Most followers of the Good Point Ideas Blog already know that the R2 (Responsible Recyclers) Certification program was developed over a decade ago by US EPA. EPA's Clare Lindsey and Bob Tonetti hired a professional consensus mediator, John Lingelbach, to moderate the development of agreed upon standards that would achieve better results in reuse, repair and recycling of used electronics. Lingelbach later incorporated the Sustainable Electronics Recycling International organization to "house" the new standard. SERI realized that the original standard developed by EPA would be a public document, not copyrightable... so SERI tweaked the R2 Standard in order to establish a way to earn revenue.
SERI's R2 Standard gives prescriptions for electronics recycling practices. The practices are developed by the Technical Advisory Committee (TAC, the ongoing advisor team from the industry). The TAC standards, if passed by the SERI Board of Directors, create new rules (red tape) for Certified Recyclers to follow.
Without even a formal change in the rules, SERI can issue guidance to reflect a change in interpretation of the original rules. That's right, a TAC can act like a radical Supreme Court, with no tether to precedent. A clear example of this took place during this year's audit of Good Point Recycling, which passed 99% of the Audit with flying colors. However, the auditor called foul on a trade which passed R2 audits the previous 9 years... a trade that has taken place with the same downstream vendor for 17 years. A new "interpretation" of the old rules may cost my Vermont company $356,000 dollars per year, while achieving zero environmental benefit.
This is messed up. The rules have not yet been changed, but the "interpretation" of the old rules has.
Let's play a game. Three Truths and a Lie about the purpose of the R2 Standard.
1) The problem R2 was developed to resolve was exaggerated. Since the original R2 Standard was drafted, the estimation of percentage of illegally exported electronics - the primary theory of waste externalization - has fallen dramatically. When R2 was first initiated, widespread press reports of 80-90% "sham" recycling were in the media. Actual studies of the exports, by Secretariat of the Basel Convention itself as well as by numerous universities, found a percent waste among used goods similar to brand new goods store refunds. The dumps identified by NGOs making the 80% claim were NOT primarily recent imports - they reflected the number of homes and businesses in the emerging markets which had TV stations, internet, cell phone towers, etc since the 1980s. In fact, developing countries reuse and maintain and repair the electronics 4 times longer than Americans.
2) The problem R2 was developed to resolve was for generators (cities, states, institutions) without the capacity to test or determine "waste" status to have access to reputable, certified recyclers. Any generator, consumer, or client is encouraged to send working, untested, or non-working electronics to an R2 Certified recycler audited to receive those materials. The generator need not test the equipment - that's what the R2 Certified Recycler is there for.
3) The problem R2 was developed to resolve was the "loophole" (actual or perceived) that would allow an R2 certified recycler to represent shipments of unrepairable scrap electronics as "working" or "repairable". While this risk was shown in the university studies above to be overstated, and while the original R2 Standard allowed companies to develop civil law contracts to protect buyer and seller, SERI increasingly interprets its role as referee in these "Ready for Repair" and "Ready for Reuse" contracts.
4) The problem R2 was developed to resolve was to make sure every recycler tests and labels every piece of equipment that enters and leaves the building, even if the shipment is to another R2 Certified Recycler. A company which had been testing a device, such as SVGA CRT monitors, for overseas purchase orders might want to cease the testing as the demand falls. It is a LIE that R2 is intended to prevent one R2 Recycler from clearing inventory by shipping the tested working, untested (scrap already removed) devices to another R2 Certified downstream specializing in those devices.
Italics and red letters added for the LIE. The R2 Standard certainly never intended to say that a generator can ship mislabelled devices to an R2 Recycler, but another R2 Recycler cannot.
My company received a non-conformance for doing number four. We appealed, and were told "it's so minor, just go along". Watch the consensus morph.
The two auditors, who cost us $24,000 a year, insisted that we could not send a mix of tested working and untested devices to another fully R2 Certified company with potential reuse markets, and known recycling processes, which we decided we had to outsource to because they were R2. We certainly could not send the mixed load outside of R2's circle. Sending untested/unlabelled equipment to a recycler is the same as sending untested unlabelled equipment to an end user? It's only a paperwork, labelling issue, we were told. Just re-label the stuff as non-working, even though you've tested it as working (but without a buyer).
Just another brick in the mission creep wall.
This was certainly not the intention of the original Responsible Recyclers consensus TAC. It adds more layers, more billable hours, more expense, more red tape, and adds zero environmental value whatsoever. And no one disputed that. No claim of environmental risk was made to us. The downstream R2 company will make whatever determination they will, regardless of how our staff label and track the material. The ones that were selling no longer paid for the labor we devoted to the selling directly to consumers (in part due to the rules R2 created for those sales, in larger part because of a new and better opportunity), so we give up and outsource. Obviously to an R2 company. But that's not acceptable, either?
This would mean that my company's own specialty - plasma, LED, and LCD large televisions - is problematic, as we get most of them "as is" from other R2 Certified Recyclers. We trade things that can be shredded (like printers or CRT TV chassis) for things those recyclers cannot safely shred.
The LIE is that this increasing level of bureaucracy solves any problem at all - or claims to, or pretends to. It is not about protecting consumers or the environment. It is either desire for authority, or a money making scheme for the auditors and R2. The incentive has been created for "spaghetti code", ever longer regulations that pass, to the layman, as improvement, but are instead a leach on environmental progress.
My company is in a state that actually makes us obtain R2 by law. We have no choice in Vermont. I believe this has created the Certification and Racketeering Problem which were 6 of the highest read the blogs accessed 2019. Here is a link to each, if you want to see the predicament Recyclers have created for ourselves, and who has profit motives to exploit the R2 Standard.
Fanaticism is a monster pretending to be the child of Religion.
The auditors admit that they lack the expertise to interpret the ever-increasing layers of rules and bureaucracy being created by the current SERI administration... leading to longer meetings and more billable hours. The current SERI leadership has shown some contempt for criticism, and is leading a charge to make changes sought by self-interested members of the TAC, who in turn make sure membership in TAC is held far below the 45 members in the charter. Most Technical Advisory Committee meetings have less than a quorum of the 45 in attendance, as they block nominations they know will be critical of the constraints they are creating.
When it comes to specialty items and specialization in the e-waste marketplace, the limitations on the number of Recyclers represented in the TAC ensures that the auditors do not know what they are talking about, and are making it up as they go along. They perceive their job as bringing "conformity" to a marketplace. And they are charging me as much as a full time staff person for it... and I have to pay FTE equivalent of another full time staff person to survive the next audit. And now SERI is insisting they have the right to stick GPS tracked devices to be handled by unwitting and unwilling participants - a clear threat to sabotage my company's reputation if I speak out about this.
Someone needs to call the FBI or the ACLU. In the meantime, contact me if you agree this thing needs a new set of brakes. It's for the good of the standard, it's rotting the same way other bureaucracies do. Nothing personal, you'll thank me one day if this causes some NEEDED INTROSPECTION.
Je suis le roi du je-m’en-foutisme!
SERI's R2 Standard gives prescriptions for electronics recycling practices. The practices are developed by the Technical Advisory Committee (TAC, the ongoing advisor team from the industry). The TAC standards, if passed by the SERI Board of Directors, create new rules (red tape) for Certified Recyclers to follow.
Without even a formal change in the rules, SERI can issue guidance to reflect a change in interpretation of the original rules. That's right, a TAC can act like a radical Supreme Court, with no tether to precedent. A clear example of this took place during this year's audit of Good Point Recycling, which passed 99% of the Audit with flying colors. However, the auditor called foul on a trade which passed R2 audits the previous 9 years... a trade that has taken place with the same downstream vendor for 17 years. A new "interpretation" of the old rules may cost my Vermont company $356,000 dollars per year, while achieving zero environmental benefit.
This is messed up. The rules have not yet been changed, but the "interpretation" of the old rules has.
Let's play a game. Three Truths and a Lie about the purpose of the R2 Standard.
 |
| As risk decreases, why must restrictions increase? |
2) The problem R2 was developed to resolve was for generators (cities, states, institutions) without the capacity to test or determine "waste" status to have access to reputable, certified recyclers. Any generator, consumer, or client is encouraged to send working, untested, or non-working electronics to an R2 Certified recycler audited to receive those materials. The generator need not test the equipment - that's what the R2 Certified Recycler is there for.
3) The problem R2 was developed to resolve was the "loophole" (actual or perceived) that would allow an R2 certified recycler to represent shipments of unrepairable scrap electronics as "working" or "repairable". While this risk was shown in the university studies above to be overstated, and while the original R2 Standard allowed companies to develop civil law contracts to protect buyer and seller, SERI increasingly interprets its role as referee in these "Ready for Repair" and "Ready for Reuse" contracts.
4) The problem R2 was developed to resolve was to make sure every recycler tests and labels every piece of equipment that enters and leaves the building, even if the shipment is to another R2 Certified Recycler. A company which had been testing a device, such as SVGA CRT monitors, for overseas purchase orders might want to cease the testing as the demand falls. It is a LIE that R2 is intended to prevent one R2 Recycler from clearing inventory by shipping the tested working, untested (scrap already removed) devices to another R2 Certified downstream specializing in those devices.
Italics and red letters added for the LIE. The R2 Standard certainly never intended to say that a generator can ship mislabelled devices to an R2 Recycler, but another R2 Recycler cannot.
My company received a non-conformance for doing number four. We appealed, and were told "it's so minor, just go along". Watch the consensus morph.
The two auditors, who cost us $24,000 a year, insisted that we could not send a mix of tested working and untested devices to another fully R2 Certified company with potential reuse markets, and known recycling processes, which we decided we had to outsource to because they were R2. We certainly could not send the mixed load outside of R2's circle. Sending untested/unlabelled equipment to a recycler is the same as sending untested unlabelled equipment to an end user? It's only a paperwork, labelling issue, we were told. Just re-label the stuff as non-working, even though you've tested it as working (but without a buyer).
Just another brick in the mission creep wall.
This was certainly not the intention of the original Responsible Recyclers consensus TAC. It adds more layers, more billable hours, more expense, more red tape, and adds zero environmental value whatsoever. And no one disputed that. No claim of environmental risk was made to us. The downstream R2 company will make whatever determination they will, regardless of how our staff label and track the material. The ones that were selling no longer paid for the labor we devoted to the selling directly to consumers (in part due to the rules R2 created for those sales, in larger part because of a new and better opportunity), so we give up and outsource. Obviously to an R2 company. But that's not acceptable, either?
This would mean that my company's own specialty - plasma, LED, and LCD large televisions - is problematic, as we get most of them "as is" from other R2 Certified Recyclers. We trade things that can be shredded (like printers or CRT TV chassis) for things those recyclers cannot safely shred.
The LIE is that this increasing level of bureaucracy solves any problem at all - or claims to, or pretends to. It is not about protecting consumers or the environment. It is either desire for authority, or a money making scheme for the auditors and R2. The incentive has been created for "spaghetti code", ever longer regulations that pass, to the layman, as improvement, but are instead a leach on environmental progress.
My company is in a state that actually makes us obtain R2 by law. We have no choice in Vermont. I believe this has created the Certification and Racketeering Problem which were 6 of the highest read the blogs accessed 2019. Here is a link to each, if you want to see the predicament Recyclers have created for ourselves, and who has profit motives to exploit the R2 Standard.
- Certification and Racketeering: Part 1 Ahmed Hussein Suale RIP
- Certification and Racketeering: Part 2 The Guardian Deceit
- Racketeering and Certification #3: Targeted Collateral Damage!?
- Racketeering and Certification 4: "Framing" the Export Market
Certification and Racketeering 5: Analysis of Seven GPS Tracking Studies
Fanaticism is a monster pretending to be the child of Religion.
-Voltaire
The auditors admit that they lack the expertise to interpret the ever-increasing layers of rules and bureaucracy being created by the current SERI administration... leading to longer meetings and more billable hours. The current SERI leadership has shown some contempt for criticism, and is leading a charge to make changes sought by self-interested members of the TAC, who in turn make sure membership in TAC is held far below the 45 members in the charter. Most Technical Advisory Committee meetings have less than a quorum of the 45 in attendance, as they block nominations they know will be critical of the constraints they are creating.
When it comes to specialty items and specialization in the e-waste marketplace, the limitations on the number of Recyclers represented in the TAC ensures that the auditors do not know what they are talking about, and are making it up as they go along. They perceive their job as bringing "conformity" to a marketplace. And they are charging me as much as a full time staff person for it... and I have to pay FTE equivalent of another full time staff person to survive the next audit. And now SERI is insisting they have the right to stick GPS tracked devices to be handled by unwitting and unwilling participants - a clear threat to sabotage my company's reputation if I speak out about this.
Someone needs to call the FBI or the ACLU. In the meantime, contact me if you agree this thing needs a new set of brakes. It's for the good of the standard, it's rotting the same way other bureaucracies do. Nothing personal, you'll thank me one day if this causes some NEEDED INTROSPECTION.
Je suis le roi du je-m’en-foutisme!
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