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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EU Customs Update

May 8, 2026

EU Customs Reform Targets Non-Compliant Imports and E-Commerce Loopholes

New rules shift responsibility to platforms and introduce stricter enforcement tools across the EU market

A provisional agreement between the European Parliament and the Council marks a significant step forward in the reform of the Union Customs Code, with a strong focus on addressing the rapid growth of e-commerce imports, product safety, and enforcement efficiency.

The reform responds to a fundamental challenge: the sheer volume of low-value parcels entering the EU from non-EU countries. In 2024 alone, an estimated 5.8 billion such parcels were imported, placing increasing pressure on customs authorities and raising concerns about compliance with EU regulations.

A shift in responsibility

One of the most important changes is the redefinition of responsibility.

Under the new rules, e-commerce platforms and sellers facilitating distance sales into the EU will be treated as importers. This means they will be required to:

  • ensure goods comply with EU legislation
  • provide full customs data
  • pay or guarantee applicable duties and fees

This measure aims to close long-standing loopholes that have allowed non-compliant goods to enter the EU market via complex or opaque supply chains.

New handling fee for individual parcels

A new handling fee will be introduced for goods shipped directly from non-EU countries to EU consumers. The objective is to reflect the real cost of processing the growing number of individual parcels.

The fee will:

  • be set by the European Commission
  • be reviewed every two years
  • apply no later than November 2026

Importantly, the fee will be charged to the responsible economic operator, not directly to consumers.

Incentives for structured supply chains

The reform also encourages the use of EU-based warehouses and bulk imports.

Goods imported in larger consignments and distributed within the EU will benefit from:

  • lower handling costs
  • more efficient customs processing

This approach supports better traceability and enforcement, while discouraging fragmented, high-volume parcel shipments that are harder to control.

Stronger enforcement and penalties

Companies that repeatedly fail to comply with EU rules will face stricter consequences, including:

  • fines ranging from 1% to 6% of annual import value
  • loss of trusted trader or AEO status
  • classification as high-risk operators

These measures signal a clear shift towards more robust enforcement across the single market.

A new EU Customs Authority

The reform establishes a new EU Customs Authority (EUCA), to be based in Lille, France.

The Authority will:

  • coordinate customs cooperation across member states
  • oversee risk management
  • manage a new EU customs data hub

The data hub will replace over 100 existing IT systems and aims to provide a real-time, integrated overview of goods entering the EU.

ETIRA perspective

For ETIRA, the reform represents an important recognition of the challenges posed by non-compliant imports and fragmented supply chains.

The shift of responsibility to platforms, combined with stronger enforcement tools, has the potential to:

  • improve product compliance
  • create fairer competition for European businesses
  • reduce the flow of non-compliant consumables entering the market

However, effective implementation will be critical. Ensuring that high-risk product categories, including printer consumables, are properly monitored and enforced remains essential.

The agreement now awaits formal approval by the European Parliament and the Council before entering into force.

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If You Import or Sell Cartridges in the EU

February 11, 2026

Printer cartridges undergoing an EU compliance inspection, with a checklist and EU compliance signage visible.

This Compliance Checklist Is Your Starting Point

If your company imports, sells, distributes, or places printer cartridges on the EU market, compliance is not optional, and it is no longer something that can be treated as a box-ticking exercise.

EU enforcement is increasing, responsibilities are expanding, and misunderstandings around who is legally responsible remain widespread. The result? Too many businesses are exposed to fines, product seizures, forced withdrawals, and in serious cases, criminal liability, often without realising it.

To help address this, ETIRA has published a practical EU Imported Cartridges Compliance Checklist, designed as a clear starting point for anyone involved in placing cartridges on the EU market.

Why a checklist?

Because most compliance failures do not occur by intent but by assumption.

Common examples ETIRA encounters include:

  • Importers assume compliance sits with the overseas supplier,
  • Distributors believing obligations stop at logistics,
  • Sellers misunderstanding of when CE marking is permitted,
  • Companies are underestimating the reach of REACH, CLP, WEEE, and GPSR obligations.

Compliance is not a sliding scale. Like being pregnant, you either are or you are not. There is no such thing as being “a little bit compliant”.

In reality, legal responsibility lies with the company that places the product on the EU market, regardless of where it was manufactured or remanufactured.

What the checklist covers

The checklist sets out ten core compliance areas that apply to new and reused cartridges, including:

  • EU presence and accountability,
  • Manufacturer and importer identification,
  • REACH obligations for chemicals and substances,
  • Safety Data Sheets and documentation,
  • Declarations of Conformity,
  • WEEE registration and take-back obligations,
  • Packaging compliance,
  • Correct and lawful use of CE marking,
  • Intellectual property and first-sale rules,
  • The new General Product Safety Regulation (GPSR).

Each point explains what must be done and, crucially, what can happen if it is ignored; from border detention and sales bans to heavy fines and, for REACH breaches, potential imprisonment.

This makes the checklist not just informative, but operational.

Why this matters now

Non-compliant cartridges cannot be reused or remanufactured. They become waste.

Every such cartridge costs the European industry money to dispose of, removes reusable cores from the circular economy, and undermines compliant businesses that invest in doing things properly. At the same time, enforcement authorities are increasingly focused on traceability, documentation, and accountability — especially for imported products.

In short, cost does not reveal compliance. Verification does.

Who should use this checklist?

This checklist is relevant if you are:

  • importing cartridges into the EU
  • selling cartridges under your own brand,
  • distributing products sourced outside the EU,
  • operating online marketplaces or fulfilment models,
  • remanufacturing or refurbishing cartridges for resale.

If you are involved at any point in placing cartridges on the EU market,  this checklist is where you should start.

Download the checklist

The EU Imported Cartridges Compliance Checklist is available now via ETIRA.

It is intended as a first step — a practical tool to help companies identify risks, ask the right questions, and avoid costly mistakes before enforcement does it for them.

Further guidance and deeper analysis will follow in upcoming ETIRA publications, but compliance always starts with understanding your obligations.

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Why you should b(r)other

January 28, 2026

ETIRA was recently asked to assess a toner cartridge offered for sale on the European market as a compatible alternative for a Brother TN-2420 cartridge, intended for use in EU-market Brother printers. The product was marketed as suitable for European models and presented as compliant with applicable EU requirements. At first glance, it appeared unremarkable. A closer inspection, however, revealed serious concerns.

Physical examination showed markings consistent with a non-European cartridge model, partially obscured or altered before sale. In practical terms, a cartridge originally designed for use outside the European market had been re-identified and placed on sale in Europe as an EU-market equivalent. That single discrepancy is sufficient to trigger a cascade of legal and compliance failures.

Under European law, the ability to remanufacture or resell a product depends on the first sale doctrine, also known as the principle of exhaustion. Intellectual property rights are exhausted only when a product has been lawfully placed on the market within the European Economic Area by the rights holder or with their consent. Where that first lawful EU sale never occurred, those rights are not exhausted. The product cannot be legally remanufactured or resold in Europe.

In this case, the original cartridge was not placed on the European market by the OEM. As a result, any remanufacture or resale of that cartridge within the EU infringes the OEM’s intellectual property rights. However, the implications extend beyond IP law alone.

Because the original product was never placed on the EU market, it was never subject to EU conformity assessment. There is therefore no valid EU Declaration of Conformity supporting its sale in Europe. Any CE marking applied to the cartridge, or its packaging, cannot lawfully stand. When such a product is imported and sold in the EU, the importer is effectively declaring compliance for a market the product was never designed or tested for.

Under Regulation (EU) 2019/1020, that declaration transfers full responsibility to the importer, who becomes the manufacturer of record. The importer assumes legal liability for conformity, safety, and compliance. Where that declaration is false, market surveillance authorities are empowered to intervene, seize products, order withdrawals, and impose penalties.

While many OEMs actively enforce their intellectual property rights, enforcement across the sector is not uniform. Some rights holders pursue infringements aggressively, while others act selectively or focus their resources elsewhere. In ETIRA’s experience, the full range of enforcement options available to rights holders is not always exercised. This can create the impression in the market that certain practices are tolerated, even where they are not lawful.

That impression is misplaced. The absence of enforcement does not create permission, nor does it limit the legal options available to rights holders or authorities. Compliance obligations exist independently of enforcement patterns, and market surveillance authorities assess legality based on the law, not on past enforcement decisions.

Beyond IP and CE compliance, there is a further consequence that is often overlooked. Cartridges imported in this way frequently cannot be reused by European remanufacturers. They fall outside established reuse streams, are incompatible with local processes, or carry legal uncertainty that makes reuse impractical. In many cases, they are diverted into disposal or OEM recycling schemes that were never designed to absorb this volume.

The result is a perverse outcome. Products imported under the guise of competition increase waste, undermine legitimate remanufacturing, and shift environmental responsibility onto Europe. European businesses and consumers are left paying to manage products that should never have been placed on the market in the first place.

For ETIRA, this case is not about one cartridge or one OEM ecosystem. It is an illustration of how misused compliance markings, re-identification practices, and weak enforcement signals distort the market and damage the circular economy. When one rule is ignored, many others fall with it.

ETIRA will continue to identify such practices, support its members in escalating concerns, and work with OEMs and market surveillance authorities to ensure that European law is applied consistently. Compliance is not a technical detail. It is the foundation of fair competition, environmental responsibility, and trust in the European market.

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ETIRA: Europe Needs Stronger Parcel Levies to Stop Illegal Cartridge Imports

December 16, 2025

The European Union is preparing to introduce in 2026 a new €3 EU-wide handling fee on low-value imports, alongside a growing number of national charges in countries such as Italy and Romania. The measures are intended to curb the huge volume of small parcels entering the bloc, more than 90 per cent of which originate in China and which often bypass essential compliance checks.

ETIRA has welcomed the move as an essential acknowledgement that low-value parcels generate real costs, but warned that €3 alone is far too low to deter non-compliant imports of cheap, single-use cartridges. The association argues that restoring market balance requires a combined approach: a border handling fee, plus proper recovery of WEEE take-back and end-of-life costs currently absorbed by compliant European operators.

To illustrate the scale of that burden, ETIRA uses €8 as a realistic benchmark for the average cost of managing non-compliant cartridges at end of life. While a small inkjet cartridge may cost only a few cents to dispose of, a large 2kg toner cartridge can cost €14 or more. Across the mix of products entering Europe, the average cost borne by the compliant industry sits close to eight euros per cartridge.

A spokesperson for the association said,
“Low-value parcels are entering the EU at unprecedented scale, and a €3 handling fee is a step in the right direction. But €3 does not cover WEEE obligations or take-back costs. Restoring balance requires €3 at the border plus around €8 to cover the real end-of-life burden created by non-compliant cartridges. Without that, illegal and non-compliant imports will continue to shift costs onto compliant European businesses.”

The warning comes as EU companies increase pressure on Brussels to act more swiftly. Some national governments have already taken their own measures. Romania has proposed a fee of 25 lei, and Italy is preparing a parcel tax to shield domestic industries from unfair online competition. Retail groups have cautioned that a patchwork of national charges could undermine the single market.

Momentum for stricter parcel controls is also growing outside the EU. In the United Kingdom, the government announced in its 2025 Budget that it will abolish the existing de minimis exemption for low-value imports, which currently allows goods worth less than £135 to enter the country without customs duty. A formal consultation is now underway, with implementation planned by March 2029. UK industry federations have warned that the loophole is enabling a surge in cheap, non-compliant imports from Asia — concerns that closely mirror those raised by ETIRA in the European market.

ETIRA argues that the solution lies in harmonised EU rules combined with meaningful enforcement. Stronger customs checks, mandatory verification of authorised representatives, and alignment with WEEE and EPR producer registers are essential steps. Without them, the forthcoming Ecodesign framework for imaging equipment will struggle to deliver real environmental improvements.

“Europe is trying to build a circular economy, yet millions of new-build cartridges that do not comply with European standards are still slipping in under low-value thresholds every week,” ETIRA noted. “Recognising the problem with a €3 fee is a start, but only a combined approach that also recovers real WEEE and take-back costs will deliver lasting change,”

ETIRA will continue engaging with EU and national policymakers to ensure that parcel-levy reforms support Europe’s reuse industry and strengthen compliance across the imaging sector.

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