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More regulation of cartridge reuse required

February 7, 2018


A new EU-commissioned study on the printer cartridge market will reveal a need for “more regulatory action” when it comes to promoting reuse, according to ETIRA.

The soon-to-be-published is entitled “Study on the implementation of product design requirements set out in Article 4 of the WEEE Directive – The case of reusability of printer cartridges”.

As ETIRA revealed in a recent newsflash regarding the study, its findings will show that, while the printer cartridge market “is very competitive”, the regulatory environment “is not well suited to promoting reuse of products or encouraging dematerialisation and greater material efficacy.”

As a result, crucial alterations have been suggested, with the writers of the study urging the implementation of Extended Producer Responsibility (EPR) as a must-have solution to “enhance over-all cartridge reuse.”

ETIRA also revealed that, in terms of market data, the study indicates “that clones represent 5 percent of toner and inkjet markets respectively”, which the Association views as “a serious underestimate”.

The study also demonstrates that, currently, the OEMs’ Voluntary Agreement (Imaging Equipment) “does not promote cartridge reuse”; as a result, the study writers suggest revising the agreement and incorporating “parameters on lower emissions of printing”, such as the mandatory targets found in the vehicle industry. The study cites the reduction of cartridge complexity as one means of achieving this. It also “supports developing an EU Ecolabel criteria for remanufactured cartridges”, a move which was called for by ETIRA.

Various concerns and their “corresponding actions” were laid out in the study, including:

  • Creating a level playing field for the new and re-use/second-hand markets.
  • Consolidating patent holder and OEM protection and second user rights.
  • Improving design for reuse, recycling and recovery
  •  Ensuring reused cartridge performance.
  • Improving re-use performance disclosure.

To improve the market situation for both legitimate new and reused cartridges, a range of measures is proposed for consideration:

  • Addressing the issue of ‘rogue clone’ imports
  • Ensuring reuse agents do not mis-represent reused units as OEM products.
  • Improving access to cartridge design and consumables specifications
  • Revising the EU GPP criteria to address ‘remanufactured and refilled cartridges.

  Improving user information on all cartridge packaging to reveal true performance.

  • Creating a rating system for cartridge quality (‘failure rate’) matched to user expectations.
  • Rationalising acceptable phrases to be used to describe new and reused cartridges.
  • Reviewing the Voluntary Agreement so that data on rates of take-back, re-use, recycling and other recovery operations is routinely collected and published.
  • Expanding scope of actions by producers of cartridges to promote and support the reuse option as an alternative to take-back.

In relation to the study, ETIRA made the following statement:

“In 2016/2017, ETIRA had provided substantial input to the writers of the study. We are glad to see that it now identifies current OEM market behaviour as not contributing to promotion of cartridge reuse, and takes on board several of our recommendations to address this problem. We will now reach out to regulators to put this into action!”




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