An excerpt from, E-Scrap News by Bobby Elliott
How R2 views shipment abroad
The R2 standard, meanwhile, does not ban shipments of e-scrap to developing countries. But it does require firms to ensure that such shipments, including those that contain potentially hazardous components – known as “focus materials” under R2 – are legal and follow the standard’s guidelines on documentation, downstream due diligence and management.
“I think that our missions are different,” said Corey Dehmey, SERI’s R2 director. “Here at SERI and R2, we’re looking at ensuring the responsible reuse and recycling of electronics around the world.”
Dehmey said, however, that R2 puts a strong focus on understanding where material is going abroad and how it is being managed once it arrives. “We’re concerned that it’s legal and that it’s being managed by a qualified downstream vendor that has the capabilities to properly manage it,” Dehmey stated.
Under the standard, certified firms shipping non-working devices or items containing focus materials (such as lead or mercury) are required to prove, first and foremost, the legality of the shipment. This requirement covers material that is sent to a downstream vendor or intermediary before being shipped to its ultimate destination.
According to the standard, “Prior to shipment, the recycler shall identify the countries that are receiving or transferring such shipments, obtain documentation demonstrating that each such country legally accepts such shipments, and demonstrate compliance of each shipment with the applicable export and import laws.”
Dehmey added, “The standard doesn’t assume that it’s legal. Each R2-certified company is required to demonstrate that it’s legal with the documentation to support that.”
For instance, if a company attempts to send shipments containing focus materials to a country that has ratified the Basel Convention, it would likely be deemed illegal and therefore not permitted under R2. “If countries want to ban it or not, that’s up to them to decide and we respect that and require that it’s followed,” Dehmey said.
Downstream partners of R2-certified firms are not required to be certified to the standard, but are expected to manage the material “in a manner protective of worker health and safety, public health, and the environment,” the R2 document states. This includes following a pre-established processing plan for focus materials and complying with the standard’s baseline on-site environmental, health and safety requirements.
For shipments of what it deems to be working devices, R2 has less demanding requirements. In addition to allowing tested and fully functional devices to be shipped overseas without extensive consent and legal documentation, the standard also allows shipments of devices that have been tested for “key functions.” This criteria, which does not exist under e-Stewards, is defined as “the originally-intended functions of a unit of equipment or component, or a subset thereof, that will satisfactorily serve the purpose(s) of someone who will reuse the unit.”
Dehmey stated that waste regulations abroad don’t often come into play with devices that are fully functional or have been tested for key functionality. “Tested, working devices are typically not considered a waste and therefore, in most countries, the waste regulations for import wouldn’t apply,” he noted.