as success records
How sharing space affects R2 Certification
Occasionally two or more companies may operate out of the same location. It may be a cost sharing arrangement, sister companies operating as independent entities, or perhaps a company operating under a parent or umbrella company. Regardless of the relationship of the co-located companies, R2 requires that all electronics recycling related activities taking place at a single facility must conform to all R2 Provisions and be included in the R2 audit.
This means that all companies sharing the same physical address, and that are involved in managing used electronics in any capacity (including collection, refurbishment, resale, data destruction, recycling, or other related activities) must be R2 Certified. It is not permissible for a recycler to cherry pick which recycling/refurbishing/resale activities taking place at the facility are subject to audit and R2 certification.
In some cases, a recycler may share space with another company that is not engaged in activities related to used electronics. Some common examples:
A metals recycling facility that has added electronics recycling to its traditional scrap metal operation. (The purchasing and processing of scrap metal is unrelated to electronics recycling.)
A company that kits new cell phones for distribution, but that also runs a return operation for used cell phones. (The distribution of new cellphones is unrelated to the management of used cell phones.)
In such cases, it is permissible to certify only the company, activities, or areas of the facility that are engaged in activities related to used electronics. The “Co-location Allowance” defined in the R2 Code of Practices applies to such arrangements, and must be vetted and approved by the Certification Body.
WHEN DO I UPGRADE TO NEW R2V3 STANDARD ?
SERI the oversight body for the R2 Recycling standard has provided the transition process.
Year 2022
All currently registered R2:2013 companies whose R2:2013 certificates are expiring in 2022 must upgrade to the new R2v3 Standard.
Year 2023
The existing R2:2013 Standard is set to expire by July 1 2023.
Helpful Tip:
Based on the new R2v3 requirements many of the Registrars are adding additional time to perform the upgrade R2v3 audit. The auditor availability to perform R2v3 audits will also be scarce based on the increased number of days to perform the upgrade. Suitable planning steps would be to schedule your R2v3 upgrade audit 6 months in advance of your expiring R2:2013 certificate.
R2 Documents
ISO 9001:2015 Standard
ISO 14001:2015 Standard
ISO 45001:2018 Standard