If You Import or Sell Cartridges in the EU

February 11, 2026

Printer cartridges undergoing an EU compliance inspection, with a checklist and EU compliance signage visible.

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.

Download the checklist

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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Circular Planet: A Closed-Loop Farce Disguised as Sustainability?

January 22, 2025

Circular Planet, the much-celebrated OEM-led cartridge collection initiative, recently marked its first anniversary, hailing the collection of 2.6 million print consumables and boasting that nearly 40% were “sent back to OEMs for reuse.” On the surface, it seems like a sustainability success story, but upon closer inspection, this programme raises significant concerns.

What Does “Reuse” Actually Mean?

The term “reuse” is at the heart of Circular Planet’s claims, but its meaning is far from clear. Does it mean cartridges are reused as cartridges — cleaned, refilled, and returned to market? Or does it refer to the mere recycling of parts? The lack of clarity leaves room for significant greenwashing.

Moreover, sending 40% of the collected cartridges “back to OEMs” does not guarantee they are reused in any meaningful way. OEMs could just as easily dismantle, recycle, or even discard these cartridges without ever returning them to their intended purpose. Without transparency or third-party oversight, these claims of “reuse” seem hollow at best and misleading at worst.

Numbers That Don’t Add Up

Circular Planet’s collection of 2.6 million cartridges represents less than 1% of the estimated 300–400 million OEM cartridges placed on the European market annually. Of those, only around one million cartridges were supposedly “reused” — a figure that pales in comparison to the programme’s lofty sustainability rhetoric.

And what about the logistics? The idea of cartridges collected in southern Spain being sent to the Netherlands, processed at a Polish facility, and then returned to the original printer in Spain raises serious questions about economic, environmental, and social benefits. Is this truly circularity, or just a wasteful shuffle masked as sustainability?

Undermining the Reuse Sector

For over 25 years, independent remanufacturers have championed true circularity by reusing cartridges multiple times, reducing waste and lowering environmental impact. In contrast, Circular Planet centralises cartridge returns to OEMs, cutting off access to high-quality reusable cores for the independent sector.

For every cartridge collected under Circular Planet, one less cartridge is available for independent remanufacturers, who have long demonstrated their commitment to reducing the environmental footprint of print consumables. This monopolisation of the cartridge lifecycle undermines open circularity and exacerbates the supply shortage, leaving smaller players in the reuse sector struggling to survive.

A Veil for Unfair Competition?

OEM control of the cartridge collection and reuse process raises serious questions about anti-competitive practices. By monopolising access to used cartridges, OEMs can restrict independent remanufacturers from competing, stifling consumer choice and driving up costs. This lack of competition benefits no one except the OEMs themselves.

Is this a collaborative sustainability effort, or simply a cartel-like operation disguised as an environmental initiative? The absence of freely available empty cores and transparent pricing reinforces these concerns.

The Way Forward

Circular Planet’s first year has revealed what’s possible — and what’s problematic. If the programme is to genuinely contribute to a sustainable future, it must redefine its approach:

  • Clarify “Reuse”: The term must unequivocally mean reuse as a cartridge, not mere recycling or disposal of parts.
  • Ensure Transparency: Independent audits must verify the fate of collected cartridges, holding OEMs accountable.
  • Collaborate with the Reuse Sector: Circularity must involve all stakeholders, not just a monopolistic few.

At ETIRA, we call for a balanced approach that upholds the principles of the circular economy, ensuring sustainability is not just a corporate PR exercise. The next chapter of Circular Planet must be about inclusivity and genuine environmental stewardship. Let’s hold them accountable to that standard.

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Member Update – Special members only meeting

November 3, 2023

MARK YOUR DIARY: 12 DECEMBER AT 4 p.m.: ONLINE ETIRA MEMBER-ONLY INFO MEETING ON INDUSTRY REGULATION  – BE THERE! 

ETIRA invites all its members to an online meeting on 12 December to learn about the upcoming EU rules for our industry. The planned regulation is an industry-first and will materially impact how you can do your business for years. We already gave you some top-line info on 25 September, but now it is time for details. Members should be fully aware of the plans and express their views. So please don’t get caught off-guard:  Join us on 12 December at 4 p.m. for a virtual info and networking session with your fellow members!

Log-in details will follow in December.

The online meeting will also approve ETIRA’s new statutes. As mentioned before, changes in the overall Belgian legislation require groups like ETIRA to adjust their laws to conform to the new rules. The changes are mainly administrative.

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ETIRA to exhibit at Remanexpo 2024

October 31, 2023

ETIRA and several members to exhibit with a dedicated pavilion at Remanexpo, Part of Ambiente, this coming 26 – 30 January.

ETIRA has confirmed its participation in Remanexpo, a prominent segment of the renowned Ambiente trade fair. Scheduled to take place from January 26 to 30, 2024, in Frankfurt, Germany, this event promises to be a pivotal platform for the promotion of sustainable printing solutions.

Visitors to the ETIRA Pavilion, nestled within Forum 1 Hall, can expect to gain valuable insights into the latest activities of the association and its positive lobbying activities that have a positive impact on the environment. Several ETIRA members are co-sponsoring the pavilion. Thus the pavilion will serve as a meeting point for industry professionals, offering a casual atmosphere for discussions and networking opportunities.

ARMOR Print Solutions SAS is one of the co-sponsors. Their CEO, Gerwald van der Gijp, said: “ARMOR Print Solutions is proud to endorse the ETIRA Pavilion on the Remanexpo show, illustrating that integrating sustainability and social responsibility into your core business strategy can lead to a thriving and prosperous business.”

ETIRA, a leading voice in the remanufacturing sector, will use the occasion to highlight its ongoing efforts in promoting sustainable printing practices and the benefits of remanufactured printer consumables. Attendees are encouraged to drop by for a friendly chat, a refreshing coffee, or even something a little stronger at 5 p.m. to toast to the future of sustainable printing.

“We are delighted to participate in the Remanexpo show, standing united with ETIRA to further our collective mission in advancing sustainable printing solutions.” Said Jan-Michael Seig, CEO of KMP AG, who is also co-sponsoring.

The ETIRA Pavilion’s presence at Remanexpo wouldn’t have been possible without the generous sponsorship of industry leaders. Other co-sponsors, including IMEX, Katun, Delacamp, and The Recycler, have all contributed to making this showcase a reality, emphasizing their commitment to sustainable printing and the role of remanufactured products in achieving this goal.

“The Recycler wholeheartedly supports ETIRA and the invaluable work they continue to do in championing sustainability within the printing industry. Through the ETIRA Pavilion at Remanexpo, ETIRA highlights its initiatives for the benefit of its members and the broader office printing community.” Commented Stefanie Unland, Editor and Publisher of The Recycler.

Peter Knak, General Manager at IMEX Europe, said: “Supporting the crucial work of ETIRA, our participation in the Remanexpo show underscores our commitment to eco-friendly printing practices.”

The pavilion is expected to be a hotbed of conversation, offering a glimpse into the latest developments in remanufacturing and upcoming legislation and services. This event is an excellent opportunity for businesses and individuals looking to reduce their environmental footprint without compromising on quality.

“ETIRA’s dedication to sustainable remanufacturing aligns with our values, and we are honoured to be part of the Remanexpo show in support of their vital efforts.” Said Heidi Boller, General Manager for Katun EMEA.

ETIRA’s presence at Remanexpo, supported by its esteemed sponsors, underscores the growing importance of sustainable printing solutions in today’s world. With a focus on reducing waste and promoting eco-conscious practices, this event is set to make a significant impact on the printing industry. Make sure to mark your calendars and visit the ETIRA Pavilion at Ambiente 2024 for a taste of the future of printing.

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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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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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