With the date to transition to the R2v3 certification standard one week away, stakeholders estimate dozens of electronics recycling and reuse facilities may temporarily lose their R2 certifications. The lapse could mean serious business consequences for companies.
“I’m worried that many of those are going to slip through the cracks,” said Steven Napoli, president and CEO of The Electronics Reuse and Recycling Alliance (TERRA), which is made up of member companies with certified facilities. “That’s going to be very damaging to their businesses.”
“You hate to see good actors get lost in the shuffle,” he added.
The transition from R2:2013 to R2v3 has been years in the making, but as the June 30 deadline approaches for all certified facilities to make the switch, it has become clear that many won’t cross the finish line in time. Losing certification may mean the loss of ITAD and recycling contracts with government agencies and private companies. It also makes it more complicated for R2v3-certified processors to trade materials with uncertified facilities while maintaining compliance with the standard.
In interviews, stakeholders point to a number of reasons a number of facilities won’t make the transition in time: auditing capacity that hasn’t been able to keep pace with demand, the increased complexity of the R2v3 standard, COVID-19 related delays, and a general inclination to wait on paying expenses associated with transitioning.
Sustainable Electronics Recycling International (SERI), which administers the R2 standard, said certification bodies (CBs) are prioritizing clients’ transition from R2:2013 to R2v3 over new certifications, but SERI did acknowledge some facilities will temporarily lose R2 certification.
Urging affected companies to be proactive and transparent with customers, SERI said it is not planning to provide extensions or grace periods after the deadline passes.
“Though people asked us throughout the process, we understood that this was not something we wanted to do. We wanted to put more resources and communication into getting it done,” said Jeff Seibert, who leads communications for SERI. “At the end of the day that is a choice that we made and we stand by it.”
He added that SERI anticipated anxiety in the industry close to the deadline, when companies would realize they had limited time left and would rush to get audits completed.
“One thing we tried to do pretty early on is communicate and stay ahead of it and say, ‘Guys, we understand why you want to delay, especially in these economic times and all that’s happening. We know why you want to delay, but there’s going to be the bubble at the end,'” Seibert said. “The resources didn’t match demand.”
How many could be affected
On June 21, Seibert said 927 facilities have become certified to R2v3 during the transition over the past three years. Of those, 647 made the transition from R2:2013 and 280 were altogether new to R2.
He estimates another 82 facilities are currently R2:2013 certified, with a chunk of those somewhere still in the process of moving to R2v3.
In a May 31 newsletter, one month before the deadline, SERI said it was becoming clear some facilities in the process of transitioning wouldn’t make it in time.
“We recognize that for a variety of reasons, some of those R2 facilities still in-process will not complete the transition to R2v3 before the June 30 deadline,” the newsletter noted. “While CBs and auditors continue to push as hard as they can, at this point, if your facility doesn’t have your R2v3 Certificate in hand, there is a good chance you’ll end up with a gap in your Certification and an ‘expired’ designation if your customers look you up on the R2 Directory.”
The reason is that there have been delays between when the audits are conducted and when the R2v3 approvals are received, even in cases where there weren’t non-conformances to fix.
That was the case with Synergy Electronics Recycling, a Madison, N.C.-based electronics recycling and reuse company that experienced a certification gap until its R2v3 certificate arrived in recent days.
“R2v3 audits are very complex … and it’s been difficult for the certification body to keep up with demand from their clients.”
–Megan Tabb, director of sales and compliance, Synergy
In early March, NSF, Synergy’s certification body, provided a letter to the recycler confirming that the firm had conducted an audit in February and found no non-conformances, and that it was recommending Synergy receive R2v3. The letter cited a delay, however, noting “the complexities involved with the review of R2v3 audit packages.”
Megan Tabb, director of sales and compliance for Synergy, said her company was able to show the letter to clients who had noticed Synergy’s R2:2013 certification had expired in mid-May.
“A lot of people have reached out to us asking what’s going on and given us a chance to say, ‘We’ve gone through the audit process, we’ve had no non-conformances, here’s a letter from our certification body stating as much. For whatever reason, the process is just taking a lot longer this time,'” Tabb told E-Scrap News shortly before Synergy received its R2v3 documentation.
NSF indicated it was hiring more staff, Tabb noted, and the auditing firm ultimately put Synergy on a priority list.
“R2v3 audits are very complex, and with the amount of evidence that the certification body has to collect and provide to SERI, it’s a lot, and it’s been difficult for the certification body to keep up with demand from their clients,” Tabb said.
Tabb also noted that some companies likely got a late start because the new requirements in R2v3 are expensive to implement, costing in the tens – or possibly even hundreds – of thousands of dollars. It’s no surprise some facility operators waited to put off that expense, she said.
“We’ve been running at a full-tilt pace because that’s what this transition required.”
–Jeff Seibert, SERI
Seibert of SERI noted that any certification transition will bring its challenges. In this case, the updated standard text was published in 2020, right as the COVID-19 pandemic swept the world, requiring a shift to online and away from in-person audits (it was a transition that needed to happen anyway, because of the globalization of R2), he said.
Additionally, the growing popularity of R2 in general has outpaced auditors’ resources, Seibert said. And because R2v3 is so technical, it takes time to get new auditors up and running, he added.
That being said, the CBs have been moving resources to prioritize transitions from R2:2013 to R2v3 over brand-new R2 certifications, Seibert noted.
“We had to tell new people, ‘Yes, but after we get through this,'” Seibert said.
Over the years, SERI worked to take an active role in the transition. The group developed a remote audit option and released video and print resources to help facilities and CBs with the transition, Seibert said.
“We’ve been running at a full-tilt pace because that’s what this transition required,” he said. “We did what we needed to do all along the way.”
He acknowledged that, as is the case with any certification update, some facilities have decided to no longer pursue R2 certification.
What happens for those falling through the gap
TERRA is a membership association that requires its participating e-scrap facilities hold e-Stewards or R2 certifications. So what if long-certified facilities aren’t able to receive their R2v3 certificates before the end of the month and end up with neither certification for a period?
The situation has presented a bit of a conundrum for TERRA, which coordinates collection opportunities and feeds material to member recycling facilities. Napoli said he talked with one TERRA member, Tennessee-based Omega Recycling Solutions, which completed its audit in November 2022 but didn’t receive the final R2v3 paperwork until two weeks ago. In that case, there were no particular compliance issues slowing down the approval, either, he said.
Overall, TERRA now has about 120 facilities around the world that are members, he said. Among those, 22 are still certified to R2:2013. He believes most, if not all, of the 22 are pursuing R2v3, with two he talked to recently indicating their paperwork was in and they’re awaiting approval.
Knowing that, he plans to offer a grace period, after he first gets in touch to confirm their certification intentions, he said.
“We’re not going to just drop them,” Napoli added.
In general, a loss of certification can mean the loss of business contracts, he noted. He could envision competitors reaching out to governments and corporations to notify them that their current ITAD vendor has lost R2 certification in an attempt to win that contract for themselves.
For those whose R2v3 paperwork won’t come through before the deadline, SERI recommends communicating proactively and being transparent with clients.
“Though this won’t be an ideal situation, having an open and honest dialogue with your customers and any upstream or downstream partners is still the best way to manage this time until your facility completes R2v3 Certification,” SERI wrote in the newsletter.
Napoli noted that, whatever happens, it will work itself out over the next 90 to 120 days and won’t be a long-term concern. Still, he worries about the impacts of even a short-term loss of certification.
“A lot of damage can take place in that time frame,” he said. “I’d hate to see those companies get devastated like that.”
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