CLP Changes Ahead

June 24, 2026

New supplier identification requirements coming into force on 1 July 2026 could have significant implications for cartridge importers, distributors, remanufacturers, private-label brands, and online sellers. ETIRA examines what the revised CLP Regulation may mean for the imaging supplies industry and the steps businesses should be taking now.

New supplier identification requirements coming into force on 1 July 2026 reinforce the EU’s growing focus on traceability, accountability, and supply chain transparency. ETIRA examines the potential implications for importers, distributors, remanufacturers, marketplace sellers, and brand owners.

The EU increasingly wants verifiable traceability. It wants to know who made the product, who imported it, who placed it on the market, and who is responsible if questions arise regarding safety, compliance, or environmental obligations.

The new provisions introduced by Regulation (EU) 2024/2865, which become applicable from 1 July 2026, form part of a broader movement towards greater supply chain transparency and accountability.

What Has Changed?

Among many other elements, the revised Classification, Labelling and Packaging (CLP) Regulation introduces a requirement that hazardous substances and mixtures placed on the EU market must have a supplier established within the European Union who is identified on the label and responsible for compliance with the Regulation. For many businesses, this may seem like a relatively minor change. However, the requirement raises important questions about responsibility, accountability, and traceability throughout the supply chain. For the imaging supplies industry, this has several practical consequences:

1. Non-EU cartridge sellers can no longer sell “direct to EU customers” without an EU responsible entity. If toner or ink cartridges contain hazardous mixtures under CLP, an EU-based economic operator must now be identified and legally accountable.

This affects Asian aftermarket manufacturers, marketplace sellers, cross-border ecommerce, drop shipments, etc.

The EU responsible entity may be the importer or an authorised representative. an EU distributor, a fulfilment service provider acting under product compliance rules

Without such an EU-based supplier indicated on the label, the products may not legally be placed on the EU market!

2. Toner and ink cartridges may require updated CLP labels

Some toner powders and some ink formulations are classified as mixtures under CLP due to:

• carbon black content
• solvents
• sensitizers
• reproductive toxicity classifications for certain components
• respiratory irritation or aquatic toxicity

If the cartridge contains a classified hazardous mixture, the cartridge packaging must comply with CLP labelling rules, including ( but note that some of these provisions enter into force only in 2028!):

• supplier identification
• hazard pictograms
• signal words
• H and P statements
• UFI where required
• language requirements for each Member State.

3. Marketplace compliance becomes much stricter

As a result, online sales platforms are increasingly expected to ensure that hazardous products sold into the EU meet CLP requirements.

For toner and ink cartridges, this means:

• Missing EU addresses on labels may trigger delisting
• Missing SDS documentation may block imports
• Incorrect hazard classification may create customs or surveillance issues
• Anonymous aftermarket brands become higher risk

This is especially relevant for low cost compatible cartridge imports.

4. Cartridges are in a grey zone between “article” and “mixture”  A cartridge itself is usually treated as an article, but:

• The toner or ink inside is a mixture
• leakage exposure scenarios matter
• Refill bottles and bulk toner are clearly within CLP scope

Therefore:

• sealed cartridges with no hazardous classification may have limited obligations
• refill toner bottles and bulk inks are fully exposed to CLP obligations
• some OEM and remanufactured cartridges may newly require closer classification review

So what Should Businesses Do Now?

Businesses should use the period before 1 July 2026 to review their supply chains and compliance arrangements.

Practical steps may include:

• Identifying the responsible supplier for each product range
• Reviewing product labels and packaging
• Verifying Safety Data Sheet (SDS) documentation
• Reviewing marketplace listings and product information
• Confirming responsibilities with suppliers and business partners
• Assessing whether current compliance arrangements remain appropriate

Products already lawfully placed on the market before the new requirements become applicable may be subject to different considerations. However, businesses that place products on the market after 1 July 2026 should carefully review their obligations.

For the imaging supplies industry, the new CLP requirements mean traceability, accountability, and compliance are becoming increasingly important commercial considerations. In our industry, many products are imported from SE Asia, and a large number do not comply with the new rules. European distributors and other customers should avoid violating EU and national laws by trading with established European remanufacturers, such as ETIRA members, who comply with the rules.

ETIRA will continue to monitor developments and provide practical guidance to members as implementation of the revised CLP requirements progresses. Already in April 2026, ETIRA provided its members with a useful Guide on REACH and CLP provisions.

Disclaimer: This article is intended as general industry guidance and should not be regarded as legal advice. Companies should seek professional advice regarding their specific compliance obligations.