COVID-19: Slowdown affecting remanufacturing

July 3, 2020

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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ETIRA welcomes the forthcoming EU Circular Economy Action plan

February 10, 2020

Draft paper on EU Circular Economy Action Plan announces regulatory measures on printers and consumables in Eco-design Directive promoting circularity in energy-related products.

Brussels, 10 February 2020 – A draft Communication from the EU Commission on the EU Circular Economy Action Plan says that as a priority, regulatory measures for printers and consumables such as cartridges, will be included in the EU eco-design Directive promoting circularity in energy-related products (2020-2024 Working Plan).

ETIRA acknowledges the strong determination and congratulates the EU Commission and the member states to speed up and advance the circular economy, for a cleaner and more competitive Europe, something that has been in ETIRA’s DNA since it was created.

Javier Martinez, President of ETIRA, commented on the draft proposals. “Waste prevention, green jobs creation and climate change defence actions, are all well addressed in the draft plan. We are pleased that following ETIRA’s long term campaign, we now see printers and cartridges as one of the priority eco-design actions for the EU.  This is something ETIRA has been asking for quite some time, and ETIRA is fully committed to it!

The plan represents a huge opportunity to rebalance the market, which up to now has been challenged because of imported non-compliant products.

As Europe transitions from a linear to a circular economy model, it is crucial that all parties move forward together, and that the doors to Europe are closed to infringing products.

ETIRA continues to support and makes every possible effort to transition to a Circular Economy, which empowers consumers, enables real reduction of waste, delivers a cleaner Europe, and generates new green jobs” .

ETIRA responds to Actionable Intelligence White Paper

November 20, 2019

ETIRA responds to the recently published white paper that charts how a premium new build Single Use Cartridge is poised to change the printer supplies market.

Recently US research firm Actionable Intelligence published a free white paper “Premium Compatibles Poised to Fundamentally Change Third-Party Printer Supplies Market” this white paper charts the evolution of the premium compatible cartridge and its potential impact on the market.

ETIRA was disappointed by the biased content of the Actionable Intelligence white paper, assuming that the viewpoint taken may have been influenced by the party or parties commissioning this work.

The focus of the report, praising the advantages of non-infringing SUC (single-use-cartridges), is based on price and IP or regulatory compliance, for which there is a legal requirement and so this is not considered to be a unique selling point. Other aspects such as quality, emissions, health, safety and economic sustainability are seemingly not considered relevant enough to be highlighted in this validation.

In cartridge tests which ETIRA has conducted in the past, we have found violations of chemical legislation and European law apparently across the board of SUC manufacturers, also including leading brands.

We assume that for advanced players it will be possible to manufacture chemically safe, legislation and IP compliant products as stated in the White paper.

But this will come at a cost. Not only at a monetary cost for the buyer but also at a cost for society and the environment.

That SUC manufacturers pay these costs for compliance has not always been the case in the past and has yet to be proven.

That our society would be paying the price for an increased share of SUC and a further reduction of locally remanufactured product is a fact.  It is not just that plastic waste ends up in landfill, but also the loss of local jobs and the unsustainability of the supply chain that are clear and negative factors of SUCs.

According to the European Parliament remanufacturing represents the “Actual mandate of society and the most important innovation need towards the future.”

We are convinced that the authorities and end-users in the EU and elsewhere will continue to increasingly demand environmentally sustainable, society friendly, high-quality and low-priced printing consumables which are remanufactured locally.

For further facts and assessment, we recommend reading a compelling and highly informative document produced under the EU commission mandate which supports our standpoint:

The cartridge remanufacturing study by Oakdene Hollins which you can download here.”

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Reusable chips on cartridges

October 17, 2019

ETIRA welcomes Brother Industries’ efforts on eco-design  and  environment, by allowing easier cartridge reuse

ETIRA, the European Toner and Inkjet Remanufacturers  Association welcomes, recognizes and congratulates Brother Industries on its latest strategy and action in favour of a cleaner Europe, and endorsing cartridge remanufacturing as a top priority.

Brother has fitted chips on recent cartridge models, and although the independent cartridge remanufacturing industry initially feared these chips would hinder and obstruct remanufacturing of the cartridge (like chips from most OEMs do!),  this is not the case with these particular Brother chips.  When these cartridges run empty, their chips can be easily reused time and time again.  And while this chip protects Brother’s IP -rights, it does not obstruct remanufacturing of the cartridge by independent cartridge remanufacturers.

In ETIRA’s view, this Brother strategy represents a key milestone in the fight against single-use cartridges (“SUCK”s as they are known in the market), and addresses the needs of our society which calls for product reuse and meets the European Directive on Eco-Design.

It also represents a major step forward into applying the “4R”- hierarchy,  which places preparation for reuse and remanufacturing above other options like mere recycling of the materials, incineration or landfill.

ETIRA calls on all other printer manufacturers and the European authorities to follow the example set by Brother. Chips can enhance cartridge functionality but must never hinder cartridge reuse.

We also ask for EU-wide mandatory and increasing minimum reuse thresholds for cartridges.  This is what some EU member states, that are truly aware of the damage that single-use plastic cartridges represent to the European environment, are already calling for.

Cartridges are WEEE, electronic waste, and as such their preparation for reuse is the top priority, as  WEEE  account for  70% of toxicity on waste.

For this, there should be an obligation  on printer manufacturers to share data with 3rd  parties under  a license  agreement, similar  to the arrangements existing in the car industry where  manufacturers  are  obliged  to  supply  independent  3rd  party  repairers all  information  they require to  do maintenance  and  repair  of  all  vehicles,  including software,  parts  catalogues, manuals, etc.

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ETIRA/ THE RECYCLER LIVE report

June 28, 2019

ETIRA/ THE RECYCLER LIVE MEET IN BRUSSELS:  RECORD ATTENDANCE – JAVIER MARTINEZ ELECTED PRESIDENT

Interesting speakers and networking in a 2-day session

On 27-28 June 2019, ETIRA held its annual meeting in Brussels, in the context of the  “The Recycler Live Europe” conference. With over 90 delegates it was again the #1 event to meet fellow industry members and hear the latest industry data.  ETIRA  thanks organisers The Recycler and David Connett for a great event!

        

On Thursday, expert Zoltan Matyas spoke on Digital Marketing, and Keypoint Intelligence’s Andrew Carroll showed latest industry market data: they expect the toner B&W aftermarket share to grow somewhat, but clones remain a concern. Nubeprint addressed security in the internet, and Italian industry experts tackled blockchain options to trace the flow of cartridges. Drinks and dinner allowed for great networking. On Friday, UK remanufacturer ECS highlighted the concerns of single-use plastics. Chip supplier APEX elaborated on firmware updates issues.  And Lauren Rabbitte drew the crowds with her take on waste and how to avoid it. The rest of the morning was dedicated to EU issues: David Fitzsimons of the EU Remanufacturing Council showed how they can help lobby EU bodies to promote product reuse. Javier Martinez and Vincent van Dijk updated the floor on our EU lobby successes in Green Public Procurement, the Voluntary Agreement, and a possible EU Ecolabel for reman cartridges (PowerPoint available). After lunch, David Connett wrapped up the event with many interesting views on the overall market.

At the ETIRA “Member’s Only” general meeting on Thursday, members elected Javier Martinez (Turbon) as their new President. Also re-elected were Gerwald van der Gijp (Vice-President), Jan-Michael Sieg, and David Connett. Newly appointed Board members include Volker Kappius (Delacamp), Peter Knak (IMEX), and Milan Banjac (TIN Group). Christian Wernhart and Jörgen Wonisch stepped down from the Board, ETIRA thanks them for their service.  At the meeting, ETIRA members discussed the new strategy of the association. We will enhance our communications and outreach in traditional and social media, and set up working groups to address selected topics. The newly appointed Board of Directors will further elaborate its 2019-2020 work programme in the coming months.

ETIRA also welcomed several new members: REEQ (NL), Delacamp (Hamburg, D), WTA (Suhl, D) and Recoll (Etten-Leur, NL) and approved the 2018 finances and 2019 budget.

 

ETIRA kindly thanks the sponsors for making this event possible: ECS, APEX, SPEED, Nubeprint,  Armor, Biuromax and Lightwords

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ETIRA CALLS FOR INCREASED RoHS CHECKS ON IMPORTED TONER & INKJET CARTRIDGES

March 26, 2019

Independent tests were undertaken by the German test lab LGA show that imported new non-OEM toner cartridges containing high levels of decaBDE breach RoHS safety limits

Brussels, 27 September 2018: – An article published in German industry magazine Digital Imaging this week reveals high levels of Decabromidiphenylether (decaBDE) in imported newbuilt non-OEM toner cartridges from two well-known brands. The story is based on tests done by the independent German test lab LGA. DecaBDE is a flame retardant found in IT and telecommunications equipment, such as printers and copying equipment. Flame retardants have been widely used in plastics of electrical appliances to mitigate fire and explosion risks. In February 2017 the European Commission added decaBDE to the REACH Annex XVII list of restricted substances, because emissions and widespread distribution of decaBDE in the environment creates a high potential for long-term (health) exposure for humans.

ETIRA, the European Toner and Inkjet Remanufacturing association is calling for the EU and member states to actively ensure that all cartridges imported into the European Union comply in every manner with European WEEE, REACH and RoHS directives and intellectual property regulations to protect the health and well-being of EU citizens and the environment.

ETIRA is also calling for the EU to mandate that all toner and inkjet cartridges placed on the market are designed and manufactured so that they are suitable for reuse as a cartridge.  ETIRA again stresses that for consumers and businesses, the best option is a remanufactured OEM cartridge, as supplied by the 3,000 companies across Europe. Remanufactured OEM cartridges are less expensive than new OEM cartridges but are 100% environment-friendly.

Europe consumes over 130 million toner cartridges a year, while the total toner and inkjet market is worth €17 billion. More than 5 million toner cartridges are new non-OEM cartridges, and they may not be suitable for reuse and may require specialised handling and material recovery.  Eliminating toxic products from the market and ensuring cartridges are reused more often could generate more than 16,000 new SME jobs across the European Union.

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June 2018: ETIRA AGM / THE RECYCLER LIVE event in Budapest !!!

Learning the latest industry news and networking over drinks and dinner!

90+ delegates attend  – ETIRA elects new Board of Directors – David Connett becomes President – ETIRA thanks outgoing President Christian Wernhart 

On the 21-22 June 2018, ETIRA met in Budapest, Hungary for its annual member meeting, and for The Recycler Live Conference. The event was a top opportunity for networking and learning, held this year at the beautiful Corinthia hotel. With 90+ delegates, and organised by The Recycler magazine, The Recycler Live Conference is the 2nd largest industry event in Europe after remanexpo@paperworld.

On Thursday, ETIRA held its internal Board meeting and annual statutory meeting. The association approved its 2017 financial statements and reset its 2018 budget. Members evaluated the 2017/2018 activities and the work done by ETIRA in the past 12 months, They also assessed the priorities for 2018.

Guenin - kopie

David Connett (r.) also thanked outgoing Treasurer Philippe Guenin (LVL) for his years of service to oversee the association’s finances. Board Member Gerwald van der Gijp (Armor) will succeed Philippe in this role.

Wernhart - kopie

Incoming President David Connett (l.) says thank you and farewell to Christian Wernhart  (Embatex) after 12 successful years at the helm of the European cartridge remanufacturing trade association.

Friday saw an impressive group of speakers addressing the floor on many topics facing remanufacturers today. Industry magazine The Recycler will report extensively on the many presentations. And the Thursday Cocktail and Dinner were great for informal networking and new business opportunities!

ETIRA elects new Board of Directors

On Thursday, ETIRA elected a new Board of Directors for the mandate 2018-2020. President Christian Wernhart (Embatex) stepped down after 12 years at the head of the association but will continue as a regular Board member.  David Connett, founding Member of ETIRA and long-time Vice-President, succeeded Wernhart as President. Also stepping down were Stephanie Unland (The Recycler) and Treasurer Philippe GUENIN (LVL).  ETIRA thanked all three for their support throughout the many years! Reappointed members of the Board include ARMOR’s Gerwald van der Gijp (elected as new Treasurer), Jörgen Wonisch (Greenman), Jan-Michael Sieg (KMP)  and Javier Martinez (Consuprint).

Former editor of The Recycler David Connett will take up the role of President at a crucial juncture. Due to the tough market environment and changes among the membership, the association is facing new challenges. Connett is keen to address those head-on: for ETIRA, member interests come first. Also, a larger focus on conveying the reman message to the outside world will bring new boosts for the industry as a whole.

ETIRA thanks organisers The Recycler magazine and the sponsors for a very successful 2-day event in Budapest!

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February 2018: EU-commissioned study on cartridge market clearly concludes: more regulatory action is needed to promote cartridge reuse  

The EU’s “Study on the implementation of product design requirements set out in Article 4 of the WEEE Directive   –  The case of re-usability of printer cartridges” came out in late February 2018.  It found that the cartridge market is very competitive, but the regulatory environment is not well suited to promoting reuse of products or encouraging dematerialisation and greater material efficiency. Significant alterations are proposed. The study writers promote using the Extended Producer Responsibility (EPR) as key to enhancing overall cartridge re-use.

Re. market data, they say that clones represent 5% of toner and inkjet markets respectively (which seems a serious underestimate).  On the OEM’s Voluntary Agreement Imaging Equipment, the study says that its data shows the VA does not promote cartridge reuse. The study suggests to revise the VA, and include parameters on lower emissions of printing. The car industry has examples of such mandatory CO2 reduction targets. Reducing cartridge complexity (clever chips !) can be one of the ways to do that. On the Ecolabel, the study supports developing an EU Ecolabel criteria for remanufactured cartridges (as requested by ETIRA).

The study identified concerns and corresponding actions as follows:

  • Creating a level playing field for the new and re-use/second-hand markets.
  • Consolidating patent holder and OEM protection and second user rights
  • Improving design for reuse, recycling and recovery
  • Ensuring reused cartridge performance.
  • Improving re-use performance disclosure.

To improve the market situation for both legitimate new and reused cartridges, a range of measures is proposed for consideration:

  • Addressing the issue of ‘rogue clone’ imports
  • Ensuring reuse agents do not misrepresent reused units as OEM products.
  • Improving access to cartridge design and consumables specifications
  • Revising the EU GPP criteria to address ‘remanufactured and refilled cartridges.
  • Improving user information on all cartridge packaging to reveal true performance.
  • Creating a rating system for cartridge quality (‘failure rate’) matched to user expectations.
  • Rationalising acceptable phrases to be used to describe new and reused cartridges.
  • Reviewing the Voluntary Agreement so that data on rates of take-back, re-use, recycling and other recovery operations is routinely collected and published.
  • Expanding the scope of actions by producers of cartridges to promote and support the reuse option as an alternative to take-back.

 

In 2016/2017, ETIRA had provided substantial input to the writers of the study. We are glad to see that it now identifies current OEM market behaviour as not contributing to the promotion of cartridge reuse, and takes on board several of our recommendations to address this problem. We will now reach out to regulators to put this into action!

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