IEEE Required – End-of-life processing requirements For all end of life equipment collected by manufacturer under :  The manufacturer must either provide evidence of participation in, or conformance to, a program sanctioned or required by the jurisdiction for the collection and recycling of the covered product in that jurisdiction;  Or must utilize initial service providers that achieve one of the following:  Initial service provider is certified to a qualified electronics recycling standard by an Independent Certification Body, such as “The Responsible Recycling (R2) Standard for Electronics Recyclers”, or “e-Stewards Standard for Responsible Recycling and Reuse of Electronic Equipment.”  If allowed by the qualified electronics recycling standard, the Initial Service Provider can demonstrate conformity to that standard as defined below.  Certification by an independent certification body to qualified electronics recycling standard  Second or third party audit reports indicating conformance to the qualified electronic recycling standard  “Independent Certification Body” is a body that has been accredited by a national accreditation body, and is a signatory to the International Laboratory Accreditation Cooperation (ILAC) Mutual Recognition Arrangement (MRA) or the International Accreditation Forum (IAF) Multilateral Recognition Arrangement (MLA).

Required – End-of-life processing requirements (cont.) A qualified electronics recycling standard shall either meet the following Minimum Technical Requirements a) through h), or meet Consensus Development Requirement i), below:  Minimum Technical Requirements a) The standard is applicable within the country(s)/region(s) being declared to, and is applicable to the scope of equipment covered by this criterion. b) The standard acknowledges that legal requirements have precedence to those within the standard. c) The standard includes a definition for “materials of concern” (or analogous term identifying materials with toxic or hazardous characteristics) and requires initial service providers to have a written management plan for these materials that protects human health and the environment. d) The standard requires that initial service providers shall maintain, review annually, and update as needed, an environmental, health and safety management system. e) The standard requires that material intended for reuse, repair, refurbishment, remanufacturing, recycling and/or disposal shall be transported in accordance with applicable trade and transporting laws of the exporting and importing countries. f) The standard requires the initial service provider to dispose of “materials of concern” in a hazardous disposal facility unless otherwise required by law or alternatively they may be incinerated in a waste-to-energy facility if the facility is designed and tested to demonstrate safe capture and/or destruction of such materials and their hazardous byproducts. g) The standard requires that initial service providers shall control, document and track the material flow of all equipment, components, and materials covered by the standard, that pass through its facilities. h) The standard requires initial service providers to track all “materials of concern” to final disposition, and to ensure that the downstream take-back service providers are meeting the requirements of items c) through h).  Consensus Development Requirement a) The standard (1) relates directly to the environmental impact of recycling electronics materials, (2) was developed or adopted by a voluntary consensus standards body 2, and (3) requires intellectual property (IP) relevant to the standard be made available by the IP owner on a non-discriminatory, royalty-free or reasonable royalty basis to all interested parties.

NSF End-of-service/end-of-life management In jurisdictions where manufacturer can control the selection of the initial service provider, manufacturer shall ensure that all registered equipment and, or components (including lease returns, warranty returns, trade-ins) forming the whole or part of the product covered by criterion are prepared for reuse and, or initially treated at a facility(s) operated by an initial service provider that is certified by an accredited certification body to one or more of the following standards:  EN Collection, logistics and treatment requirements for WEEE;  e-Stewards Standard for Responsible Recycling and Reuse of Electronic Equipment;  Responsible Recycling (“R2”) Standard for Electronics Recyclers; and, or  WEEELABEX Treatment Standard. Certification bodies shall be accredited by an International Accreditation Forum member accreditation body ( to certify to the specific standard identified. The NSF Joint Committee on the Environmental Leadership Standard for Servers may add standards to the above list of recognized standards, provided the standard meets requirements a) through i) in criterion of the IEEE Standard for the Environmental Assessment of Imaging Equipment.

12.1.2End-of-service/end-of-life management (cont.) In countries where there are no initial service providers certified by accredited certification bodies to any of the above recycling standards, manufacturers shall have 18 months before use of such certified initial service providers is required for conformance with this criterion. During that grace period manufacturers may, for conformance with this criterion, either:  Utilize initial service providers that meet requirements a) through i) in criterion of the IEEE Standard for the Environmental Assessment of Imaging Equipment, as confirmed through second- or third-party audits, or  Legally export taken-back equipment or components to a facility in another country that can legally import such materials and that is certified to one of the above recycling standard by an accredited certification body.

Directional Guidance Discussion  How should “qualified standards” be defined?  How should Initial Service Providers be qualified?  What should be the minimum technical performance requirements for a standard to qualify?  What equipment should be covered by the criterion?  Proposals for reconciliation of the equipment processing criteria?

Comparison of Key Differences Criterion ElementIEEENSF 1) Qualified Electronics Recycling Standards – the recycling standards that Initial Service Providers must be conformant with in order for a manufacturer to use their services to meet this criterion Meets minimum technical requirements a) – h) or Consensus development requirement Note: manufacturer’s technical performance specifications are eligible if they meet minimum technical performance requirements Provides list of qualified standards Additional standards can be added through NSF continuous maintenance process, if the standard meets minimum technical performance requirements of a) – i) 2) Approval/qualification process for Initial Service Providers to demonstrate conformance to the qualified electronics recycling standard Certified by independent certification body or 2 nd or 3 rd party audit findings Certified by accredited certification body with IAF accreditation 18 month grace period in countries with no certified ISP

Comparison of Key Differences Criterion ElementIEEENSF 3) Minimum technical requirements that a recycling standard must meet to become a Qualified Electronics Recycling Standard? a – h (modification of a- i) For example: f) The standard requires the initial service provider to dispose of “materials of concern” in a hazardous disposal facility unless otherwise required by law or alternatively they may be incinerated in a waste-to- energy facility if the facility is designed and tested to demonstrate safe capture and/or destruction of such materials and their hazardous byproducts. References a- i For example: g) The standard disallows the initial service provider from utilizing: Incineration and waste-to-energy facilities for materials that contain mercury, halogenated compounds, and beryllium, at a minimum. Non-hazardous disposal facilities for disposing of equipment, components, or materials derived from them, which contain “materials of concern,” except as required by law. 4) Equipment covered under this criterion End of life equipment All equipment collected by manufacturer, including equipment recovered under End of service and end of life equipment recovered under Includes warranty returns, lease returns and trade ins

Comparison of Key Differences Criterion ElementIEEENSF 5) When a manufacture must select an Initial Service Provider that meets a Qualified Electronics Recycling Standard If not participating or conforming to program sanctioned or required by the jurisdiction In jurisdictions where they have control over selection of Initial Service Provider

Directional Guidance Discussion  How should “qualified standards” be defined?  How should Initial Service Providers be qualified?  What should be the minimum technical performance requirements for a standard to qualify?  What equipment should be covered by the criterion?  Proposals for reconciliation of the equipment processing criteria?