February 2018: EU-commissioned study on cartridge market clearly concludes: more regulatory action is needed to promote cartridge reuse
March 26, 2019
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!