Five Fundamental Flaws of the 2013 R2 Standard for Electronics Recycling

The Basel Action Network (BAN) recently released a critique entitled “Five Fundamental Flaws: A Concise Critique of the R2:2013 Standard.” It speaks to the loopholes caused by the ambiguity of the certification, but does mention that the overall implementation of the R2 certification has improved.

“We remain disappointed and very concerned with the substance of the Standard itself, which has change little from the initial version (R2:2008) published five years ago,” BAN stated.

The fundamental flaws of the certification stem from what appear to be intentional loopholes that facilitate social and environmental irresponsibility in the electronic recycling and asset recovery industry. The critique outlined the following flaws:

  1. R2 does not adhere to international hazardous waste trade laws that apply to the exportation of used electronics. These laws, established under the Basel Convention, have been adopted by 180 countries and are the legal waste trading framework practiced worldwide. Basically, the R2 certification has no provisions that prohibit the export of harmful toxic waste. This creates problems for developing countries where e-waste is being imported because they do not have the appropriate infrastructure in place to prevent harm to the environment and to the health of their communities. Enterprises that recycle their mobile phones, tablets and other electronic devices may be at risk of having their electronics discovered in overseas “toxic wastelands.”
  2. R2 allows recyclers to be certified without certifying all of the facilities operating under the company’s control. This presents serious issues because irresponsible, unethical recyclers can externalize costs by sending toxic materials that require expensive management to developing countries. These organizations do not have to adhere to any regulations regarding the disposal of e-waste, while the parent company can still claim R2 certification.
  3. R2 allows insufficient Environmental, Health, & Safety Management System (EHSM) to be substituted for the internationally accepted ISO and OSHAS standards. To remedy issues with earlier versions of the R2 standard, the requirement for an EHSM System was added to R2:2013. This is problematic because it falsely implicates that an EHSM system is equivalent to the comprehensive and internationally accepted ISO standards. R2:2013 also fails to define any measurement to qualify an EHSM system as being acceptable.
  4. R2 does not require ethical labor practices. Unfortunately, child, slave and prison labor are still common practices in the recycling supply chain worldwide. The R2:2013 Standard fails the test of being socially responsible by excluding any reference to minimum labor standards. The terms “labor” and “social accountability” do not even appear in the Standard. E-waste contains hazardous materials and sensitive data, so a truly responsible certification must strictly exclude such dangerous and unethical practices.
  5. R2 does not require satisfactory occupational health and safety protections. The Standard fails to require mandatory air testing and does not prevent the shredding of devices containing hazardous materials like beryllium, cadmium or mercury. These practices can cause irreparable harm to the health of workers in the e-waste industry.

R2:2013 Standard’s ambiguity and refusal to acknowledge the guidelines of the Basel Convention creates loopholes for irresponsible recycling. It provides unwarranted credit to electronics recyclers who deceive consumers and businesses by allowing them to believe their devices are being recycled in a secure and responsible manner.

It is imperative that businesses and individuals properly recycle their retired devices with a responsible electronics recycler. BAN, together with industry leaders, developed the globally recognized e-Stewards certification program in an effort to eliminate the growing e-waste problem.

e-Stewards is the only electronics recycler certification that strictly prohibits the export of toxic e-waste into developing countries, includes industry-specific worker health and safety requirements and bans the use of child, slave and prison labor. Using e-Stewards certified recyclers guarantees the highest standards of environmental responsibility, data security and worker protection are being met.

To download BAN’s full report, visit http: www.e-cycle.com/wp-content/uploads/FiveFundamentalFlawFinal.pdf.

To learn more about responsible mobile phone and tablet recycling, visit www.e-Cycle.com.

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