Q: What does Appendix G(2) mean by managing PV modules under the same R2 requirements that apply to electronic equipment?

A: Appendix G(2) expands the applicability of R2 requirements for electronic equipment to include PV modules. This means that references to electronic equipment in both the R2 Core and Process requirements now apply to PV modules.

The following is a summary of some of the key Core Requirements that apply to all R2 Certified Facilities controlling PV modules (remember that Core 1-10 and any Process Requirements carried out by the R2 Facility for PV modules are applicable):  

Core 4-Legal and Other Requirements  

• R2 Facilities must identify in their legal compliance plans all laws and regulations related to transboundary shipments of electronic equipment, components and materials and include evidence demonstrating that the R2 Facilities’ inbound and outbound shipments comply with those legal requirements from the importing, transit and exporting countries.  

• Facilities controlling PV modules must include all EH&S requirements that are applicable to their operations in their legal compliance plans.  

Core 5-Tracking Throughput  

• Because the electronic equipment requirements now apply to PV modules, all R2 Facilities controlling PV modules will need to capture and maintain accurate inbound and outbound PV module shipping records with the detailed information specified in Core 5. Keep in mind that these requirements apply to any PV modules under the R2 Facility’s “control.” Control can mean brokered transactions where the facility does not physically receive the PV modules, or transactions where the facility is performing a contracted service but does not have ownership of the PV modules. In all cases, regardless of physical possession or ownership, R2 Facilities are required to maintain accurate and detailed inbound and outbound shipping records.  

• Core 5 requirements related to inventory tracking and management also apply to PV modules. R2 Facilities must maintain records that accurately reflect the quantity of PV modules through all steps that may be occurring at a facility, including receipt, processing, storage, and shipment.  

• Core 5 also places limits on the amount of PV module inventory that can be on site. Specifically, Core 5(b)(2) limits PV module inventories to below defined legal limits and in accordance with the R2 Facility’s closure plan and financial assurance.  In circumstances in which PV modules are considered negative-value equipment, which is usually the case for end-of-life modules, Core 5(b)(3) restricts their storage to no more than one year, with some limited exceptions.  

Core 6-Sorting, Categorization, and Processing  

• R2 Facilities must evaluate all electronic equipment, including PV modules, for reuse potential, taking into account the level of functionality, physical condition, and value of the PV modules in the destination market.  

• Facilities must manage PV modules as R2 Controlled Streams, recategorizing them as they proceed through reuse or materials recovery processes and are no longer an R2 Controlled Stream. PV modules received by a facility are an R2 Controlled Stream, but once they’re tested, confirmed functional and assigned one of two R2 Equipment Categorization (REC) guide categories for PV modules, they can be recategorized as Functional Product that is no longer subject to R2 downstream controls. Likewise, end-of-life panels are an R2 Controlled Stream, but the materials stemming from materials recovery processes may necessitate recategorization as an Unrestricted Stream once they achieve one of the materials recovery conditions described in the R2 Definitions section for Focus Materials. Keep in mind that the above-mentioned reuse and materials recovery processing may occur at the R2 Facility or at one or more DSVs. 

Core 9-Facility Requirements  

• R2 Facilities must establish a written plan for closure of the facility in the case of an unplanned closure or abandonment. Because requirements for electronic equipment are applied to PV modules through Appendix G(2), that closure plan must address which commercial businesses will manage the remaining PV modules in the event of an unplanned closure.  

• Along with the closure plan, Core 9 also requires the facility to establish a financial instrument to pay for the closure and cleanup work. The expected inventories of PV modules must be addressed in that closure plan and factored into the value of the financial instrument that’s established.   

Appendix G also triggers the applicability of various Process Requirements, depending on the process(es) performed by the facility. A summary of key Process Requirements to note is as follows: 

Appendix C-Test & Repair requirements apply if the facility is planning to test and repair PV modules. 

Appendix E-Materials Recovery requirements apply if the facility is conducting any further processing of PV modules that are not capable of reuse. 

Appendix F-Brokering requirements apply if the facility is planning to broker PV modules. 

Appendix A-Downstream Recycling Chain requirements apply if the facility is planning to send any R2 Controlled Streams to a downstream vendor (see the Part 1 Q&A for a discussion of downstream vendor management for PV modules).   It’s important to note that if an R2 Facility determines that any damaged, aging or otherwise obsolete PV module has no reuse potential, then it’s very likely that the facility will have to rely on downstream vendors (DSVs) to process the materials to final disposition. We’ll discuss the recycling requirements for PV modules in subsequent Q&As.  

In summary, extending the R2 electronic equipment requirements to also cover PV modules triggers a number of requirements for PV modules. These include, but are not limited to, ensuring legal compliance for all shipments, maintaining detailed shipping and inventory records, and addressing PV modules in the closure plan and financial assurance. Additionally, facilities must evaluate PV modules for reuse potential and categorize them appropriately according to the REC throughout the processing steps. Finally, it’s important to understand that all relevant R2 Process Requirements also apply to PV modules. Those various appendices apply to PV modules depending on whether the facility is shipping PV modules to DSVs, testing and repairing them in-house, performing materials recovery on-site, or brokering PV modules.