If You Import or Sell Cartridges in the EU
February 11, 2026
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.
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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ComplianceETIRA
EU
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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Integrity
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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EU momentum grows for binding reuse targets
December 3, 2025
New RREUSE report reinforces ETIRA’s call for separate reuse targets for printer cartridges
The European policy landscape is shifting in favour of reuse. A major new report from RREUSE, Targets for Reuse and Preparing for Reuse in the European Union, provides strong evidence that Europe needs separate, binding reuse targets across key product streams. This includes WEEE items such as printer cartridges, where the absence of dedicated reuse targets continues to undermine the waste hierarchy.
For ETIRA, the findings confirm what we have long argued. Recycling-only targets disadvantage reuse, create perverse incentives, and prevent the EU from capturing the environmental and social benefits of remanufacturing. With over 100 million toner cartridges collected each year in Europe, the introduction of cartridge-specific reuse and preparing-for-reuse targets is realistic, measurable, and urgently needed.
RREUSE findings validate ETIRA’s longstanding concerns
The RREUSE report makes several key points that directly support ETIRA’s policy position:
- Combined reuse and recycling targets do not work
The report notes that mixed targets incentivise recycling at the expense of reuse. This contradicts the waste hierarchy, which places preparing for reuse above recycling. RREUSE therefore calls for separate targets across all major product streams including WEEE. - WEEE reuse remains neglected
Despite years of discussion, the WEEE Directive still does not include dedicated reuse targets. RREUSE highlights the structural issue: EPR schemes tend to focus on recycling because it is easier and cheaper, leaving reuse operators underfunded and with limited access to the waste stream. For printer cartridges, this problem is acute and long recognised by ETIRA. - Evidence from Member States shows reuse targets are feasible
Flanders, France, the Netherlands, Ireland and others have already introduced reuse targets at regional or national level. Their experience shows that targets improve access to reusable goods, attract investment in reuse infrastructure, and deliver measurable climate benefits. - Reuse delivers major environmental and social gains
The report links reuse to significant reductions in CO₂ emissions and strong job creation potential, especially when implemented by social enterprises. These benefits apply equally to cartridge remanufacturing, which offers both carbon savings and local employment.
A shifting political environment
The publication comes at a moment of wider political momentum. In its 26 November 2025 resolution on unsafe and illegal products circulating on online marketplaces, the European Parliament demanded stronger and faster enforcement, including temporary suspension of non-compliant platforms in cases of repeated or systemic breaches.
This is directly relevant to the printer cartridge market. Non-EU sellers who disregard EU rules distort competition and undermine legitimate reuse operators. ETIRA therefore supports the Parliament’s call for decisive action, including coordinated EU enforcement and stronger obligations for platforms that place products on the market.
What this means for remanufactured printer cartridges
Printer cartridges have long been recognised by the Commission and the Parliament as priority consumables with high reuse value. Yet:
- There is no separate reuse or preparing-for-reuse target for cartridges under WEEE
- EPR schemes focus heavily on recycling rather than reuse
- Non-compliant imports continue to undermine legitimate EU operators
- Reuse data for cartridges is not adequately captured
The RREUSE report strengthens the argument that these gaps must be closed in the forthcoming review of the WEEE Directive.
ETIRA’s position
ETIRA calls on the European Commission to take the following steps within the upcoming legislative cycle:
- Introduce separate reuse and preparing-for-reuse targets for printer cartridges under the revised WEEE Directive.
- Require EPR schemes to finance preparing-for-reuse activities, not only recycling, in line with the waste hierarchy.
- Guarantee access to reusable cartridges for accredited reuse operators across Europe.
- Strengthen monitoring and reporting to ensure that cartridge reuse is measured accurately and consistently.
- Ensure consistent EU-level enforcement against non-compliant imports and platforms offering illegal or dangerous products.
These measures would deliver meaningful environmental gains, support the circular economy, and protect consumers while strengthening the legitimate remanufacturing industry.
Next steps
ETIRA will use the findings from the RREUSE report in its ongoing dialogue with DG Environment, the European Parliament, and national authorities. As the WEEE review progresses, ETIRA will advocate for cartridge-specific reuse targets as a practical and effective way to raise circularity and reduce waste across Europe.
ETIRA Board meets in Italy and visits Ecomondo 2025
November 10, 2025
On 5–6 November, the ETIRA Board of Directors met in Italy for its annual face-to-face meeting. This year, the session was combined with a visit to Ecomondo, the leading European exhibition for the green and circular economy, held annually at the Rimini Expo Centre.
Ecomondo brings together industrial groups, policymakers, stakeholders, opinion leaders, local authorities, research bodies, and institutions to assess strategies for the development of EU environmental policy. ETIRA Board members used the opportunity to engage with reuse organisations and Italian ecolabel bodies during their visit.
While in Rimini, the Board discussed the challenging market conditions faced by ETIRA members. To support its members, the association reaffirmed its commitment to fighting non-compliant new-build cartridges and will intensify outreach to authorities to help stop illegal imports at EU borders. ETIRA will also continue to inform customers about the risks of trading non-compliant, non-OEM products.
The Board also reviewed ETIRA’s 2026 PR strategy and trade show participation, and looked forward to the forthcoming publication of the Impact Assessment for the EU’s proposed Ecodesign Regulation for imaging equipment and cartridges. Under this future regulation, OEMs will be required to share firmware and software data with recognised repairers and remanufacturers for a reasonable fee — a key step forward for fair competition and sustainability.
ETIRA comments on EU plans for Circular Economy Act
The European Union is preparing a Circular Economy Act to enhance Europe’s economic security and competitiveness, while promoting more sustainable production, circular business models, and decarbonisation. The Act aims to facilitate the free movement of circular products, secondary raw materials, and waste. It will also increase the supply of high-quality recycled materials and stimulate demand for these materials across the EU.
Before drafting the law, the European Commission is calling for input from stakeholders. ETIRA has therefore urged the EU to provide urgent regulatory support for the reuse of cartridges as cartridges.
Our industry is under existential pressure, not only due to anti-reuse practices by original equipment manufacturers (OEMs), but also because of the surge of cheap, polluting, non-OEM single-use cartridges (SUCs) flooding into Europe from Southeast Asia.
ETIRA calls for immediate EU action to remove OEM barriers to cartridge reuse, including restrictions on access to empties. Third-party remanufacturers must have full and unrestricted access to OEM software, and printer firmware updates must not block the use of remanufactured cartridges. Furthermore, non-reusable, cheap, polluting SUCs should be banned from the EU market.
Public bodies should lead by example in promoting the reuse of cartridges. ETIRA therefore calls for the EU’s Green Public Procurement (GPP) criteria to be made mandatory.
The EU WEEE Directive should also be revised to include a dedicated target for the reuse of cartridges.
Finally, in EU waste law, used cartridges should be classified as raw materials, not waste. Current waste transport rules at the EU, national, and regional levels create unnecessary barriers to the remanufacturing of cartridges. ETIRA urges that excessive licensing be reduced and that rules be harmonised across the EU at a low-risk level.
ETIRA welcomes EU and national parcel levies, calls for stronger compliance to protect Europe’s reuse industry
October 21, 2025
The European Toner & Inkjet Remanufacturers Association (ETIRA) has welcomed the European Commission’s plans to introduce a €2 flat handling fee on small parcels imported from outside the EU, alongside national initiatives such as Romania’s proposed RON 25 (€5) levy starting in November 2025. The Association says these steps mark an important move towards fairer trade and a more level playing field between European and non-EU producers.
However, ETIRA warns that while these levies will help recover lost VAT and customs revenues, they do not address the environmental loopholes that continue to undermine the EU’s circular economy goals — especially in the imaging and printing sector.
“We support the levies as a first step towards fair competition,” said ETIRA Secretary General Vincent van Dijk. “But the environmental costs of imported cartridges are far higher than €2 per parcel. The real cost of collecting and recycling these products within Europe is closer to €8 per unit. Unless importers also contribute their fair share to waste management, compliant European producers will keep paying for the waste of those who don’t.”
ETIRA argues that the EU already has the necessary legal framework to close this gap — it simply needs to be enforced. The Association is calling for customs authorities to cross-check small-parcel imports against national WEEE and EPR producer-registration databases, and to verify that non-EU manufacturers have a valid Authorised Representative (AR) established within the Union.
“The law already requires that any non-EU manufacturer placing products on the EU market has an authorised representative here, legally responsible for compliance,” van Dijk added. “If customs authorities checked that each import has a registered producer or AR before release, we’d instantly stop free-riders and hold someone accountable for non-compliance.”
Looking ahead, ETIRA welcomed the forthcoming Ecodesign for Imaging Equipment Regulationwhich will establish design and reuse requirements for printers and cartridges. The Association stressed that strong customs and compliance systems are essential to make this legislation effective.
“Ecodesign without enforcement will not deliver,” van Dijk concluded. “We urge the European Commission and Member States to coordinate customs, WEEE, and market-surveillance authorities so that only compliant, reusable products enter the EU market. The tools already exist, what’s needed now is the political will to use them. Europe’s circular economy depends on it.”
New EU Ecodesign Rules for Smartphones – A Glimpse into the Future for Printing Equipment
October 2, 2025
This summer, the EU’s new Ecodesign and Energy Labelling Regulations for mobile phones and tablets entered into force. From June 2025, smartphones, tablets, and other mobile devices placed on the EU market will need to comply with strict new requirements for energy efficiency, durability, reparability, and recyclability.
What’s new?
The regulations introduce a series of obligations for manufacturers and suppliers:
- Spare parts & repair: mandatory availability of key spare parts for up to 7 years, maximum delivery times, and easy access to repair and maintenance information.
- Durability & reuse: devices must meet standards for drop resistance, scratch resistance, dust and water protection, and battery endurance. They must also provide a secure factory reset to enable reuse.
- Recyclability: dismantling instructions and plastic marking requirements to improve recovery of critical raw materials.
- Energy labelling: smartphones and tablets will now carry an EU energy label, informing consumers about battery life, repairability, resistance to drops, and water protection.
- Market surveillance: suppliers must maintain technical documentation for 10 years and ensure products are CE-marked and fully traceable, with national authorities empowered to test and enforce compliance.
Why it matters for imaging equipment
For ETIRA, these new rules provide a preview of what may come for our industry. Concepts such as mandatory spare parts availability, design for repair, preparation for reuse, dismantling information, and stronger market surveillance are highly relevant for printers and imaging consumables.
If similar rules are extended to imaging equipment, they could significantly strengthen the remanufacturing industry by:
- Ensuring fair access to repair information and spare parts.
- Supporting preparation for reuse as a standard compliance requirement.
- Closing loopholes that allow non-compliant, non-recyclable products to undercut responsible European remanufacturers.
ETIRA’s perspective
These measures reflect the EU’s growing commitment to the circular economy. For our sector, they offer a glimpse of a more level playing field where reusability, compliance, and sustainability are prioritised over cheap disposability. ETIRA will continue to follow these developments closely and advocate for similar, strong ecodesign rules for imaging equipment.
👉 Read more about the new smartphone and tablet rules on the EU product portal.
ETIRA joins coalition calling for stronger EU rules on online marketplaces
September 18, 2025
E-commerce has transformed the way Europeans buy everything from toys to tech to printer cartridges. Yet behind the convenience of a click lies a growing risk: unsafe and non-compliant products entering the EU market without proper oversight.
Every year, billions of small parcels arrive in the EU from third countries. According to the European Commission, 4.6 billion parcels under €150 entered the EU in 2023. Many of these bypass EU safety and compliance checks, exposing consumers to unsafe products, fake labels, and goods that do not meet sustainability requirements. In the printing sector, this includes toner and ink cartridges sold online without meeting EU safety, chemical or recycling rules.
Marketplaces Escape Accountability
Under current EU law, online marketplaces are not recognised as economic operators. This means they are not legally responsible for verifying compliance of products sold by third-country sellers on their platforms. They act only if notified of violations. Existing laws, such as the Digital Services Act (DSA) and the General Product Safety Regulation (GPSR), have not closed this gap.
Key Recommendations
To protect consumers, the environment, and fair competition, a coalition of 63 organisations – including ETIRA – calls for decisive action:
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Mandatory EU economic operator for every product sold into the EU.
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Recognition of marketplaces as economic operators responsible for third-country sales.
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Enhanced obligations for marketplaces to verify compliance, ensure traceability, and uphold Extended Producer Responsibility (EPR).
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Improved traceability via integration of EU databases and the Digital Product Passport.
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Stronger customs checks and the swift abolition of the €150 de minimis exemption.
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Reinforced enforcement resources for market surveillance and customs authorities.
A Call to Action
Closing these loopholes is essential to safeguard consumers, protect the environment, and ensure fair competition for businesses playing by the rules. For Europe’s remanufacturers, this is not only a question of fairness but also of sustainability: compliant, reusable cartridges should not be undercut by non-compliant imports that evade EU law.
ETIRA urges EU policymakers to act swiftly. Stronger rules will not only protect consumers but also support Europe’s circular economy and create a level playing field for responsible businesses.
Read all details and the full declaration here.