Facilities Face Certification Troubles
In less than a week, the shift to the R2v3 certification standard will take effect, and unfortunately many electronics recycling and reuse facilities are expected to be impacted. Experts predict that because of this change, numerous organizations may experience temporary de-certification, which could have serious corporate implications.
Concerns have been raised by Steven Napoli, the president and CEO of The Electronics Reuse and Recycling Alliance (TERRA), which consists of member companies with approved sites. According to Napoli, “That’s going to be very damaging to their businesses.”
“You hate to see good actors get lost in the shuffle,” he added.
As June 30th quickly approaches, many facilities have found themselves unable to make a successful transition from R2:2013 to R2v3. Those who fail to meet this deadline, and lose certification, are at risk of missing out on valuable contracts for ITAD and recycling opportunities with governments and private corporations.
Furthermore, it becomes more complex for certified R2v3 processors to conduct transactions with uncertified facilities, while adhering to the current standard.
A Look into the Issues
Interviews with stakeholders have revealed that there are a few key issues contributing to the failure of some facilities to meet the transition date for the R2v3 standard. Roadblocks include limited audit capacity, an increase of complexity regarding the new standard, delays related to COVID-19, and a reluctance on the part of decision makers to make expenditures associated with transitioning.
Sustainable Electronics Recycling International (SERI) has declared that certification bodies (CBs) are concentrating on helping clients switch from R2:2013 to R2v3 instead of focusing on new certifications being issued. Nevertheless, certain facilities may face a temporary suspension of their R2 certification.
As the deadline for compliance quickly approaches, SERI is reiterating that companies must remain vigilant and open in communication with customers. No extensions or grace periods will be given after the expiration date.
“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, the communication leader for SERI. “At the end of the day that is a choice that we made and we stand by it.”
He highlighted that SERI predicted apprehension in the industry around the cut-off date, as businesses understood they were running out of time and would need to rush to conclude audits.
“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 stated. “The resources didn’t match demand.”
The Possible Consequences
According to Seibert, in the last three years, 927 different locations have completed the certification process for R2v3. Out of this figure, 647 were transitioning from R2:2013, and 280 had never been certified before.
He believes that there are currently a total of 82 facilities which are still R2:2013 certified, and many more in the process of upgrading to R2v3.
With only a month left before the cut-off date, SERI made it apparent that some facilities wouldn’t make the transition on time via its May 31st newsletter.
“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 stated. “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.”
It has become evident that there is a significant time lag between when audits are completed and when R2v3 authorizations are issued, even in cases that feature no non-conformances.
“Certification Gaps”
Recently, Synergy Electronics Recycling, a Madison, N.C.-based company working in the field of electronics recycling and reuse, was met with a certification gap which has now been filled due to the arrival of its R2v3 certification.
At the beginning of March, NSF, which is Synergy’s certification body, sent a letter to the recycler. This letter stated that an audit performed during February yielded no discrepancies and that NSF was proposing Synergy receive R2v3 accreditation. The message then went on to recognize “the complexities involved with the review of R2v3 audit packages.”
Megan Tabb, the head of sales and compliance for Synergy, declared that she was able to display a letter to customers who saw that the company’s R2:2013 certification lapsed 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 explained to E-Scrap News just before Synergy received its R2v3 documentation.
Tabb highlighted that the NSF had begun a recruitment drive, which led the auditing firm to give Synergy highest priority.
“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 stated.
Tabb pointed out that many organizations began the process of transitioning into R2v3 at a later point, due to the high cost associated with it. She estimated such an expense could be in the tens or hundreds of thousands for some companies. As expected, this caused many operators to delay initiating the upgrade.
A Unique Set of Challenges
Noted by Seibert of SERI, the move to a new certification standard came with its set of hurdles. This transition to updated text was released in 2020 which coincided with the spread of COVID-19, resulting in an immediate shift towards virtual audits from in-person meetings (which many assumed was going to occur naturally given the increasing globalization of R2).
Seibert notes that the remarkable growth of R2 has outdistanced the resources available to auditors. Also, since the technical elements of R2v3 are complex, onboarding new auditors can take some time.
Saying this, Seibert illuminated the fact the CBs have been giving more attention to the switch from R2:2013 to R2v3 over brand-new R2 certifications.
“We had to tell new people, ‘Yes, but after we get through this,’” Seibert commented.
SERI has long strived to assume a significant role in the transition process. As part of this commitment, Seibert explained that SERI has released video and printed materials to assist CBs and facilities in making the switch, alongside creating a remote auditing system for use.
“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.”
Although many facilities were expected to do so, some have chosen to abstain from obtaining the R2 certification following its latest update. He noted that this is not an uncommon practice when a certification process undergoes any kind of change.
Those “Falling Through the Gap”
TERRA is an organization that requires all of its members who process e-scrap to have either one of two certifications, being e-Stewards or R2. But, a crippling issue remains: what does a certified facility do in the event that it is not able to get its R2v3 certification before the end of the month, and risk having neither?
TERRA is currently in a difficult situation, as the organization is tasked with coordinating collection opportunities and supplying material to member recycling facilities. According to Napoli, a terra member, Tennessee-based Omega Recycling Solutions was audited in November 2022, but its R2v3 paperwork didn’t arrive until two weeks ago. Incredibly enough, there were no issues that delayed its final approval process.
In total, TERRA has approximately 120 member centers around the world, according to his report. Of those, 22 remain certified to R2:2013, but it appears that almost all are in the process of transitioning into R2v3. He recently spoke with two centers, who confirmed that their paperwork had already been submitted and they were awaiting approval.
With that in mind, he has decided to provide a window of opportunity, once he makes initial contact, to ensure that firms are sure about certification objectives, he noted.
“We’re not going to just drop them,” Napoli added.
He cautioned that the loss of certification could easily translate to a decline of business. He was aware that rivals would take advantage of such situations and contact governments and companies to inform them that certain ITAD vendors no longer had R2 certification, with the hope of persuading these groups into signing an agreement with competitors instead.
Before the R2v3 paperwork deadline, SERI advises that individuals be proactive with communication, and open 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 noted in the newsletter.
Napoli stressed that the situation should be sorted within three to four months, although he can’t overlook the potential repercussions of a temporary lack of accreditation. He pointed out that even a brief period without certification could have far-reaching effects.
“A lot of damage can take place in that time frame,” he said. “I’d hate to see those companies get devastated like that.”
