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European Toner Inkjet Remanufacturers' Association

ETIRA

Intrest representation for the European remanufacturers of toner and inkjet cartridges

Lobbying Activity

Response to Export and import of hazardous chemicals – amendment of annexes 1 and V

21 Mar 2023

The controls on Imports are extremely weak and many products and substances that have to comply simply with REACH , enter without control .Once inside MSA have more problems This is the case of "Printer Consumables " that are clearly in the context of REACH considered "a combination of an article and a suvbstance mixture " Article 33 of REACH stablishes the right of Consumers to know , and this is specially important in substances that contain heavy metals, and generate Volatile Organic Compounds while printing . To our knowledge non of the importers of "Compatible China Clones" is REACH Compliant . However never a strong supervision action took place . By not being REACH compliant the "Fair Single Market" is disrupted and EU Companies subject to "Unfair comercial practices"
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Response to Evaluation of the 2012 Directive on waste from electrical and electronic equipment

3 Nov 2022

As our feedback exceeds the 4000 character limit, we submit it by the enclosed PDF- file. A summary includes: According to ETIRA, representing the European cartridge remanufacturers, in terms of promoting cartridge reuse and reducing (hazardous) cartridge waste, the WEEE has not delivered on its promise. Today, after 20 years of WEEE, fewer cartridges are being reused than ever before, and hazardous and polluting non-OEM and OEM single-use newbuilt cartridges from SE Asia are flooding the EU market in larger volumes than ever before. And as the non-OEM newbuilts cannot be reused, meaning they go straight to landfill or incineration in the EU after 1st use. Cartridges produce much more waste than most IT-products, including mobile phones etc. Printer cartridge reuse has existed for 25 years but never developed to its full potential. Today only 7%-20% of cartridges are reused, while technically up to 80%-90% could be reused. Increase in reuse is hindered by many barriers put up by printer manufacturers, which, only for commercial reasons, want single-use only, and by imports of cheap an polluting single-use non-OEM clone cartridges from SE Asia. The WEEE should help to remve those barriers. For cartridges, ETIRA states that there are many material shortcomings of the WEEE: -Member States can reach the generic reuse / recycling percentage targets set under the WEEE without a single cartridge being reused. But according to EU waste laws and the international waste hierarchy pyramid, reuse has a lower environmental footprint than recycling materials. In the case of cartridges, many studies have shown that reusing a cartridge as a cartridge saves natural resource resources and reduce CO2 emissions by 45%-60% compared to producing a new cartridge. That is why in the WEEE, the activities reuse and recycling should be split into two seperate activities, with each having their own WEEE target. -Because of the great environmental impact they can have, combined with their great reuse potential, printer cartridges need to be seperated from the EEE umbrella product category in which they classified are now, and get their own speciific, cartridge WEEE reuse target. -WEEE implementation is very very different across EU Member States, and even between regions within a Member State !! Environment-friendly cartridge reuse is made impossible as operators are confronted by a plethora of different and often outright contradictory rules and definitions and classifications of used cartridges. Definition of empties range from waste to product. The EU needs to set a definition. -for cartridges, the article 4 WEEE prohibition of specific design features or manufacturing processes that prevent WEEE from being re-used (ecodesign) is a farce because, in 2002 only some, but today all cartridges on the EU market have such illegal features !! The EU should outlaw such design features or manufacturing processes at EU level, and not leave this up to the not-acting Member States -enforcement of WEEE compliance by national market surveillance authorities is non-existent: imports of polluting single-use newbuild cartridges from the Far East by rogue traders without any registration in national WEEE registers and containing illegal chemicals are rampant in most EU countries. The EU should force Member States to act decisively. Importers should provide evidence of correct WEEE registration and REACH/ROHS compliance before importation is allowed. -Today, all too often players do not pay for the waste and wasteful effects they generate. Today, environmental penalties are way too low to really discourage wasting and pollution. To end the soft and varying implementation of the WEEE across Member States, the WEEE should become a regulation.
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

2 Jun 2021 · Circular economy, reuse and printer cartridges

Meeting with Rozalina Petrova (Cabinet of Commissioner Virginijus Sinkevičius)

2 Jun 2021 · Circular economy, reuse and printer cartridges

Response to A new Circular Economy Action Plan

30 Dec 2019

Flagship measure on the Circular Economy . The Printing challenge . The cartridge remanufacturing business has been a textbook example of Circular Economy for decades (more than 30 years now! ) . It brought, and demonstrated , early enough some of the benefits of circular Economy models :Waste Reduction , job creation and wealth distribution . However in recent years it has been dramatically shrinking , as counterforces appeared on the market and destroying the ”Single market” . Opposition from linear manufacturers on the top end, using a myriad of Anti Reuse devices and tactics, and low quality non compliant infringing products on the bottom , have tremendously undermined the market and evidences have been highlighted by several EU Commission Studies : https://ec.europa.eu/environment/waste/weee/pdf/KH0418170ENN.pdf And later the self regulatory revision process. https://www.review-imagingequipment.eu/documents For the second time the EU Commission rejected the self regulatory agreement proposed by Printer manufacturers (First on the meeting on 25th April and later on the 12th December . The “Paradoxes” and “success stories” of VA can be found here with a call to stop this non effective policy instrument https://www.coolproducts.eu/news/all-we-want-for-christmas-is-for-the-eu-to-finally-give-up-on-voluntary-agreements Furthermore the validity of VA to be enforced by MSA is extremely weak not to say non existing Why we call for an urgent implementing measure ? Main aspect to reduce waste, defend thousands of green jobs and create up to 40-60.000 new jobs Moreover because it is a clear example of disruption into the Single market and it looks as the more Compliant companies are placed on a worse competitive scenario . Evidences of RoHS, REACH and WEEE infringements are just dramatic However tools to address this situation are invalid Some data will reinforce the petition: -Nearly one Printer per household -Very exigent in resources and a well known and described razor and blades model .(paper , WEEE and Chemicals ) -Printers used at 7% of potential performance -Average cartridge life at home use 288 pages (EU sources ) representing 19 minutes life . Global life of home printers rated at 5-7 hours total end of life! -Home printer repair rate=0 .cartridges are more expensive than printers and parts also -Up to 2,5% of Small and medium appliances WEEE caused only by cartridges -Reuse market share around 10% while EU Commission Studies set potential at +80% And many more We urge the EU to defend a well stablished Circular market ( With all reverse logistics , secondary supply chains etc. well stablished) and learn about how Circular approaches could be challenged in the future, prior to any other measure . We call for support into having a new category under the EU Eco-label program
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Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen) and Deutsche Kartuschen Wiederaufbereitungs-Unternehmen

4 Jul 2018 · Presentation of the toner cartridge remanufacturers industry/market conditions