ABCDEFGHIJKLMNOPQRSTUVWXYZ
1
Electronic device refurbishing Methodology V2.0Methodology ID: RIV-REC-01-ELEC-V2.0
2
Public consultation collected comments and responses
Public Consultation period:
April 24th 2024- March 24th 2024
3
AuthorCommentTypeRiverse responseAny change made?Status
4
Guillaume AUDRAIN- ecosystem3.5 Baseline scenario / p16
Use phase is not considered in the LCA scope yet it is a risk identified as a reused product may overconusme compare to a product from new generation. In the case of smartphone PC laptop and tablets it may not influence the outcome but question would be different if discussing about other type of EEE.
TechnicalIndeed we deemed the use phase 1) not impactful enough and not different enough between new and refurbished to justify including in the calculations, and 2) too variable and based on individual consumer behaviors that we have no visibility on. We will be sure to look at this more closely if/when we add other types of electronic waste to the methodology. NoRejected
5
Guillaume AUDRAIN- ecosystem[from previous comment, split to new row] This relates to another point I have regarding the (W)EEE categories and typologies covered by this projet. Why selecting a market of reconditionning already in place on which rebound effect is a major risk identified as well ?TechnicalWe agree that the rebound effect poses a large risk, but refurbishing these types of devices is still valuable. The rebound effect is not larger than the avoided emissions. In this revision, we have taken major steps to account for the rebound effect by accounting for residual value in used devices, and considering the market share of refurbished devices in the baseline scenario.NoValidated
6
Guillaume AUDRAIN- ecosystem1.2 / p5
Why restricting the eligibility to only smartphones, laptops, tablets, desktop computers and screens ? The market's already grown and besides the fact that it is always better to increase product lifetimes there is a risk of higher rebound effect which could requestion the benefits of the project. I would recommend to consider other (W)EEE categories as well on which reuse activities need a bigger support.
GeneralWe would be happy to include other WEEE categories, but we are most limited by data on the refurbishing process (i.e. material and energy inputs), which we need for the GHG reduction calculations. Project Developers don't tend to track this process closely, so for now we take it from the literature. We have good literature resources for the devices mentioned. With sufficiently reliable data, we would consider other WEEE categories. NoValidated
7
Guillaume AUDRAIN- ecosystem1. Eligible technologies / P5
Rebound effect is an identified risk and was stated in a dedicated section in the document "Reconditioning of electronic devices" V1.2 section C10. Looking at the change log and arbitrary decisions it was decided to not consider rebound effect part of the LCA scope. Yet to me this is a risk to be evaluated specifically for the smartphone market on which 1st product lifetime may be much lower than expected compared to a theoretical lifetime.
GeneralRebound effect was not considered in the LCA scope even in V1.2, it was considered via a qualitative risk assessment. In the current version, this qualitative risk assessment for rebound effect has been moved to the Environmental and Social Do No Harm category. This was because we decided to remove Rebound effect as a general criteria for all technologies under the Standard Rules because it is not relevant for many of our technologies/methodologies. Instead of fully removing it from this methodolology, we moved it under a different criteria.
We were indeed concerned with including the fact that smartphone's first lifetimes might be shorter when there is a refurbishment/buyback market available. We feel that this is well captured in the allocation of residual value to used devices that only undergo "light refurbishment", indicating that they were in good working condition when they were disponsed of from their first product life.
NoRejected
8
Guillaume Mohier- e-recycleAppendix 2
English: The pool of products studied is too small to give a true estimate of the entire catalog of Apple product refurbishers. Today, refurbishers work on smartphones up to the iPhone X (production eqCO2 impact higher than a 14). For iPads, the Pro (11“ and 13”) and air models are absent. Similarly, no Intel MacBooks are taken into consideration. To get a more accurate measure of Apple's pluses, we'd need to extend the catalog to include devices still supported by software (year 2017/2018 for iPads and MacBooks, and up to X for smartphones). As far as we know, recent products (2 years old) do not make up the bulk of refurbishers' trade-in catalogs.

Original (French): Le pool de produit étudié est trop restreint pour donner une réelle estimation sur l'ensemble d'un catalogue de reconditionneurs de produits Apple. Aujourd'hui, les reconditionneurs travaillent les smartphones jusqu'à l'iPhone X (impact eqCO2 à la production supérieur à un 14). Sur les iPads, les modèles Pro (11" et 13") et air sont absents. De même, aucun MacBook Intel n'est pris en considération. Pour obtenir une mesure plus adéquate sur les plus Apple, il faudrait élargir le catalogue aux appareils encore supportés logiciellement (année 2017/2018 pour iPads et MacBooks et jusqu'au X pour les smartphones). Les produits réçents (2ans) ne représentent pas à notre connaissance la majeur partie du catalogue de reprise des reconditionneurs.
TechnicalThese data are primarily used for calculating the impacts of new Apple device purchases that are replaced/avoided by refurbished Apple devices. They are not intended to represent the breakdown of Apple devices refurbished by refurbishers. With this data we wanted to capture the most commonly purchased new Apple devices currently. For this, it did not make sense to go back further than a couple of years. NoRejected
9
Simon Deschamps- Climate Dividends Association
1.1.1 / p.5
Marketplaces are not eligible projects. How does this rule fit with a player such as Backmarket and their desire to generate carbon credits for their refurbishers
GeneralWe have added the following text in paragraph 1.2 to clarify this point: "Marketplaces may act as intermediaries between Riverse and refurbishers to assist in the certification process. Signed agreements shall be provided ensuring that the refurbishers are the principal and final beneficiaries of carbon finance."YesValidated
10
Simon Deschamps- Climate Dividends Association
2.1.2 / p.6 I feel like an explanation on the unlikelihood of double counting would be valuableEditorialWe have specified that it is unlikely "given that device collectors and marketplaces are not eligible under this methodology".YesValidated
11
Simon Deschamps- Climate Dividends Association
2.3.2 / p.8 Proving that refurbished devices are valid substitutes is not easy but it's important to avoid important leakages (i.e. "This phone is too old to be kept more than 1 year"). Providing more guidance on how to assess it would be valuableTechnicalWe added the following text in paragraph 2.4.2: "This evidence may include documentation of quality control checks, the device grading system, and the quality thresholds that devices must meet to be sold instead of recycled."YesValidated
12
Simon Deschamps- Climate Dividends Association
3.3.1 / p.13 Why is the buyback price per device category optional? What purpose does it serve?GeneralIt is optional because we have default data from secondary sources that we can use if Project Developers can't provide their own data.
The purpose of this data is to calculate the residual value of used devices.
NoRejected
13
Simon Deschamps- Climate Dividends Association
Table #2 / p.15 Do you think it would be realistic to opt for a more precise approach with more precise operational data and emission factor transparency from manufacturers? For example, I understand that smartphones tend to all be the same form factor nowadays however laptop, PC and most of all screens are very diverse in terms of sizes and thus impacts: a specialized company refurbishing 1000 14 inches screens will have the same results as a competitor focusing on 1000 40 inches screens. More granularity could be useful to prevent that, even more if refurbishers have the operational data for all their devices and manufacturers are transparent about the emissions of their products...TechnicalIndeed this could be a more accurate approach, and we have investigated and tried to impelement it, but we found that it was not realistic or feasible. Projecs do not have sufficiently detailed or relevant data on their refurbishment inputs. Notably, we lack precise data on their replacement parts (e.g. new screen, new battery), which are expected to be by far the largest source of impact from refurbishing, compared to electricity from software fixes, cleaning supplies... Their purchase records of new parts does not necessarily match new parts used in a year, since they can sit on shelves unused for a long time.

We will continue to monitor for this data and see if it can be improved in the future, but our current approach based on literature data was deemed a good balance of accuracy, data relevance, and data collection feasibility.
NoRejected
14
Simon Deschamps- Climate Dividends Association
3.5.6.2 / p.22 I understand what you're trying to say but I think the wording could be clearer, and/or accompanied by a mass flow diagram (one for the project scenario, one for the baseline scenario) that shows why this is necessary when thinking in terms of equivalent functions.TechnicalThis was revised and reworded for clarity. YesValidated
15
Simon Deschamps- Climate Dividends Association
3.5.6.4 / p.22 How confident are you in the independance and reliability of Apple emission factors?TechnicalThis is partly addressed in the Uncertainty Assessment section, where we evaluate the uncertainty in secondary data used (among other factors). Apple emission factor data were designated low uncertainty, but the overall uncertainty of the model was estimated to be medium, which leads us to apply a 6% discount factor (i.e. we issue 6% fewer credits than are calculated as avoided emissions).
We are as confident in these emission factors as we are for the other generalized, average emission factors (such as those taken from ecoinvent). They have similar values, and are not consistently lower (or higher). The Apple Proudct Environmental Reports (PERs) were estimated to be as transparent as could be expected from an internal LCA from a private company. They describe the methodology well, state that data and models are checked by a third-party research institute (Fraunhofer Institute in Germany), and receive a Gold rating from the Electronic Product Environmental Assessment Tool (EPEAT) Registry for many of their products (stated in the PERs, and confirmed on the registry databases). The EPEAT Climate Change Mitigation Criteria can be found here, and include components such as thorough and publicly disclosed LCAs.
YesValidated
16
Simon Deschamps- Climate Dividends Association
Eq. 6 / p.24 What do you use the "𝐼𝐹 𝑓𝑢𝑙𝑙 𝑟𝑒𝑓 * 𝐸𝐹 𝑛𝑒𝑤. " instead of directly using the emission factor from the refurbishment? Given the construction logic of the term "𝐼𝐹 𝑓𝑢𝑙𝑙 𝑟𝑒𝑓", I feel like it'd be clearer to avoid adding this notion.TechnicalWe don't really have an appropriate emission factor for refurbishment to directly use. We did not direclty use the refurbishing emission factors from the ADEME study because they were proportional to/based on the methodology from their new device production emissions, and we preferred to use ecoinvent values for those. This was because 1) ecoinvent is more generalizable and transparent, and 2) we wanted to consider Apple devices separately. So we only used the ratio of refurbishing impacts to new device impacts (IF, the impact fraction), but apply this to ecoinvent values, which are represented in the EF new.

We can see the difference in refurbishing impacts we obtain by comparing our values in Table 3, to the ADEME values in Table A6.

We add this in the equation even if it is confusing and complicated because we want to be fully transparent and accurate showing how we literally do the calculations.
NoRejected
17
Simon Deschamps- Climate Dividends Association
3.6.3.4 / p.32 I understand the distinction between light and full refurbishment when it comes to residual value. But isn't there a risk that the tracking of the 2 categories is too complex and/or subject to false estimations?TechnicalWe have found that Project Developers are able to sufficiently prove how many devices undergo full and light refurbishment using process records and tracking. If this cannot be proven, we would always take a conservative approach and assume that all devices underwent full refurbishment. NoRejected
18
Simon Deschamps- Climate Dividends Association
table 4 / p.32 Given the fact that you allow Project Developers to come up with their own data for residual value (which is good IMO), it is important to detail how the values in Table 4 were determined (method, data sets, validity period, etc.) to allow for comparison.TechnicalWe feel that this is sufficiently detailed in Appendix 7. NoRejected
19
Hasler Iglesias- CETENMA2.1 / p. 6. Very good mentioning the measures taken to prevent double counting. It is usually not frontally addressedGeneralThank you, it is one of our 12 eligibility criteria, so we must discuss it. NoRejected
20
Hasler Iglesias- CETENMA2.3/ p. 9 The example in the light blue box illustrates very well the (appropriate) measure taken. Refurbished devices' impacts should be thoroughly assessed as to what emissions do they avoid.GeneralThank you.NoValidated
21
Hasler Iglesias- CETENMA3.2 /p. 12 Very interesting and useful functional unit. It considers the refurbishing of a product but also the waste generated at the end of life of the "first" device. This demonstrated a good understanding of the system, and the honesty pursuited by the projectTechnicalThank you, this approach is based on the life cycle assessment (LCA) concept of system expansion. LCA helps us use a systemic perspective and make sure that no processes or coproducts are left out.NoValidated
22
Hasler Iglesias- CETENMA3.4.8 / p.15 Economic allocation doesn't look like the most appropriate go-to strategy. Specially when talking about rare earths, precious metals, and other components (e.g., Litium) which may have a substantial impact not necessarily associated to the impacts they cause. A "system expansion" looks like a better idea. This means, avoided impacts of device B should be those that would have been caused by the production of a brand new device.TechnicalWe don't fully understand your comment. "Avoided impacts of device B should be those that would have been caused by the production of a brand new device" is what we are quantifying with our comparative approach, where production of a brand new device is consdiered in the baseline scenrio. Allocation was appropriate here because we are"isolating" the impacts of the project scenario (refurbishment), since system expansion and substitution/avoidance doesn't make sense, with out comparative LCA structure. NoRejected
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100