USA's e-Waste Tangle: R2, ISO 14001, and Basel

The US EPA has a program called Responsible Recycling (“R2”) Practices. R2 "is a set of [voluntary] guidelines for accredited certification programs to assess electronics recyclers’ environmental, worker health and safety, and security practices." An industry body, the Institute of Scrap Recycling Industries, Inc, has responded by launching its R2/RIOS certification program. But the situation is more complex.

Some e-cyclers have gone a step further and applied the ISO 14001:2004 international standard for Environmental Management Systems to their operations.

The Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal "is the most comprehensive global environmental agreement on hazardous and other wastes. The Convention has 172 Parties and aims to protect human health and the environment against the adverse effects resulting from the generation, management, transboundary movements and disposal of hazardous and other wastes." The US government has not yet ratified the Basel Convention.

The Basel Action Network (BAN) is an independent support group for Basel Convention. BAN has criticized R2and has launched, along with the Electronics TakeBack Coalition and other organizations, the e-Stewards certification program. e-Stewards incorporates ISO 14001.

What is a responsible American company to do? Each program currently lists ~5 certified recyclers in the US, so options are limited. A number of US companies with international stakeholders have publicly announced that they will use facilities certified by e-Stewards, although there is no information about the relative use of the two groups of recyclers. Conflicting messages slow adoption while e-waste is growing. We encourage the EPA and BAN to harmonize their standards and certifications.

Click on the "recycle" tag under this post's title to learn more about e-waste/cyberwaste, including dramatic photos.

R2, ISO 14001, or RIOS?

Anyone who needs free advice as to whether Rios, R2 or ISO 14001 is the right option for their organization, feel free to contact me at 847-635-0999 x4319. I am with Perry Johnson and have been working with these standards closely for quite some time.

e-Stewards or R2?

That's for you to decide. When you do---call me. My company AQA International can certify you to both standards. Please call and ask for Dennis: 800.281.4384

rios certification

Thanks for such a nicely written. Electronic Waste (e-waste)describes loosely discarded, surplus, obsolete, or broken electrical or electronic devices. In developing countries, it causes serious health hazards and polluting problems. in developed countries and USA EPA must agree that materials should be managed with caution.
rios certification

Fair Trade exports vs. Prohibition

While and their E-Stewards Pledge has the best of all intentions, they have committed the mistake of "perfect is the enemy of the good". There are very good repair and refurbishing factories all over the world, and there are many types of repair and refurbishing that the USA has no capacity whatsoever. Even BAN, in fact, has to accept CRT glass going to non-OECD CRT furnaces, because there are none left in OECD countries (and its a good thing BAN did close one eye on that recycling practice).

Just as Fair Trade Coffee realized that the "coffee boycott" hurt the farmers and that coffee cannot be grown domestically, R2 or Responsible Recyclers certification realizes that shredding things in the USA is by no means superior to repairing them in Indonesia, if the Indonesian factory is treated fairly, sent good material, and given environmental audits. R2 will succeed because it sees people, including people of color, for what they can do, not just for what they cannot do or did not do in the past. The usual way to harmonize these standards now is to abandon computer monitor refurbishing on the hierarchy in favor of shredding. Organizations like are exploring getting subsidized states like CA to test monitors prior to export to BAN standards. Moving an Indonesia factory to Mexico is another possibility. But I for one will not tell an Asian engineer who invented, designed, and oversaw manufacture of a CRT monitor that he can never recycle it due to his ethnicity. Doing so robs the developing country of a head start in establishing a recycling infrastructure for their own material, which is about to eclipse the generation of e-waste domestically.

e-Stewards vastly superior

Dear reader:

First of all the R2 Standard is not an EPA standard. The environmental community dropped out of the R2 negotiations after R2 became far too weak. It allows dumping hazardous equipment in landfills, allows prison labor to process toxic e-waste and private data, and it allows numerous loopholes by which e-waste can be dumped in developing countries. Please visit to see several comparisons between R2 and e-Stewards. And realize that while there are only 3 certified companies at the moment, there are already over 45 companies that have been audited by BAN to meet the basic requirements of the pledge. These companies are in the process of graduating to certification via third party audits but they are still highly recommended until then. Find them at

There are vast difference between these standards. Only e-Stewards can assure customers and consumers of truly responsible recycling. And of course, only e-Stewards requires ISO 14001 as part of it. Feel free to call ban and ask any questions about our program. We are happy to assist.

Sincerely yours,

Jim Puckett
Basel Action Network

Another point of view


Thank you for raising this question. I have been asking myself the same thing. I do believe that both standards ultimately want the same thing. The R2 standard is against electronic waste dumping (See 3.2, 5e, 5f, and 6 of the R2 standard), as R2 facilities and the auditors ensuring compliance do look for a sustainable and ethical vendors to work with. This means that a certified electronics collector needs to make sure that the recyclers, refurbishers, etc. they work with will not ship the materials to an underdeveloped country, and the facilities must keep three years of records for auditing purposes (See 7 of the R2 standard); instead, they need to ensure that the organization they work with is ethical and recycles the materials responsibly.

The purpose of R2 is not to mask improper recycling, but it is a legitimate standard which encourages refurbishment and reuse of materials before disposal (See 2a, 2b, 2c, 5e, and 5f of the R2 standard). This is a standard that will allow legitimate electronics refurbishers to receive a certification. While there are larger refurbishers with global operations (i.e. TechSoup Global), many are smaller mom-and-pop types of operations. Such organizations have a much smaller budget and may not be able to afford an expensive standard such as R2.

Personally, one thing I like about the R2 standard is that it does not offer organizational blanket certifications. With R2, individual plants or locations would have to be audited and receive certifications. This means that operations at each individual plant would have to meet the standards, which, in my opinion, offers an increased level of security.

In my opinion, the R2 and the e-Stewards standards are both very good standards with good intentions and ultimately common goals. If you would like to learn more about the R2 standard, I do highly recommend the following training - IT'S FREE! Perry Johnston Registrars offers a free R2 training (, and I have attended the training to get more educated on the standard and better understand it. The training is geared toward auditors, as PJR is an auditing firm, and the instructors focus on what the R2 standard says, how electronics recyclers, collectors, and refurbishers can meet the standard, and what someone should look for if they are auditing a facility. The training is a great educational tool, but in order to become an auditor of the R2 standard, much more information and training is required.

I know that a major concern that e-Stewards consistently raises is that R2 does not follow the ISO framework. While it is vague, R2 covers many of the same points that are included in the ISO 14001/18001 standard. If I get permission from PJR, I will share a document with you that I received at the training. I will keep you posted on that.

Matt, this is obviously a very contentious issue, as we have found out. Recently, one of our staff also wrote a blog ( pointing out a few things in Redemtech's comparison of R2 and e-Stewards (, and we received a lot of very good comments. This topic is obviously very heated at some points. But, in my honest opinion, I do think that both standards are good and ultimately ask for the same thing - responsible electronics end-of-life handling as well as increased environmental and social responsibility from our electronics manufacturers, recyclers, refurbishers, and collectors.

I think that it is very unfortunate that the work of many responsible and ethical recyclers and refurbishers is overshadowed by unethical organizations that use recycling and refurbishment as a cover for illegal export of electronic waste. In the spirit of "Why can't we all get along", I think it would be great for ethical electronics handlers to respect their differences between the standards and find a way to work together in order to mutually stop recyclers and refurbishers that dump their electronics.

R2/ISO comparison

In my previous post, I mentioned a comparison/parallel between ISO 14001 and the R2 standard. The document was created by Paul Johnson Registrars, Inc., and it is available online at:

be realistic

If everyone agreed that dumping, prison labor, and use of poor people in developing countries were bad ways to process e-waste, there would only be one certification: e-Stewards.

But since the EPA leadership has been weak, and since too many of ISRI's members wish to continue to profit by using fast-cheap-and-dirty business practices, they have invented a greenwash standard known as R2. It gives the impression of accountability with plenty of loopholes to allow bad actors to qualify.

Asking for harmony in this situation is naive. It is up to all businesses and individuals to decide which standard they want to apply for their toxic used electronics-- one that allows dumping, prison labor, and export to poor people (R2) or one that ensures complete responsibility (e-Stewards).

It's that simple. We hope everyone makes the right choice. 68 environmental organizations have made their opinion clear. So have major corporations like Samsung and Bank of America.

This isn't difficult to figure out.

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