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UKCRA comments on EU’s rejection of the proposed Voluntary Agreement

May 5, 2022

In March, the European Commission rejected the proposed Voluntary Agreement and will instead bring forward regulations so that reuse is properly regularised. 

The working plan by the European Commission confirmed the Commissions assessment that the revised Voluntary Agreement submission proposed by representatives of the OEM and aftermarket would not achieve the objectives considered in the Circular Economy Action Plan (CEAP) and cannot be considered compliant with the guidelines regarding the possible re-use of consumables and the Commission will launch the preparation of regulatory measures for this product group.

The Commission is proposing new rules to make almost all physical goods on the EU market more friendly to the environment, circular, and energy efficient throughout their whole lifecycle from the design phase through to daily use, repurposing and end-of-life.

UKCRA made the following observations:

“The EU’s rejection signals the start of upheaval in which industry players will need to reconsider their business models for positioning in a fast-emerging circular economy. Players such as cartridge collectors and brokers, component suppliers, OEMs, remanufacturers and others through the supply chains, will all need to establish new ways for the consumer to receive a high-quality product every time with increasingly lower impact on the environment.

“Over the years UKCRA has been pro-active in communicating the benefits that cartridge re-manufacturing and printer refurbishment bring to the consumers, the industry, the economy and the environment. UKCRA has been involved in many initiatives – and looking back over the last decade or so can be seen to be ahead of its time – in taking practical measures leading to a circular economy.  For many, the concept of a circular economy is simply about recycling materials. UKCRA has never shared this view. UKCRA has always maintained that the circular economy requires a re-evaluation of the way in which value add is built into and maintained within high-quality environmentally-preferable products. 

“A fully-developed circular economy will require fundamentally new forms of service systems to sustain much higher levels of reuse, remanufacturing, and refurbishing than is currently possible today. Some of the changes to be expected can be traced to legislation brought in many years ago. Specifically, the WEEE Directive, a Directive concerned with waste, included in its Article 4 requirements about designing a product for reuse.”

In 2014 UKCRA commissioned an assessment of the impact of the Recast WEEE Directive on the industry [Recast WEEE and the UK Cartridge Remanufacturing Industry – Assessment of the Impact on the Industry of Regulatory Changes]. The study, reported in The Recycler, explained overall why and how the various industries (OEMs, OEM remanufacturers, 3rd party remanufacturers) involved with printer cartridge remanufacturing may converge over the coming business cycles. 

UKCRA concluded: “We are now at such a point with the EU readying the market for regulation. The UKCRA work from nearly a decade ago identified that future developments in the cartridge remanufacturing arena relate to an emerging industrial system in which environmental regulation may evolve to a more modern approach requiring regulatory approaches for distributed circular-economic systems and components and products with many lifetimes.  This points to a converging industrial system in which traditional industries (OEMs and remanufacturers) converge to service printing needs in a more sophisticated circular economy. UKCRA recognises this is a turning point for the whole industry, one in which a key focus will become the maintenance and longevity of cartridge assets. This will bring about significant changes in cartridge designs, approaches to availability of spare parts to the printer repair Industry, as well as availability of cartridge components in order to uphold multi-life cartridge servicing and quality metrics.”

Categories : Around the Industry

Tags : Comments Eco Design UKCRA Voluntary Agreement

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