When Green Tenders Fail the Price Test

October 27, 2026

ETIRA examines how unrealistic pricing and inadequate verification can undermine public procurement of legally compliant remanufactured cartridges.

A recent Italian public tender for remanufactured toner cartridges has raised a question extending far beyond Italy. Can public authorities achieve their environmental objectives if the prices they expect to pay for remanufactured products are commercially unrealistic?

Across Europe, public procurement increasingly supports sustainability, resource efficiency and the circular economy. Remanufactured toner cartridges extend product lifecycles, retain valuable materials and reduce waste.

The commercial significance is considerable. A preliminary examination of notices published through the EU’s Tenders Electronic Daily (TED) database between 15 July and 15 October 2026 identified 13 cartridge-related procurement notices with disclosed estimated values totalling approximately €6.1 million. This limited sample is not a comprehensive estimate of European expenditure, and some notices require further verification of their cartridge-specific scope. Nevertheless, it illustrates the scale of public purchasing opportunities.

Yet there is a fundamental difference between specifying a sustainable product and actually purchasing one.

A contracting authority can prepare a tender containing demanding technical specifications, environmental criteria and applicable legal requirements. But these ambitions must also be reflected in the commercial conditions under which suppliers compete.

Genuine remanufacturing involves collecting suitable used cartridges, inspecting and processing them, replacing components where necessary and testing finished products. Manufacturers must also meet applicable product safety, chemical, environmental and waste management requirements.

All this costs money.

Businesses have different cost structures, and competitive pricing is desirable. However, exceptionally low prices raise reasonable questions about whether specified products can genuinely be supplied while meeting every requirement.

A remanufacturer investing in compliant processes, testing and environmental management may find a tender commercially unattractive and decline to participate. Other suppliers may submit lower offers, but price alone tells the authority little about how they intend to meet the specifications.

The risk is that procurement intended to support circularity inadvertently discourages the businesses it seeks to encourage.

The Difference Between Promising and Delivering

Another concern is familiar to Europe’s remanufacturing industry. Established manufacturers are sometimes approached by companies preparing public contract bids and asked to provide quotations, technical information and evidence of compliance. Their products may help bidders demonstrate that tender requirements can be satisfied.

Yet remanufacturers report occasions when, despite a bidder securing the contract, the anticipated orders never materialise.

There can be legitimate explanations, and the absence of orders does not establish wrongdoing. Nevertheless, it raises questions about the relationship between products proposed during a tender and those eventually delivered.

A compliant remanufactured cartridge could help secure a contract without ever being supplied under it.

This is why verification matters beyond the initial award. Where bids are assessed using particular products, manufacturers or supporting documentation, contracting authorities should ensure that deliveries continue to meet the agreed specifications throughout the contract.

This is particularly important for multi-year arrangements. Initial deliveries may meet every requirement, while later supplies could involve different products. Without ongoing checks, compliant remanufactured cartridges risk being replaced by cheaper, non-compliant newbuild alternatives.

A low price does not automatically indicate non-compliance, just as a higher price does not guarantee compliance. But relying solely on declarations submitted during the tender process can leave a gap between products promised and those delivered.

Periodic verification throughout the contracted supply period is therefore essential. Depending on applicable requirements, this may involve checking product identification, traceability, environmental documentation, evidence of remanufacturing and product quality.

No single certificate establishes compliance with every obligation. Authorities must understand which requirements apply and what constitutes credible evidence.

European procurement rules provide mechanisms for examining apparently abnormally low offers. These should establish whether suppliers can fulfil the specifications rather than treating the lowest price as sufficient justification for an award.

For ETIRA, the concern is not competitive pricing itself. It is that environmental and legal requirements lose their practical significance when price and compliance verification are considered separately.

Turning Environmental Ambition into Results

The European Union is considering further reform of its public procurement framework, including greater recognition of circular economy activities and lifecycle considerations. This offers an opportunity to examine how authorities ensure their purchasing decisions deliver the intended outcomes.

ETIRA believes legally compliant remanufactured cartridges should compete fairly on quality, performance, reliability, environmental benefits and lifecycle costs. Genuine efficiencies should be recognised, while every supplier must meet the same applicable standards.

This requires a clear connection between tender specifications, commercial conditions and verification of products actually supplied. Authorities need not abandon competitive purchasing. They must ensure competition takes place between products genuinely meeting their requirements.

Even a tender containing excellent environmental specifications can fail to deliver circular economy benefits if those requirements are not reflected in the products purchased.

A green tender is not necessarily a green purchase.

Ecodesign Regulation Remains on Track

September 9, 2026

Agreement to extend the ESPR transitional period should allow work on new Ecodesign rules for imaging equipment and consumables to continue under the existing framework.

Progress towards new European Ecodesign rules for imaging equipment and consumables has received an important boost following agreement in principle to extend the transitional arrangements under the Ecodesign for Sustainable Products Regulation (ESPR).

The forthcoming imaging equipment regulation has been developed under the EU’s previous Ecodesign Directive. When ESPR replaced that Directive in 2024, transitional provisions allowed work already underway for several product groups, including imaging equipment, to continue — provided implementing measures could be adopted by 31 December 2026.

Delays within the European Commission meant that deadline was increasingly unlikely to be met. Without an extension, there was concern that the imaging equipment initiative could have been transferred into the newer ESPR framework, potentially resulting in several additional years of delay.

European industry organisations therefore called for the transitional period to be extended by two years, until 31 December 2028.

That proposal was subsequently included within the European Commission’s Omnibus IV legislative package. In late July, the Council and European Parliament reached agreement in principle on the extension, with formal approval expected to follow.

For ETIRA, this is a welcome development.

It should allow the proposed Ecodesign regulation covering imaging equipment and consumables to continue progressing under the existing legislative framework rather than being delayed by a move into the ESPR process.

ETIRA has been closely involved in discussions surrounding the future Ecodesign requirements for the imaging sector and will continue working to ensure that remanufacturing, cartridge reuse, access to components and the principles of the circular economy are properly reflected in the final regulation.

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New EU Packaging Rules Take Effect

While many European businesses were taking their summer break, new EU packaging rules became applicable. ETIRA looks at what they could mean for the imaging supplies industry and businesses selling across Europe.

While many businesses were enjoying their summer holidays, another significant piece of European environmental legislation became applicable.

On 12 August 2026, the EU’s Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, became applicable across the European Union, replacing the previous Packaging and Packaging Waste Directive.

The Regulation is intended to reduce packaging waste, improve recyclability and reuse, increase the use of recycled materials and strengthen producer responsibility. Many of its detailed requirements will be introduced progressively over the coming years.

For the imaging supplies industry, however, PPWR is about considerably more than designing a better cartridge box.

One issue in particular deserves the immediate attention of companies selling products across Europe: producer registration and Extended Producer Responsibility (EPR).

Selling Across Europe

Under the PPWR, producers are required to register in each Member State where they make packaging or packaged products available for the first time.

This could have significant implications for European businesses operating across the Single Market.

A remanufacturer selling packaged cartridges directly into several Member States may need to consider registration, reporting and EPR requirements in each of those countries. Depending on the company’s role and route to market, this could mean dealing with several different national registration and producer responsibility systems.

The precise responsibility will depend upon the supply chain and which business meets the Regulation’s definition of the producer. Selling through an independent distributor, for example, can create a different situation from selling directly to an end user in another Member State.

ETIRA therefore recommends that companies selling packaged products across borders review their current arrangements and establish where registration and EPR obligations may apply.

More Than the Cartridge Box

The PPWR covers packaging throughout its lifecycle.

For imaging supplies companies, that can include the packaging immediately surrounding a toner or inkjet cartridge as well as packaging used to group, transport and deliver products.

Over the coming years, businesses will also have to consider increasingly demanding requirements covering areas such as packaging minimisation, recyclability, recycled content and harmonised labelling.

The direction is clear: packaging is increasingly being treated as an integral part of the environmental impact of the product being placed on the European market.

Another Layer of Compliance

For Europe’s remanufacturing industry, PPWR does not exist in isolation.

European businesses already operate within an extensive framework of product and environmental legislation. Depending on their activities and products, this can include WEEE, Extended Producer Responsibility, REACH, CLP, product safety, packaging and waste legislation, together with associated registration, reporting, collection and end-of-life responsibilities.

Every one of these obligations carries an administrative and financial cost.

For smaller companies operating across several European markets, the cumulative burden can become substantial. A business supplying relatively modest quantities of packaged products across Europe could potentially find itself navigating numerous national registration, reporting and EPR systems.

ETIRA supports the environmental objectives behind the PPWR. However, implementation should also seek to minimise unnecessary administrative complexity, particularly for SMEs operating legitimately across the European Single Market.

What About Products Sold From Outside Europe?

The PPWR does not simply exempt producers because they are established outside the European Union.

Third-country businesses selling packaged products directly to European end users can also have producer responsibility obligations in the Member States into which they sell.

This is particularly important as ecommerce allows products to be sold directly from manufacturers and traders outside Europe to European consumers and businesses.

The challenge is therefore not simply whether European legislation applies. The challenge is ensuring that it is effectively enforced.

European manufacturers, remanufacturers, importers and distributors should not find themselves paying registration fees, EPR contributions and the administrative costs of compliance while competing products reach the same European customers without equivalent obligations being met.

Same Market, Same Responsibilities

ETIRA has consistently argued that environmental and product legislation must create a level playing field.

Companies established outside Europe should remain free to compete in the European market. But where they sell products into Europe, the same environmental and product responsibilities must be effectively applied and enforced.

The PPWR also introduces provisions intended to strengthen accountability for cross-border and online sales, including requirements affecting online platforms and the verification of producer registration.

ETIRA welcomes moves towards greater accountability but believes enforcement will determine whether the new framework succeeds.

If European businesses are required to register, report and contribute towards the environmental cost of packaging in every market they serve, equivalent requirements must be effectively enforced for all businesses supplying those markets, regardless of where they are established.

A More Accessible Single Market

There is also a wider issue for European policymakers to consider.

A Regulation designed to create more harmonised rules across the Single Market should ultimately make compliance easier to understand and administer, not require SMEs to navigate an unnecessarily fragmented landscape of national systems.

ETIRA believes greater harmonisation of registration, reporting and verification could reduce the administrative burden on compliant businesses while simultaneously making enforcement more effective.

A simple, accessible European system through which businesses, customers, online platforms and enforcement authorities could verify producer registrations across Member States would be a logical step towards that objective.

In the meantime, ETIRA encourages members selling packaged products across Europe to review their existing packaging registrations and EPR arrangements and seek specialist advice where necessary.

ETIRA will continue to monitor implementation of the PPWR and advocate for a system that supports the environmental objectives of the Regulation while ensuring fair competition, proportionate administration and equal enforcement across the European market.

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EU Parcel Levy Marks First Step Towards Fairer Competition

July 22, 2026

New €3 customs levy on low-value imports signals a broader shift towards stronger customs enforcement and greater supply chain accountability across Europe.

On 1 July 2026, the European Union introduced a temporary €3 customs levy on low-value parcels valued at €150 or less entering the EU from third countries.

While the levy is expected to increase the cost of many direct-to-consumer imports, ETIRA believes its greatest significance lies elsewhere. It represents the first practical step towards a wider reform of the EU customs system and a stronger focus on ensuring that products entering the European market comply with European legislation.

For many years, ETIRA has argued that European remanufacturers, distributors and compliant importers have faced an uneven competitive environment. Businesses placing products on the EU market must meet obligations under legislation, including WEEE, Extended Producer Responsibility (EPR), REACH, CLP and other product and environmental regulations. These requirements create genuine compliance costs that are not always reflected in the price of products imported directly through low-value parcel channels.

The new levy does not replace these obligations, nor does it remove the competitive advantage enjoyed by some low-cost imports. However, it begins to address one element of the imbalance while supporting customs authorities as wider reforms are introduced.

For the imaging supplies industry, the measure is particularly relevant. The economics of direct-to-consumer imports of low-cost compatible cartridges may begin to change, especially as customs authorities increase their focus on traceability, product compliance and supply chain accountability.

The levy should therefore be viewed as part of a much broader direction of travel. Alongside reforms to the Union Customs Code, new product safety requirements, revised CLP rules, Ecodesign legislation and future Digital Product Passports, the European Union is steadily building a regulatory framework based on verifiable traceability and more consistent enforcement.

ETIRA welcomes this first step but believes further progress is needed. A level playing field requires not only effective customs controls but also consistent enforcement of existing legislation across all products entering the European Single Market.

The association will continue to work with European institutions and national authorities to promote policies that support fair competition, encourage remanufacturing, and strengthen the circular economy while ensuring that all market participants operate under the same regulatory framework.

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ETIRA joins 88 organisations calling for stronger accountability in EU e-commerce

July 16, 2026

The European Toner and Inkjet Remanufacturers Association (ETIRA) has joined 87 other European industry and civil society organisations in signing a joint letter to Executive Vice-President Stéphane Séjourné calling for stronger enforcement against non-compliant products sold through online platforms.

The coalition argues that the rapid growth of cross-border e-commerce has exposed a significant gap in European legislation. While European manufacturers, importers and distributors must comply with product safety, environmental and Extended Producer Responsibility (EPR) legislation, many products sold directly by sellers outside the EU enter the market without an identifiable economic operator established within Europe.

According to the letter, an estimated 5.9 billion low-value parcels entered the European Union during 2025, placing increasing pressure on customs and market surveillance authorities. The signatories argue that enforcement alone cannot solve the problem and that legislation must clearly establish responsibility for every product sold to European consumers.

The coalition is calling on the European Commission to ensure that the forthcoming European Product Act:

  • requires every product sold in the EU to have a responsible economic operator established within the EU or EEA;
  • makes online platforms responsible where no other accountable economic operator exists;
  • recognises platforms as placing products on the EU market under defined circumstances; and
  • closes the accountability gap that currently allows many non-compliant products to reach European consumers.

For ETIRA, the issue extends well beyond product safety.

Javier Martinez, President of ETIRA, commented: “European companies invest every day to comply with environmental and product legislation. Those same rules must apply equally to products sold through online platforms. Accountability is fundamental to a fair Single Market.”

For many years, ETIRA has highlighted how European remanufacturers invest heavily in complying with WEEE, REACH, CLP, packaging legislation, EPR obligations and other product requirements, while many products imported directly through online marketplaces avoid equivalent responsibilities.

The association believes that ensuring every product sold in Europe has a clearly identifiable responsible economic operator is essential to creating a fair, competitive and sustainable Single Market.

Read the full joint letter here.

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Kyoto Club Withdraws Cartridge Ecolabel

July 8, 2026

Ecolabel body Kyotoclub / Multieticchetta Elabel! ends certification of cartridges and withdraws the label granted to SEA

This month, the Italian ecolabel organisation Kyoto Club decided to no longer certify remanufactured toner and inkjet cartridges for printers, copiers, multifunctional printing devices under the Multieticchetta Elablel! program. Also, licenses on remanufactured toner and inkjet cartridges currently active under the program have been revoked following an assessment by the competent certification body. This concerns the remanufactured toner cartridge product line, produced by S.E.A. s.r.l.    Full details can be found here:

ETIRA welcomes this decision. To have credibility, ecolables, in particular Type-1 ecolables, must have full and proper auditing criteria in place, and these must be strictly enforced. Without it, free riders who falsely claim compliance with the ecolabel criteria win government procurement contracts, while honest firms lose out, and customers are tricked into thinking they buy eco-friendly products, when in reality they receive single-use, cheap, polluting knock-offs. Already a long time ago, ETIRA asked Kyoto Club to reassess the Elablel! certification of SEA products. Following the revocation of the SEA label, ETIRA now asks that all contracts granted using the SEA certification be revisited.

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CLP Changes Ahead

June 24, 2026

New supplier identification requirements coming into force on 1 July 2026 could have significant implications for cartridge importers, distributors, remanufacturers, private-label brands, and online sellers. ETIRA examines what the revised CLP Regulation may mean for the imaging supplies industry and the steps businesses should be taking now.

New supplier identification requirements coming into force on 1 July 2026 reinforce the EU’s growing focus on traceability, accountability, and supply chain transparency. ETIRA examines the potential implications for importers, distributors, remanufacturers, marketplace sellers, and brand owners.

The EU increasingly wants verifiable traceability. It wants to know who made the product, who imported it, who placed it on the market, and who is responsible if questions arise regarding safety, compliance, or environmental obligations.

The new provisions introduced by Regulation (EU) 2024/2865, which become applicable from 1 July 2026, form part of a broader movement towards greater supply chain transparency and accountability.

What Has Changed?

Among many other elements, the revised Classification, Labelling and Packaging (CLP) Regulation introduces a requirement that hazardous substances and mixtures placed on the EU market must have a supplier established within the European Union who is identified on the label and responsible for compliance with the Regulation. For many businesses, this may seem like a relatively minor change. However, the requirement raises important questions about responsibility, accountability, and traceability throughout the supply chain. For the imaging supplies industry, this has several practical consequences:

  1. Non-EU cartridge sellers can no longer sell “direct to EU customers” without an EU responsible entity. If toner or ink cartridges contain hazardous mixtures under CLP, an EU-based economic operator must now be identified and legally accountable.

This affects Asian aftermarket manufacturers, marketplace sellers, cross-border ecommerce, drop shipments, etc.

The EU responsible entity may be the importer or an authorised representative. an EU distributor, a fulfilment service provider acting under product compliance rules

Without such an EU-based supplier indicated on the label, the products may not legally be placed on the EU market!

2. Toner and ink cartridges may require updated CLP labels

Some toner powders and some ink formulations are classified as mixtures under CLP due to:

  • carbon black content
  • solvents
  • sensitizers
  • reproductive toxicity classifications for certain components
  • respiratory irritation or aquatic toxicity

If the cartridge contains a classified hazardous mixture, the cartridge packaging must comply with CLP labelling rules, including ( but note that some of these provisions enter into force only in 2028!):

  • supplier identification
  • hazard pictograms
  • signal words
  • H and P statements
  • UFI where required
  • language requirements for each Member State.

3. Marketplace compliance becomes much stricter

As a result, online sales platforms are increasingly expected to ensure that hazardous products sold into the EU meet CLP requirements.

For toner and ink cartridges, this means:

  • Missing EU addresses on labels may trigger delisting
  • Missing SDS documentation may block imports
  • Incorrect hazard classification may create customs or surveillance issues
  • Anonymous aftermarket brands become higher risk

This is especially relevant for low cost compatible cartridge imports.

4. Cartridges are in a grey zone between “article” and “mixture”  A cartridge itself is usually treated as an article, but:

  • The toner or ink inside is a mixture
  • leakage exposure scenarios matter
  • Refill bottles and bulk toner are clearly within CLP scope

Therefore:

  • sealed cartridges with no hazardous classification may have limited obligations
  • refill toner bottles and bulk inks are fully exposed to CLP obligations
  • some OEM and remanufactured cartridges may newly require closer classification review

So what Should Businesses Do Now?

Businesses should use the period before 1 July 2026 to review their supply chains and compliance arrangements.

Practical steps may include:

  • Identifying the responsible supplier for each product range
  • Reviewing product labels and packaging
  • Verifying Safety Data Sheet (SDS) documentation
  • Reviewing marketplace listings and product information
  • Confirming responsibilities with suppliers and business partners
  • Assessing whether current compliance arrangements remain appropriate

Products already lawfully placed on the market before the new requirements become applicable may be subject to different considerations. However, businesses that place products on the market after 1 July 2026 should carefully review their obligations.

For the imaging supplies industry, the new CLP requirements mean traceability, accountability, and compliance are becoming increasingly important commercial considerations. In our industry, many products are imported from SE Asia, and a large number do not comply with the new rules. European distributors and other customers should avoid violating EU and national laws by trading with established European remanufacturers, such as ETIRA members, who comply with the rules.

ETIRA will continue to monitor developments and provide practical guidance to members as implementation of the revised CLP requirements progresses. Already in April 2026, ETIRA provided its members with a useful Guide on REACH and CLP provisions.

Disclaimer: This article is intended as general industry guidance and should not be regarded as legal advice. Companies should seek professional advice regarding their specific compliance obligations.

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German Court Rules Against Ninestar in HP Patent Case

May 29, 2026

A Munich Regional Court has ruled in favour of HP in a patent infringement case involving Ninestar Corporation, recently renamed Pantum Technology, and related European entities including Seine Holland, G&G, Zhuhai Ninestar Information Technology, and Ninestar Image Tech.

According to industry reporting, the court found an infringement of European Patent EP 3 530 470. Importantly, the ruling confirmed the principle of “expanded group liability”, establishing that parent companies can be held directly liable for patent compliance failures across their European subsidiaries.

For ETIRA, this ruling highlights the growing structural and compliance risks facing European distributors when sourcing products through complex international supply chains. The decision also demonstrates that intellectual property enforcement is intensifying within the European Single Market, potentially creating significant financial and operational liabilities for resellers.

Separately, international trade developments, including ongoing U.S. import restrictions affecting Ninestar-related entities under the Uyghur Forced Labor Prevention Act (UFLPA), reflect a broader global trend toward increased supply chain accountability and due diligence.

ETIRA reminds European distributors and public procurement officers that maintaining supply chains free from patent infringement risks and wider regulatory exposure is increasingly important for protecting brand integrity and fulfilling corporate code of conduct obligations.

The association continues to encourage European businesses and public authorities to prioritise verified and compliant European remanufactured products as part of a responsible and transparent sourcing strategy.

Source: JUVE Patent

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2026 AGM Dortmund

May 27, 2026

ETIRA and The Recycler Live Bring the Industry Together in Dortmund

On 21 May 2026, ETIRA held its Annual Meeting during The Recycler Live & Trade Days in Dortmund, Germany, bringing together members and industry representatives from across Europe for discussions on the future of remanufacturing, compliance, sustainability, and circular economy policy.

With strong participation from across the membership, the event once again demonstrated the importance of face-to-face industry engagement at a time of significant regulatory and market change.

During the AGM, members reviewed and approved financial and statutory matters while also discussing ETIRA priorities and ongoing activities for the year ahead. As a member-driven organisation, the meeting provided an important opportunity for participants to contribute directly to the association’s direction and ongoing policy work.

Good conversations

Earlier in the day, ETIRA facilitated a private Industry Round Table bringing together approximately 35 delegates from across the sector. Discussions focused on how evolving remanufacturing business models align with new EU sustainability objectives and the growing recognition of remanufacturing as a strategic pillar of the circular economy.

Participants also examined the increasing impact of non-compliant imports and the continuing distortion of fair competition within the European market. Delegates exchanged views on how the industry can better respond to regulatory, environmental, and enforcement challenges while protecting high-quality European remanufacturing operations.

Additional discussions focused on upcoming EU Ecodesign Regulation measures,

Brussels Brief

broader circular economy policies, empties collection requirements, and the increasing digitalisation of collection and waste systems through DIWASS. Participants agreed that the future of cartridge remanufacturing in Europe remains closely linked to effective collection systems and the continued availability of reusable OEM cartridges.

ETIRA representatives also contributed to the show’s briefing programme through a series of presentations covering compliance developments, sustainability, market trends, and wider industry challenges.

Throughout the event, ETIRA maintained an open booth where members, partners, and visitors could meet, exchange views, and discuss current market developments directly with the association team.

ETIRA members were also strongly represented during The Recycler Annual

Awards presentation held during the evening networking reception. ETIRA members Altkin, Copyclic, Katun, KMP, and Integral were all recognised during the awards ceremony, reflecting the continued strength and innovation of the European remanufacturing sector.

The award for Remanufacturer of the Year was presented to Altkin following an extremely close public vote. Just eight votes behind was CM Printing GmbH, demonstrating the strong support both companies received across the industry.

The evening reception, kindly sponsored by ETIRA member SAPI, provided an excellent opportunity for delegates to continue discussions, strengthen business relationships, and celebrate industry achievements in an informal setting.

ETIRA extends its sincere thanks to the organisers of The Recycler Live & Trade Days, including Editor and Publisher of The Recycler, Stefanie Unland and David Connett of Connett & Unland GbR, as well as all sponsors, speakers, exhibitors, and participants who contributed to the success of the event.

As regulatory and market pressures continue to accelerate across Europe, ETIRA will continue supporting members through advocacy, compliance guidance, industry coordination, and the promotion of sustainable remanufacturing throughout the European market.

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