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.
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EU
New Ecodesign Proposals Unveiled
February 29, 2024
The European Union’s Joint Research Centre (JRC) has introduced ambitious ecodesign proposals to enhance the sustainability of printers and cartridges significantly. This initiative represents a pivotal shift towards mandatory regulatory measures, departing from the voluntary agreements that have characterised the sector since 2015. The JRC’s Preparatory Study outlines a comprehensive strategy focused on extending product lifespans, improving material efficiency, and fostering a circular economy.
Key proposals include increasing the durability and reparability of printers, setting mandatory page yield requirements for cartridges, and promoting the use of remanufactured cartridges. Additionally, the JRC advocates for optimising energy savings, paper consumption, and the incorporation of post-consumer recycled plastic in printer manufacturing.
ETIRA President Javier Martinez welcomed the proposals, highlighting their alignment with the EU’s Green Deal objectives and their potential to reduce the environmental footprint of printing significantly. As the EU prepares to translate these findings into draft regulation, ETIRA commits to collaborating with stakeholders to ensure these positive advancements are realised.
You can download the JRC Report here.
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JRC
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!