No.

The DFFE policy is that the producer contributes to a system of electronic waste recycling that includes building
a collection system, public awareness, jobs and training etc. This expands the scope of producer responsibility
beyond the specific recycling of only your products put on market. The R2E2 National Collection Model project
as well as our collaborative public awareness and jobs training creates this shared compliance for all our paid
up members. R2E2 has taken this up with DFFE and we will continue to table this point at each relevant
interaction with them.

Should you not meet your recycling target but still want to be compliant, you may purchase weights within
your product category that are unidentifiable i.e products that does not have a brand name or number on it.
These weights are purchased and allocated to your weights to achieve your compliance target.

When any Producer indicates an interest in joining R2E2 we schedule an onboarding session which lasts 1
hour. In this workshop/meeting our team presents the vision of R2E2, our full service offering and outlines the
procedures of verification of recycled e-waste volumes, compliance with the legislation, reporting and how
recycling costs are determined and managed. Thereafter once a new member joins, we implement these
arrangements and adjust where necessary based on feedback from a producer member.

The fees are set according to the category of electronic waste. R2E2 bases its EPR fee on the total put on the
market weight, as instructed by DFFE (Also see question number 2). This fee is currently R1,50 per kilogram.
Furthermore, producers are charged a separate recycling fee for materials actually recycled by a recognised
recycler. In terms of the WEEE sector, the recycling fee is based on the non-recoverable weights which are
negative fractions. These fees are paid to R2E2 who then pay the recycling fees to the recycler whilst the EPR
Fee collected by R2E2 is used to fulfill mandated obligations as legislated.
Please see appendix A for the breakdown of fees.

Through the track and trace system as explained in questioned 8 below.

R2E2 e-waste recyclers use different Track & Trace (T&T) systems but all basically deliver the same results. A
picture of the producer’s product is taken when received (either per unit or batch, depending on the
producer’s requirements). The item description, weight, EPR grade and serial number or barcode is added
(depending on the producer’s requirements). This information is entered into a web-based database that is
used to track the product through the total recycling process. The customer (producer) has access to this
customer data via a R2E2 supplied web portal, R2E2 also uses the T&T system for desktop audits to verify the
process for the customer. Additional options are available in the T&T system, including customer mobile
recording, payment, and cost breakdown, EPR data transfer to customers’ database system.

Billing will be done monthly. However should your organization requirements differ, we will adhere to your
time frames. At the end of each month an invoice will be sent out to the client to process and approve. Clients
are given two days to verify the weights invoiced. Once verification is complete the client is expected to make
payment to R2E2. Should any delays occur in a given month, the invoice will then be consolidated in the
following month. However, it should be noted that continued non-payment could ultimately lead to non-
compliance and an adverse finding reported to DFFE.

When a client requests a collection of materials, R2E2 will arrange the collections through one of their
recycling service providers who will then proceed with the recycling process. Thereafter the recycler is to send
a report to R2E2 with the weights recycled.

The customers’ product is identified and recorded using the T&T system, the weight for recoverable and non-
recoverable fractions are recorded, and the customer is charged as per the R2E2 pricing sheet. Once the
recycler has completed the process R2E2 verifies the outcome via a desktop audit using the T&T system. This
process confirms the brand name, weight, recoverable outcomes, collection location, description, and
recycling fee. The customer can, if required, audit the process remotely using the pictures to verify the EPR
service, alternatively R2E2 verifies the customers EPR service via the T&T system. The fulfillment of mandates
are explained in question number 3.

Yes, if the producer wants to, this is achieved via the T&T system. The producer can (if required) pay for more
than its own product weight if (for example) the producer requires more weight to meet its annual EPR
recycling target. This is left up to the producer to decide, R2E2 and its recyclers don’t apply a generic
compliance weight to the producer, and the producer is always in charge when it comes to accepting payment
for the recycled e-waste.

This applies to electronic waste in the WEEE sector. R2E2 manages these costs via the recyclers’ mass-balance
process and the T&T system. For material supplied, collected, or sourced by the producer, the producer only
pays for the non-value fractions of the producer’s product, as per the legislation. For material collected and
bought by the recycler (from consumers) the producer pays as per the R2E2 price list, with no offset for value-
fractions. The recycler collected weights are added to the producers annual EPR weights.

Producers may join more than one PRO. R2E2 has taken legal opinion on this matter and have confirmed that
the EPR legislation does not prohibit membership of multiple PRO’s.
This is an important fact to note as it allows individual companies to choose which PRO to join based on their
real experience of costs incurred and actual services delivered.
R2E2 also believes that any producer member should have the unrestricted freedom to leave at any time if
they see greater benefits in joining another PRO. In addition to this, in terms of the legislation, a producer
may also elect to establish its own PRO and manage it and their recycling process if they chose to do so.

Yes, if the producer wants to, this is achieved via the T&T system. The producer can (if required) pay for more
than its own product weight if (for example) the producer requires more weight to meet its annual EPR
recycling target. This is left up to the producer to decide, R2E2 and its recyclers don’t apply a generic
compliance weight to the producer, and the producer is always in charge when it comes to accepting payment
for the recycled e-waste.