The 3 Challenges Sharon, an E-waste Recycler, Faces with the R2 Standard

By ,

By: Sharon Tansky
EHS Coordinator, 100% Environnemental


Certifications….. necessary for most industries, optional for some but mandatory for Electronics Recycling!


R2 Challenges

About My Company, 100% Environmental

A pioneer in the industry, 100% Environmental, located in Montreal, Quebec, started electronics recycling in the late “00’s” with minimal resources and a passion to ensure the safe disposal and dismantling of electronics.

Resources and technical “know how” were hard to come by, and the company’s President, Anthony Salvatore, made it a mission to learn as much as possible by attending various conferences and travelling to downstream facilities.

With incredible foresight the company has been ISO 14001 certified since 2012, and RQO since 2014.


About Me

Starting up as a newbie in the electronics field I came on board to help manage the certifications.

Our small company has had at least 8 certification audits in 2 years! As a bonus, the ISO 14001: 2004 standard was revised to 2015 (the revision audit is mandatory by September 2018) and we had to change our certification auditors as ours could not secure us an R2 auditor by the deadline, resulting in a bonus certification audit instead of a surveillance one.

The RQO certification already incorporated some of the demands of R2, but many were new, including the OHSAS health and safety certification. Yes, a whole new certification to be certified!

Managing all this required extensive use of resources, notably online research, consultants, peers and Nimonik.

Nimonik proved to be very useful for all our standards as a tool to track changes to legislation, providing a list of laws that we need to track while making our audits easy. My favourite part is the audit templates which provide a user friendly version of the standard internal audit template. The information is input online and a report is created in seconds.


My 3 Challenges with R2

We have now been R2 certified for over a year, passing the S1 surveillance audit. The R2 has been in revision mode for the past couple of years and a new standard is expected within the next while. The R2 standard is unique with an informative website with a wealth of information and templates for many documents. The guidance document is extensive and provides clarity on the standard.

Through all this I have made the following observations:

Getting companies on board is one of any certifications challenges, and R2 also faces the challenge of getting the consumer on board as they are the end user of electronics.


I will discuss 3 main challenges that we face at our facility:

1) Downstream vendors;

2) Miniaturization of electronics; and

3) Reuse

1. Downstream vendors

Provision 5 of the R2 standard states: R2:2013 electronics recycler shall manage – both on-site and in the selection of downstream vendors – the Focus Materials (hazard materials) that pass through its facility or control in a manner protective of worker health and safety, public health, and the environment.

Unlike the previous standard(RQO) we followed, we were now welcome to find our own downstream vendors, audit them ourselves and prove they were in compliance with the standard even if they were not certified themselves.

However, to be an approved down stream vendor before the first R2 audit a company has to demonstrate they have already sent materials to that company, and have proof such as BOL’s.

Getting a private company to send out this information before a company becomes a client is challenging, to say the least.

The challenge we face is in the manpower. Auditing other companies requires time, trained personnel, often perseverance and the talent known as “sucking up”. Not every company has a dedicated EHS coordinator, and some offer a service unique enough that they are so busy and no longer want to deal with individual companies.

One way R2 can help is with dedicated industries. For example, there are just a few companies that recycle CRT glass or mercury bulbs. Yet every individual recycling company has to do an audit on the very same companies that are R2 certified themselves (The audit is shorter than an audit for a non R2 certified company but still rather comprehensive).

I strongly believe in these cases R2 can provide a short list of companies approved and audited by them, and the only onus on the recycling company would be to ensure the downstream vendor is not in violation with their R2 certification and that the downstream vendor processes things in accordance to the company’s own policies.


2. Miniaturization of electronics

Miniaturization of electronics is the buzz word in the industry.

As electronics get smaller, not made to last, more is getting disposed. As opposed to my parents buying the computer in 1990, today’s consumer purchases items with no intention on it lasting, anticipating when the new one will come out to replace it!

From a dismantling point of view newer electronics require more time, with less material value.

Removing the hazardous material, such as small LEDs from lap tops is extremely challenging.

The other problem from the miniaturization is the payout from Stewardship programs. This program should adapt to the newer electronics. The older model of paying by the weight is not reflective of the newer electronics which are much lighter but more labour intensive.


3. Reuse

Lastly, Reuse.

R2 website states: “Reuse is widely recognized as the most environmentally beneficial form of materials management.  Repairing and reusing electronics extends the useful life of products and keeps them out of the waste stream.  It also recovers more value per unit than any other form of materials management.  Not only that, reusing electronics devices reduces the need to manufacture new units, and makes affordable electronics more accessible to a wider range of consumers.”


While I can’t argue the theory behind the statement, from a practical point of view there are several problems.


For starters, these units will still end up in the recycling stream within a few years, and unless the whole industry magically has an overhaul, it is hard to change consumers’ habits who demand new and trendy electronics.

The clients using the refurbished electronics in developing countries were probably not purchasing that over new ones, I feel it is doubtful that this will decrease manufacturing of new units.

As technology keeps improving and changing so quickly, and the price points keep dropping, consumers do not need to consider used models. The exceptions are the high end models, especially anything Apple, which consumers buy and sell several times.

R2 is very stringent in requiring a detailed complicated process in place for a company to sell its electronics to the reuse market.

One solution is for a recycler to pair up with a refurbisher, but with the industry still in the pioneering stage there are very few companies to choose from to work with in most areas.


Until everyone is on board from the manufacturing, the sellers and finally the consumers I believe the reuse market is very limited and cannot be fully explored.


A Brief History of our Industry
(You Must Know)

Electronics recycling industry is fairly recent. It did not exist prior to the 2000’s. Growing up in the 80’s and 90’s this industry was not even listed in the career placement programs!


The Technological Revolution

  • In 1990’s, given the cost of a computer, which was over a grand (that’s the equivalent of today’s $2000), not including the cost of software and printer, no one was giving their electronics up for recycling that quickly.
  • VCR’s, SONY Walk Mans, camcorders, Nintendo NES…. Disposable electronic devices were unheard of
  • Taking an educated guess most manufacturers must have not considered the recycling aspect of their products.


There was no Environmental Handling fees, recycle my electronics program, e-waste collection sites; and people kept everything as it was valuable!


  • Fast forward through the 90’s, when technology rapidly progressed making things obsolete.
  • Walkman’s became portable CD players, MP3 players, and eventually iPods
  • VCR’s became DVD players, then Blu Ray, then PVR’s
  • The big clunky computers are gone
  • Cell phones have replaced all kinds of digital cameras and cell phones themselves have undergone transformation too many times to count.
  • Many households don’t even bother with a land line anymore!

But this technological growth has created a huge problem.


While the pioneers of this industry walked into an unregulated gold mine, where money was made without stewardship programs or handling fees; today’s electronic waste handler is in a very different position.


Early Days of the Electronics Recycling Industry

Initially, many electronics, especially computers, were sent overseas. China and India were the main recipients, eventually leading to an export/ import ban from China.

Entrepreneurs were able to buy monitors, computer consoles & other materials and send it overseas to get paid (quite nicely) for their efforts.

While some reuse took place, these materials were mostly dismantled for the precious metals housed in electronics. The older the computer the more precious metals it contains: gold, silver, platinum, copper; Oh my!!!

To boot, metals were worth much more than today on the commodities market.

The remaining parts (most of the device!) was discarded to landfill. There were no safety measures in place to handle the risks associated with dismantling devices that contain lead, cadmium, beryllium, flame retardants, and batteries housed in the mercury bearing bulbs, CRTs (Cathode Tube Rays), casing and memory boards.


The Birth of the Recycling Program

The beginning of responsible recycling in Canada was established in 2004, when Canada’s electronics industry – comprised of manufacturers and retailers – demonstrated leadership and foresight and developed the first Electronics Recycling Standard (ERS) as a means to prevent illegal exporting of e-waste.

ERS ensured proper controls (environmental, health and safety, data security and handling of materials) were in place to appropriately manage the risks associated with processing of EOLE.

The next ten years saw the advent of various regional, industry-led electronics stewardship programs across the country, and in 2011 the electronics industry brought these programs together to create the Electronic Products Recycling Association (EPRA)


The Arrival of R2

R2, (the premier global environmental, worker health and safety standard for the electronics refurbishing and recycling industry) published its first edition in 2008 and revised to its current version in 2013. The standard demands a company to be first ISO 14001 and OHSAS 18001 or RIOS (Recycling Industry Operating Standard) certified. From its humble beginnings, R2 now has over 730 facilities in 30 countries.

Its growth is partially due to the awareness and the demand of clients to deal with companies that are certified, and the integration of R2 into other standards like the RQO, where it became mandatory by December 2016 to be R2 certified to keep RQO status.

All this to say, the industry has come a long way, but there is still much more to be achieved and many problems to solve.

In conclusion, although the industry comes with its challenges we have come very far in just a few decades. From the creation of products and consumer demand, to great increases in technology, electronics are part of everyone’s everyday life. The continuing challenge is to ensure the devices are recycled properly but first must find their way to the recycling plants!