The R2 Certification program is built on a third-party certification model, with a deliberate separation of roles between SERI and the Certification Bodies (CBs) that audit and certify facilities to the R2 Standard. As part of this separation, SERI relies on Accreditation Bodies (ABs) to oversee the qualifications and performance of CBs and doesn’t arbitrate disputes between any of the parties. This third-party certification scheme structure brings several advantages – one of which is a checks and balances structure that’s supportive of nonbiased and fair outcomes – but it can also lead to confusion about where complaints should be directed when disputes arise. Just like SERI doesn’t make any certification decisions, the complaint outcomes are primarily managed by the CBs as well.

The following Q&A is intended to help provide clarity about who folks can appeal to when disputes arise with auditors, CBs, consultants, facilities, and ABs.

Disclaimer: It is important to understand that SERI does not make decisions related to the certification processes outlined in the Code of Practices. Certification decisions are managed and determined by the Certification Bodies. 

Q: An R2 Facility has a complaint about the Certification Body auditor who conducted the R2 audit. Who should be contacted?

Complaints about Certification Body auditors should be directed to the Certification Body (CB) that employs or has contracted with them. The CB’s role is to ensure their auditors are performing R2 audits in accordance with the R2 Code of Practices, the auditor training provided by SERI, and other guidelines established by the CB. When concerns about auditor performance arise, the CB is expected to investigate the matter and take the necessary steps to remedy any performance issues.  Most CBs have a website where a customer complaint can be filed. 

Q: An R2 Facility has a complaint about a CB. Who should the R2 Facility contact?

Complaints about a CB should be directed to its Accreditation Body (AB). The role of the AB is to assess the quality and competence of the CBs and ensure that they conduct audits and issue certificates in accordance with the IAF (International Accreditation Forum) requirements that govern CBs, and in accordance with the program requirements for the R2 Certification Program found in the R2 Code of Practices (COP). The AB’s role is to investigate complaints filed against a CB that it has accredited and take the necessary actions to remedy performance issues, including training, suspension or even loss of accreditation, depending on the nature of the issue.  The CB’s Accreditation Body can be found on the SERI website. Most ABs have a website where a customer complaint can be filed.  

Q: An R2 Facility does not agree with a nonconformity (NC) issued by the R2 auditor. Who should the R2 Facility contact?

If an R2 Facility disagrees with an NC issued by its auditor, the facility should initiate a dispute with its CB. Each CB has a dispute process for reviewing and determining the validity of an NC. The CB dispute process will choose independent and objective parties to determine the validity of the NC. SERI does not participate in the CB dispute process.  

Q: An R2 Facility is involved in a dispute with its CB regarding an NC. Can SERI intervene?

SERI firmly believes that impartial Certification Body audits benefit both facilities and their customers. For this reason, SERI does not intervene in or overturn Certification Body decisions about specific audits or nonconformities. If an R2 Facility has a dispute with a CB, the proper recourse is to file a complaint with the AB for the CB. The CB’s Accreditation Body can be found on the SERI website. Most ABs have a website where a customer complaint can be filed.

While it is outside of SERI’s role to overturn decisions made by a CB, it is acceptable for an R2 Facility or Certification Body to contact SERI for clarification about a specific R2 requirement. Keep in mind, however, this clarification is limited to the R2 requirement – it is not an evaluation or determination of the disputed issue or the R2 Facility’s specific operation. 

Q: What if an R2 Facility does not agree with a CB’s verdict in a dispute? 

If an R2 Facility does not agree with the final verdict in a dispute with a CB, the proper recourse is to file a complaint with the AB for the CB.  The CB’s Accreditation Body can be found on the SERI website.  Most ABs have a website where a customer complaint can be filed. 

Q: What if an R2 Facility’s NC is related to an active Formal Interpretation being reviewed by the R2 Technical Advisory Committee (TAC)? 

If an NC is written to a requirement that is being considered by the TAC for a Formal Interpretation, the CB can extend the deadline for the closure of that NC to the next scheduled audit or until the Formal Interpretation is released, whichever comes sooner. The extension of the closure timeline will not be applied to other NCs issued during the same audit. 

Q: An R2 Facility’s certificate was suspended. Can SERI overturn the CB’s decision? 

SERI does not overturn Certification Body decisions about suspensions. If an R2 Facility has a dispute with a CB, the proper recourse is to file a complaint with the AB for the CB.  The CB’s Accreditation Body can be found on the SERI website.  Most ABs have a website where a customer complaint can be filed. 

Q: An R2 Facility disputes its CB’s decision to revoke the facility’s R2 certificate. Can SERI reinstate it? 

SERI does not involve itself in certification decisions.  SERI solely reports the status of certificates. The CB is responsible for decisions related to certificates. As a result, SERI cannot reinstate a certificate. The R2 Facility can dispute the decision of a revocation by filing a complaint against the CB with the AB that has accredited the CB. The CB’s Accreditation Body can be found on the SERI website.  Most ABs have a website where a customer complaint can be filed. 

Q: An external party has a complaint about an R2 Certified Facility. Who should be contacted?

Complaints about an R2 Certified Facility should be sent to SERI via the Contact Us page. SERI will review all complaints for merit and share the information with the CB that issued the R2 Certificate for the R2 Facility. 

It is the role of the CB to take the lead in R2 Facility complaints and to work closely with SERI during the investigation process. The CB is expected to adhere to the timelines prescribed in the R2 Code of Practices to address the complaint. Additionally, as part of SERI’s ongoing Assurance Program, SERI may conduct its own review of the R2 Facility’s previous audit package(s) and/or conduct a spot inspection of the R2 Facility.  SERI communicates the results of the reviews to the CB investigation. The investigation may lead the CB to issue NCs or to suspend or revoke the R2 Certificate, depending on the severity of the issue. Also, if the complaint is egregious and deemed valid based on the investigation, SERI can terminate the R2 Facility’s SERI License Agreement, thereby preventing an R2 Facility from obtaining or maintaining R2 Certification.  SERI may also require the R2 Facility to sign a Probationary License Agreement. 

Q: Where does a complaint related to a consultant listed on the SERI Consultant List get directed? 

Complaints about a consultant listed on the SERI Consultant List should be sent to SERI via the Contact Us page. The SERI Consultant List is available here: Find A Consultant – SERI (sustainableelectronics.org). SERI will review all complaints that have merit and determine a course of action.