In addition to the summary above from Corey Dehmey regarding the R2v3 process, ISRI submitted comments to SERI focusing on three main areas: definitions including the definition of recycling and co-location facilities, downstream vendor qualifications, and the R2 equipment categorization document (REC). ISRI also provided substantive suggestions to address the concerns with those specific issues.
Prior to the May 20 filing deadline, ISRI hosted two public meetings for recyclers to discuss the new version of the standard directly with the SERI staff. The first meeting was at ISRI’s Board Meetings in Austin, Texas in January and the second one was at the ISRI Convention in April in Los Angeles. Both meetings were well attended and many issues were discussed. Because of these two substantive meetings, our comments were focused on three main areas. ISRI members were encouraged to submit their own comments focusing on company-specific issues. Nearly 500 comments were received! The R2 Technical Advisory Committee will meet in mid-June to review all the comments and determine whether enough substantive changes are necessary to warrant a second draft complete with a public comment period. If not, the standard will be finalized by the end of 2019.
In our formal comments, we did state that the public meetings were very useful and helped ISRI’s members better understand the changes and make positive suggestions to help improve the standard, make the standard more flexible and ensure better compliance. ISRI was at the beginning of the R2 standard and wants the standard to continually improve and respond to the changing dynamics of the electronics recycling industry.