ETIRA condemns confusing endusers regarding new vs. environment-friendly remanufactured cartridges

November 17, 2020

Using identical article numbers for both new and remanufactured Blue Angel certified cartridges can mislead customers who order green products.

Last week, German industry magazine Digital Imaging (DI) published an article(*)  about cartridges from Chinese supplier Ninestar. According to DI, the large Chinese supplier has been advertising since August that it had received the ‘Blue Angel’ accreditation cf. standard RAL DE-ZU 177 for several toner modules of their G&G brand. The Blue Angel environmental certification is only awarded to remanufactured toner cartridges. DI writes that test purchases have now shown that six G&G cartridges purchased at German firm Tonerdumping in recent weeks, are however 100 % newbuilt. And even though the Blue Angel logo was not affixed on these cartridges, they did have exactly the same manufacturers’ article numbers as the Blue Angel certified cartridges. 

ETIRA President Javier Martinez said: “We strongly condemn any confusion when it comes to the Blue Angel certification. Customers are being misled when they want to buy an environment-friendly product but in reality receive a single-use cartridge (“SUC’). A SUC cannot be reused but ends up in the landfill or clogs up the collection systems of remanufacturers.

Certification bodies must act fast and decisively against any confusion surrounding use of their logo. The Blue Angel eco-label is widely respected in our industry and by our customers. Remanufacturers have made great efforts to obtain the Blue Angel approval for their toners, and cannot accept that the benefits of the logo are used without doing the work for it. 

ETIRA welcomes that, as reported by DI, Blue Angel has removed the G&G cartridges from their homepage. Enforcing compliance with  standards is key for environmental and circular products. 

(*) http://di-branche.de/digital-imaging/topthemen/default.asp?top_item=52547&i_item=52547&top_step=15&top_start=1&rb=topthemen&top_rb=topthemen

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ETIRA calls for amendments to latest draft of the EU Voluntary Agreement for Imaging Equipment

October 29, 2020

The European Toner and Inkjet Remanufacturers Association (ETIRA) has issued a detailed response calling for amends to be made to the latest draft of the Voluntary Agreement for Imaging Equipment, released by Eurovaprint earlier this month.

The association, which represents inkjet and toner cartridge remanufacturers across the EU, says it acknowledges the proposal is a ‘useful step forward’ but urges amendments to be made, outlining its suggested minimum changes.

The aim of the draft Voluntary Agreement (VA) is to improve the environmental performance of imaging equipment products across the EU, through the creation of eco-design minimum requirements, supporting the EU’s Circular Economy Action Plan.

Javier Martinez, president of ETIRA, said: “ETIRA has always called for mandatory legislation to replace the Voluntary Agreement. In our view, only a mandatory approach can bring tangible and enforceable implementation of the goals defined under the Circular Economy Action Plan, because only a regulation is applicable to all market players.

“Legislation therefore continues to be our preferred option. However, ETIRA acknowledges that the October 2020 draft VA represents a useful step forward and, if the core objectives we continue to lobby for can be achieved through a more stringent voluntary agreement, ETIRA would be  interested to  participate and engage in the process, provided the proposal includes our suggested minimum amendments in line with EU Treaty, EU Circular Economy Action Plan and EU Eco-design directive.”

ETIRA’s suggested minimum amendments are:

  • The exemptions in Articles 9.2.1, 9.4. and 9.5.2 should all be removed. Excluding cartridges under contract or subscription means that a very large part of the cartridge market is excluded from the VA, resulting in less cartridge reuse in the EU;

  • A clear and ambitious re-use target for all cartridges marketed by the Original Equipment Manufacturers (OEMs) must be set: 45% within two years and 60% within four years. Without fixed targets, reuse of cartridges will not grow, in particular if contract or subscription sales are excluded;

  • Transparency on the Bilateral Agreements (BAs): There is a need for equal terms. Equal volume pricing, equal technical solutions, equal product range etc. need to be offered by an OEM signatory to all supporting signatories who want to agree a BA with that OEM signatory;

  • Criteria for qualifying as supporting signatory:  ETIRA calls for a transparent and non-discriminatory decision-making process as to who can and who cannot become supporting signatory;

  • The VA should be limited in time, e.g. maximum three-year period. During this period, the EU should prepare a regulation to replace the VA. ETIRA is happy to assist in this task;

  • ETIRA asks that the VA recognizes ISO standards EN 45552 , EN 45553  to  EN 45559 (resource  efficiency) and  also  findings  by  the  UNEP  resource  panel  on “Value  retention  Processes

ETIRA will be sharing its feedback on the draft VA with all stakeholders, such as EU and Member State authorities, NGO’s etc,.  

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New EU legislation set to hold manufacturers to account

October 13, 2020

New legislation, set to hold ink toner and printer manufacturers to account when it comes to complying with rules around substances of very high concern (SVHC) and product safety, has been welcomed by ETIRA.

The European Ink Toner and Remanufacturers Association (ETIRA) has given its approval to two new items of legislation introduced by the EU.

The first item of legislation comes into force from 5 January 2021, requiring all companies that supply products containing REACH Candidate List substances to submit information into the European Chemicals Agency’s SCIP Database.

The move affects all products on the EU market that contain a SVHC on the REACH Candidate List, with a concentration of more than 0.1% by mass.

The new legislation will make compliance efforts by manufacturers and other suppliers transparent to authorities and third parties, as well as proving particularly useful for waste processors and recyclers to determine the hazardous content in the products they process.

The second legislation item is the introduction of Market Surveillance Authorities, due to be launched in July 2021.

Introduced by the European Commission, the new regulation for market surveillance will require all products sold in the EU under Directive 2009/125/EC – whether sold directly, online or through a fulfilment service provider – to be registered with an official responsible party based in the EU.

A ‘responsible party’ can be a manufacturer, importer, distributor, fulfilment service provider or ‘authorised representative’.

Javier Martinez, president of ETIRA, said: “We are pleased to see these two items of legislation set to come into force across the EU within the next 12 months.

“Knowing who placed products on the EU market is key to holding suppliers and manufacturers to account when it comes to compliance with hazardous content and market surveillance. Earlier this year, two studies showed that many products, including cartridges, that are sold over the internet directly to end users, contained illegal and hazardous chemicals. The new legislation provides tools for the national authorities to ban products at the EU border and impose penalties on companies offering infringing products on the EU market. Online platforms will be required to fulfil the same obligations as other importers and will no longer be able to dodge their responsibility and liability for products offered on their websites etc.

 In the coming months, ETIRA and its members will signpost the authorities to online platforms and other “orphan’ cartridges that fail to comply with the new rules.

The two reports mentions are:

ETIRA report: https://www.etira.org/posts/etira-cautions-that-recent-toner-emission-tests-reveal-a-100-failure-rate/

European Chemicals Agency report: https://echa.europa.eu/-/1-in-4-imported-products-found-to-be-non-compliant-with-reach-and-clp For further information about ETIRA and its work, visit www.etira.org

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ETIRA welcomes EU’s new Green Procurement Policy (GPP) Criteria for Imaging Equipment tenders

September 14, 2020

  • The European Toner and Inkjet Remanufacturers Association (ETIRA) has welcomed the EU’s new GPP policy, after more than two years of lobbying  
  • The association and its members will now raise awareness of the new criteria across the EU Member States 
     

ETIRA, the European Toner and Inkjet Remanufacturers Association, has welcomed new criteria introduced by the EU to reduce the environmental footprint of printers and cartridges purchased through public tenders.  

The new Green Procurement Policy (GPP) Criteria for Imaging Equipment applies to printers, copiers, multifunctional devices and scanners, enabling public authorities to endorse sustainable printing by lowering the environmental impact of devices purchased, and favouring the use of remanufactured cartridges.

The new criteria, which also includes requirements for printers’ plastics, chemicals and emissions, have been in development by the EU’s scientific body – the Joint Research Centre (JRC) – since 2018, and the list was approved by the EU Commission in late July 2020.

Public bodies are being invited to use the guide, which is currently voluntary, when they solicit offers for imaging equipment and consumables through tenders.

ETIRA President, Javier Martinez

Javier Martinez, president of ETIRA, said: “The introduction of this new list of criteria within the European Union is an encouraging step forward towards a more sustainable future for the printing and ink and toner cartridge industry.

“We have been lobbying the EU for two years on this policy and participating in the development process while insisting that cartridge reuse is a vital part of the new criteria.

“By including a clear preference for remanufactured cartridges in the 2020 GPP criteria, the EU confirms that in terms of environmental performance, reusing your cartridge is better than buying a new one each time.

“Together with our members, we will now raise awareness of the criteria in EU countries to encourage public authorities to use the GPP criteria and in turn, lower the  environmental footprint of printing and cartridge use across EU member states.”

The GPP is made up of two elements – ‘core criteria’ designed to allow for easy application, focusing on the environmental performance of a product, and ‘comprehensive criteria’ for use by authorities that want to lead the way in supporting innovative environmental goals. 

Key takeaways from the new policy are outlined below, with the full criteria available here.

  • Printers must comply with EU regulations on REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) WEEE (Waste Electrical and Electronic Equipment Directive) and other regular EU rules and laws.
    • Printers must meet standards for emissions, noise, energy consumption, and not contain hazardous substances beyond limits.
    • They must offer warranties and allow the use of remanufactured cartridges and any firmware update must not hinder the use of reused or remanufactured consumables.
    • Take-back programmes are also requested, and there are criteria for consumables supplied under a managed print contract. Cartridges must comply with page yield standards and must not be designed to limit the ability to reuse or remanufacture them.

The GPP criteria also encourages an initial ‘fleet assessment’ to determine which machines need to be replaced and crucially, which ones can be kept, which will offer increased opportunities to reuse both cartridges and machines.

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HP firmware update: ETIRA urges HP to change course and take ‘path of sustainability’

July 29, 2020

The European Toner and Inkjet Remanufacturers Association (ETIRA) is urging HP to rethink its latest printer firmware update.

The update, version 2025A/2021B – released in July 2020 – affects HP OfficeJet 5220, 5255, 5230, 5232, HP ENVY 5020, 5032 and HP DeskJet 2621 devices.

In the past, similar updates have blocked out reused HP cartridges across the globe, causing significant financial damage to end-users, resulting in many claims against HP. ETIRA is hoping to avoid a similar situation again.

Javier Martinez, president of ETIRA, said: “It is quite clear that HP printer owners using reuse cartridges who update the firmware, may find that their cartridges no longer work, and this is down to HP. Its printers use something called ‘dynamic security’, which recognises cartridges that aren’t HP branded and stops them from working and this is unacceptable for a variety of important reasons.

“Firstly, the result of the overnight change is that reuse/remanufactured HP cartridges no longer function in the printer in which they are installed, and they may render remanufactured stock cartridges useless. End-users can no longer print, and this is especially painful in the current COVID-19 environment, where many are forced to use home printers to do their job.

ETIRA President, Javier Martinez

“Secondly, the resulting higher volume of non-working but full cartridges exponentially increases waste treatment risks, as treatment plants are designed to process empty cartridges, not full ones.

“And finally, but most important: this approach has an unnecessary and negative environmental impact as good products are wasted prematurely and unnecessarily. Reuse of a cartridge several times, followed by recycling its base materials is by far the preferred option as it reduces CO2 emissions by up to 45%-60%, and saves energy and natural resources.

“Our members will hold HP responsible and liable for all damages occurring from this update and under the new EU Circular Economy Action plan mandate and existing waste regulations, HP may find that its actions are considered an environmental offence.”

ETIRA has mentioned this issue to HP on numerous occasions but so far to no satisfactory conclusion. The association has now again written to the firm, raising its concerns.

Javier Martinez added: “HP’s printer cartridges business model is the opposite of sustainability, forcing end-users to buy a new cartridge each time instead of reusing it several times. It also renders reuse cartridges useless without cause and goes against the new EU policy to become carbon-neutral and promote reuse EU-wide.

“On behalf of our members and all those across Europe who use reusable cartridges, we urge HP to abandon this strategy of creating pollution  and take the path of sustainability instead which will allow consumers and third parties to easily reuse HP cartridges without being hindered by unnecessary firmware updates that block out remanufactured HP cartridges.”

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ETIRA and member firm Armor podcast promoting cartridge reuse

July 3, 2020

In June, ETIRA joined hands with our member firm Armor during a 1 hr podcast Dutch language broadcasted live on Dutch radio station New Business Radio. Armor’s Frans Hondmann and ETIRA’s Vincent van Dijk highlighted the benefits for end-users of reusing cartridges. We raised awareness about the lower CO 2 emissions and use of natural resources. We also informed the listeners about the unfair barriers to reuse erected by printer manufacturers, and about the risks when buying cheap non-OEM newbuilds from Asia that pollute the environment and endanger your health.

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Leaving the OEM logo on a remanufactured OEM cartridge:

Remanufacturers often put the question: is it allowed to leave the OEM logo on the remanufactured cartridge? 

ETIRA recently commissioned a legal opinion to answer this question and the answer is set out in our 20 page analysis which is available exclusively and free of charge, to ETIRA members. If you have not received your copy please contact the secretariat at info@etira.org.

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COVID-19: Slowdown affecting remanufacturing

Since the start of the pandemic, many remanufacturers across Europe have experienced falls in sales. For some the damage was very severe, for some it was relatively limited. Some even experienced an increase in parts of their business: thanks to the large number of employees now forced to work from home, sales of certain products (inkjets) saw double-digit growth. Part of that growth may well prove to be permanent. Setbacks were the firmware updates that some OEM’s continue to implement. 

Also at ETIRA, the pandemic caused a slowdown in activities, as you will have noticed the low frequency of this Newsletter. But that was not only due to the pandemic: as part of our new PR and media strategy, ETIRA is making more use of other channels than just this Newsletter for its outreach. 

Behind the scenes, the ETIRA Board of Directors remained very active. The main topic is the 2020 EU’s Action Plan on the Circular Economy. Here the multi-annual ETIRA lobby efforts again paid off 100%: the programme announces legislation to promote circularity for IT products, including printers and cartridges unless an ambitious Voluntary Agreement Imaging Equipment is agreed in the next few months. The Board also discusses leaving the OEM logos on remans, a new ETIRA logo’ distinguishing remanufactured cartridges from non-OEM newbuilds, PR work, etc. 

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ETIRA cautions that recent new build Toner Emission Tests reveal a 100% failure rate

April 14, 2020

Imported non-OEM new build cartridges sourced in Europe were tested by the LGA and 100% failed, underlining again that such products are a threat to our health and the environment.

As part of its product safety remit, ETIRA recently purchased on Amazon and then commissioned the testing of three non-OEM new build toner cartridges by Germany’s expert LGA test centre. Additionally, five further tests by the LGA were commissioned by other industry players concerned about product safety.  The result was stunning: All eight new non-OEM newbuild cartridges failed the LGA emissions tests for multiple reasons. By contrast, a test of two toners widely used by European remanufacturers passed the LGA emissions test.

(Full details of the tests can be downloaded here).

The range of failures included excessive levels of cobalt, benzene and naphthalene. Four cartridges had levels ranging from 37 to 44 mg/kg of cobalt,  which according to the European Chemicals Agency harmonised classification and labelling (CLP00) approved by the European Union ECHA), may cause long lasting harmful effects to aquatic life, may cause an allergic skin reaction and may cause allergy or asthma symptoms or breathing difficulties if inhaled.

Benzene was also detected at a level of 0.9 mg/kg, 157% above the LGA threshold of 0.35 mg/kg.  The ECHA classification states that Benzene may be fatal if swallowed and enters airways, may cause genetic defects, may cause cancer, causes damage to organs through prolonged or repeated exposure, is a highly flammable liquid and vapour causes serious eye irritation and causes skin irritation. 

Naphthalene was present in seven of the tested cartridges at a level of between 3.8 and 7.5 mg/kg, between 280% and 650% above the LGA test threshold of 1.0 mg/kg. According to the ECHA classification, this substance is very toxic to aquatic life, with long lasting effects, is harmful if swallowed and is suspected of causing cancer.

One test cartridge contained 86 mg/kg of Bis(2-methoxyethyl) ether, which is more than 8500% above the LGA test threshold of 1.0 mg/kg. According to the ECHA classification, this substance may damage fertility and may damage the unborn child and is a flammable liquid and vapour.

In the past, toner powders extensively used in the European remanufacturing sector have been tested by the LGA and they easily passed this stringent emissions test. 

As the European Union moves towards a circular economy, one of the key goals will be addressing the presence of hazardous chemicals in products.  Javier Martinez, President of ETIRA said “ These tests show that very often it is dangerous to buy newbuild non-OEM cartridges: by offering products containing dirty toners, traders are playing with the health of their customers.  The current coronavirus pandemic will heighten the awareness and need for the products we use to be safe and reliable, and at the same time the standards required for CE and other certifications applied to goods entering the EU must be rigorously checked.”

  1. TVOC = total volatile organic compounds in forming the corresponding totals. all individually quantified components are included with a mass-based emission rate of ≥ 0.3 mg/kg. Insofar as possible concentrations of all individual compounds are quantified against authentic standard. Unidentified substances are quantified on basis of substance groups against substance-like compounds from this group.
  2. CMR = carcinogenic (C). mutagenic (M). toxic to reproduction (R) classified according to the EU classification with reference to Annex VI of Regulation (EC) No.1272/2008 (GHS) of Categories 1A and 1B and according to the national classification in compliance with TRGS 905 or the MAK and BAT Value Lists of the DFG (German Research Foundation). (Categories 1 and 2 and Pregnancy Group A and B).
  3. According to the EU classification with reference to Annex VI of Regulation (EC) No. 1272/2008 (GHS)
  4. According to the MAK and BAT Value Lists of the DFG (German Research Foundation). (Categories 1 and 2 and Pregnancy Group A and B).

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