What are the R2:2013 Focus materials?
The R2:2013 standard requires recyclers to document any movement of used and end-of- life equipment that is likely to qualify as a Focus Material or hazardous waste. The R2:2013 Standard identifies as Focus Materials any end-of-life electronic equipment and/or electronic assemblies that contain hazardous materials:
A. Polychlorinated biphenyls (PCBs)
C. CRT glass (with some exceptions)
E. Whole or shredded circuit boards containing lead solder
In several important respects, R2:2013 adopts more detailed obligations exceeding the Basel Convention or national legislation in many countries. For example, R2:2013’s broad references to PCBs, mercury, and batteries in the definition of Focus Materials are broader than the component listings identified in the Basel Convention A1180 listing.
Also, R2:2013 removes some of the ambiguity related to the Convention’s non-hazardous waste listing for waste electronics by designating circuit boards containing lead as Focus Materials requiring more stringent management and export controls. (The Convention lists printed circuit boards under the non-hazardous B1180 waste entry in Annex IX – presumptively non- hazardous.)
R2:2013 also imposes requirements for recyclers to document the legality of importing or exporting Focus Materials contained in so-called “untested or non- functioning equipment.” As noted further below, untested used equipment destined for repair, refurbishment and reuse is generally viewed as non-waste that is outside the Basel Convention, although this issue is the subject of ongoing discussions among governments. Obligations to assess untested or end-of-life equipment containing Focus Materials apply to shipments for recycling within the Organization for Economic Co-operation and Development (OECD) area, despite the fact that the Basel Convention does not apply to such shipments, and OECD countries may not regard some of these materials as wastes subject to stringent regulation.
Furthermore, R2:2013 mandates that an electronics recycler “comply with all applicable environmental, health and safety . . . legal requirements . . .” This broad requirement ensures legal compliance includes consideration of differing approaches governments have taken to the classification and control of e-waste shipments, including imports and exports.
In conclusion, certification to R2:2013 requires recyclers to document the legality in the importing, exporting and transit countries of any movement of used and end-of- life equipment that is likely to qualify as an A1180 hazardous waste. The R2:2013 Standard’s special attention and obligations for importing and exporting Focus Materials correctly directs the attention of recyclers to those materials often regarded as “hazardous wastes” under the Basel Convention. The more general obligation to comply with applicable legal requirements ensures that in those instances where a government may choose to regulate a broader universe of used or end-of-life equipment as hazardous, such requirements are identified and addressed.