From the R2 Update Newsletter
The R2 requirement to track Focus Materials (FMs) includes whole electronic devices and components that contain FMs (circuit boards, batteries, mercury, CRT glass, and PCBs). SERI has witnessed some examples of flowcharts and lists of downstream vendors that cover FMs that have been removed from equipment, but do not list and track whole electronics and components that contain FMs.
Power supplies, for example, are an FM because each contains a circuit board. Therefore, when they are removed from desktops and sent to a downstream vendor for further processing, they must be tracked and due diligence is required to qualify the downstream vendors processing the equipment.
Provision 5(e) specifically states “that shipments of removed FMs, and shipments of equipment and components containing FMs” may only go to qualified downstream vendors that meet Provision 5(e) requirements.
Other examples of devices and components that are considered FMs and subject to Provision 5(e) include AC Adapters, optical drives, floppy drives, cable boxes, DVRs, modems, VCRs, DVD players, stereos, routers, telephones, cell phones, etc. Such devices, commonly referred to as “low value” or “consumer” electronics, are typically sent to shredders for materials recovery. This stream of equipment must be controlled as each contains at least a circuit board.
Bottom line: Used electronics likely contain FMs, and therefore, if they are untested or non-working they must be tracked just like any other FM to qualified downstream vendors.
