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.