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ETIRA calls for faster progress on draft regulation for the imaging equipment sector

July 4, 2022

The European Toner and Inkjet Remanufacturers Association (ETIRA) is developing an updated position regarding the forthcoming draft EU regulatory framework for the imaging equipment sector.

The organisation, which represents the interests of the inkjet and toner cartridge remanufacturers and related service providers in the EU, is working on a formal position paper which will be submitted to the EU commission and other bodies who are tasked with writing the impact assessment and draft regulation. ETIRA will also take part in the industry stakeholders consultation meetings which the EU will organise in the coming months.

Javier Martinez, President of the European Toner and Inkjet Remanufacturers Association (ETIRA), said: “Earlier this year the Commission rejected the Voluntary Agreement for imaging in favour of its Green Deal which many of our members believe is good news for inkjet and toner cartridge remanufacturers.

“This move takes us away from a ‘directive’ and towards ‘regulation’ which is a major step because it is no longer proposing just guidance but rules that will be directly applicable and can be enforced in all  EU Member States, and apply equally to all market participants.

This  is  in line  with  EU  Position  replacing  directives  (Eco-Design,  WEEE  Etc. )  by  a  more stringent  Regulation

“Our board of directors are now in the process of contributing to the next phase by providing the EU commission, and other interested parties, with a very clear position on what we and our members want to see happen next. This is still being developed but we are now able to give a flavour of the underlying principles that we hope to come from the new regulation.

“ETIRA has always insisted that all environmental policies affecting printing should respect the Eco-design directives, the EU Treaty, and defend SME and consumer rights. In addition, it should respect the EU’s waste hierarchy concept, which sets waste reduction, repair, and reuse above mere recycling of the materials. Moreover, it is important to note that the transition from recycling to remanufacturing can exponentially increase the number of EU jobs..

“Like NGO’s, consumer associations, Member States, and other stakeholders, we want to make printing sustainable. Products should be designed with their environmental footprint in mind during production, operational life, and at end-of-life including reusing a cartridge as many cycles as possible, followed by the recycling of its composing materials. It is vital to create and allow a functional secondary market, which does not exist at the customer level. 

“Since 2002, the EU’s WEEE legislation seeks to reduce the fast growing waste streams generated by IT, electrical and electronic products, by designing products in an environment-friendly way. Therefore, in the case of printing and cartridges, Original Equipment Manufacturers (OEMs) have had 20 years to reduce the waste volume generated by printers and cartridges, but in practice they have done very little. The anti-reuse design of today’s cartridges is not environment-friendly and unsafe. Reusing cartridges can change that.

“These views are not only ETIRA’s views, in fact the EU itself has outlined similar objectives in many recent EU reports and policy initiatives on the environmental impact of printing.”

On cartridges, ETIRA maintains that EU policy should ensure, as a minimum, that the following elements are met, to be able to reduce waste and move towards a new and more sustainable business model: 

• A compulsory minimum percentage, increasing every year, of all produced cartridges (OEM and non-OEM newbuilts) to be reused as a cartridge. Clear and ambitious re-use targets for all cartridges must be set: Without fixed targets, reuse of cartridges will not grow.
• Prohibition of all anti-reuse tools and tactics such as firmware updates, chips, chip resetting, embedded software, patents on remanufacturing, closed loop sales systems, that prohibit  third party remanufacturers full access to full printer / cartridge functionality
• Any new rules for printers must provide professional providers of reused cartridges with access to printer software and firmware, so that cartridges can be easily reused.
• An end to imports of polluting and unhealthy non-OEM new built cartridges at the EU border, not just retroactive inspections/checks when they are all already in the EU market.
• The EU has introduced ecodesign rules for several electronic products, such as vacuum cleaners and dishwashers, which include   provisions on sharing product and software and firmware data with 3^rd party repairers. The same is needed for   3^rd party cartridge remanufacturers

Javier added: “In Europe, up to 70 per cent of empty toner and inkjet cartridges are incinerated or dumped in landfill every year after 1st use. But between 80 and 90 percent of these cartridges could have been reused as a cartridge several times. Remanufacturing cartridges reduce their carbon footprint by up to 45-60  per cent. Every cartridge that is remanufactured is one fewer going directly to landfill. Remanufactured cartridges are also often up to 30 per cent cheaper than OEM equivalents, representing a cost-effective and environmentally-friendlier option.

“This issue needs tackling as a matter of urgency and we want to see change introduced as quickly as possible. We continue to lobby for the new draft regulation to come in as soon as possible and to incorporate our principles which we think would be a sensible way forward for our industry.”

Last year, ETIRA launched a new certification label to help customers distinguish between printing cartridges which are better for the environment from others.