ETIRA comments on EU plans for Circular Economy Act

November 10, 2025

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.