BAN slams R2:2013 as "avoiding international law"

BAN slams R2:2013 as "avoiding international law"

By Editorial Staff, Resource Recycling

The Basel Action Network has penned a blistering critique of the R2:2013 standard, alleging that the updated certification "facilitates socially and environmentally irresponsible behavior in the electronic equipment recycling and asset recovery industry."

While the white paper acknowledges that R2:2013 is an improvement over the previous version of the standard, specifically citing the new R2 Code of Practice in the document, Five Fundamental Flaws: A Concise Critique of the R2:2013 Standard sharply criticizes what the group says are a lack of conformance to international hazardous waste laws, as well as allowing recycling firms to claim certification without certifying all facilities under their control. The white paper goes on to assert that the new certification allows for substitution of an EH&S system for ISO and OHSAS systems, allegedly do not require ethical labor practices, and allegedly do not require occupational health and safety practices "proportional to the unique hazards of electronics recycling.

The criticism, the full details of which can be read here , is not without its own set of problems, however.

For instance, both R2 and e-Stewards are explicitly facility-specific certifications. A full list of R2 certified facilities is available via the R2 Solutions website, presented in a similar manner to the list of certified and contracted-to-be-certified facilities listed on  Additionally, the R2 Code of Practice states that "multi-site certifications shall clearly identify the controlling site. Each site listing will clearly demonstrate any differences in scope of activities between sites. Each site must be fully audited before added to the multi-site certificate."

"These criticisms of R2:2013 are incredibly weak and misguided," said R2 Solutions executive director John Lingelbach. "[The white paper] says R2:2013 is not consistent with the Basel Ban Amendment, however the Basel Ban Amendment is not ratified and implemented as law in all developing countries nor is it ratified as part of the Basel Convention. In other words, it is not international law. It is, rather, this organization's personally preferred but misguided and ineffective tool for 'turning back the toxic tide.'"

Regarding ethical labor practices, Lingelbach says the certification explicitly states that workers in electronics recycling facilities must be treated equally and have access to the same environmental health and safety standards, regardless of where they are in the world.

"The authors of this paper are really stretching at this point to find something 'wrong' with R2:2013," says Lingelbach. "Perhaps it's a further indication that, indeed, R2:2013 is the most rigorous standard available in the electronics recycling marketplace."

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Rebuttal comments are off the mark



Dear e-Scrap News and Readers:

It appears that the rebuttal statements in this article have not been informed by an actual reading of the BAN critique.  We hope all will find it on our websites and take the time to read through it. 

The point regarding a site certification v. a corporate certification which is lost in your article is that the e-Stewards Certification requires all facilities operated by a company in a country to be certified within 18 months.  R2 allows a company to maintain uncertified sites that do not have to comply with the Standard.  This creates the problem of a company operating with double standards with different facilities in the same market.  It allows for an irresponsible company to receive an R2 certificate.  And this fact creates a situation where customer of that company are misled.   E-Stewards lists sites but what is not obvious on the map is that all facilties of a single company must be certified.   This is not a minor flaw.  It is a fundamental failure of the R2 standard. 

Mr. Lingelbach was also off the mark in his statement about international law.  We were not even speaking about the Ban Amendment.    We were noting that the R2 Standard does not acknowledge even the existence of the Basel Convention and is not cognizant of its rules.  For example many Basel wastes, which under international law must be controlled whenever traded, are not listed as "focus materials" controlled by R2 for export.   Thus R2 is written in a manner which will create illegality by the user in a Basel Country.  They will criminally liable.   This is not a minor flaw.  It is a fundamental failure of the R2 standard. 

Regarding ethical labor practices, our complaint in the critique is not about "equality".  It is that the Standard is slient on prison, child or slave labor and social accountability issues.  Nowhere does it prohibit these activities nor is the SA 8000 standard cited. 

These were some of our points.  They are very serious shortcomings in the R2 Standard and we stand by these statements.  

Sincerely yours, 

Jim Puckett, Executive Director
Basel Action Network