New Rules Drafted for EU. to Implement for Honest Toner Remanufacturing, Especially for OEMs, and Chinese Companies. PDF

[toner]

New Rules Drafted for EU. to Implement for
Honest Toner Remanufacturing, Especially for OEMs, and Chinese Companies. PDF
The enclosed current draft of the Eco-design Regulation for office imaging equipment represents a significant step towards more sustainable office printing and greater freedom of choice for users. Remanufacturing (refurbishing/preparing for reuse) is not only becoming acceptable but is now a central factor in the imaging equipment industry.

Article 6: Circumvention, Software, and Firmware Updates.
This article is particularly important as it mandates that for all devices, regardless of whether they are sold or otherwise put into service in the EU, including all devices for PaaS and subscription models, a firmware update must not restrict the quality or functioning of a remanufactured cartridge in any way.

Other important advancements include:
Devices must be repairable.
Cartridges must be designed and manufactured to be recyclable.
Plastic parts must be labeled with the type of plastic used.
Chips must be available as spare parts or as a reset offer.
Starter cartridges will no longer be available.

Clarifications Needed:
ANNEX I: Printing speed is usually measured in pages per minute (ppm) and not images per minute (ipm).

1. and C. 1.3. (1) (a): The marking of the plastic should follow ISO 11469:2017-01.
2. and C. 1.3. (1) (b): The mention of the flame retardant should adhere to ISO 1043.
3. and D. 1.1. (1): Printing speeds should be in ppm (pages per minute) and not ipm (images per minute).
4. and D. 1.2. (1): It takes time for used cartridges to enter the collection stream and be remanufactured. The older the machine, the higher the percentage of reuse. Therefore, ten years is much closer to reality than seven years.
5. 1.2. (1): It should state, “A chip reset shall not lead to any deterioration in the printing quality of the cartridge,” for both inkjet (IJ) and laser cartridges. The word “artificial” must be included in the sentence for laser cartridges.
6. 1.2. (1): It should state, “A chip reset shall not lead to any deterioration in the printing quality of the cartridge.” This applies to both inkjet (IJ) and laser cartridges. The word “artificial” must be included in the sentence for laser cartridges. The minimum page yield for medium laser printers should be between 30 and 50 pages.
7. and D. 1.2 (3): The current draft allows OEMs to charge a fee for access to remanufacturing information, even if the information is not used by remanufacturers. While a fee for the chip reset is appropriate, charging for access to information that remanufacturers have built up over 30 years is not justified, especially if the information is not retrieved or used. A fee for the use of this information, if a remanufacturer chooses to access it, would be acceptable. However, access to remanufacturing information and access to chip resets should be regulated separately. One should not require the other.

By charging excessive fees for remanufacturing information and chip resets, OEMs can hinder or even prevent the competitiveness and marketability of remanufacturers. HP’s presentation in Brussels in mid-May on the subject of SecuReuse suggests high costs: “pricing will be reasonable and proportionate to the value of the cartridge.”

According to the current draft, OEMs can deny or delay access to remanufacturing information and chips as spare parts or for chip resetting. Clear checkpoints must be defined to regulate access automatically. Any subjective judgment by OEMs towards a remanufacturer seeking access to spare part chips and/or chip resets must be ruled out.

1. and D. 2 (2): This opens a small loophole that is difficult to close when the OEM provides only return information. The draft must ensure that all collected cartridges are considered waste, have undergone patent exhaustion, and are free to be prepared for reuse by any genuine professional remanufacturer. It must be clear that it is the user’s choice to return a cartridge to the OEM or to a licensed first treatment facility. If OEMs want empty cores, they are free to submit an offer to the collector, but it is the collector’s choice to accept or reject the offer.

However, there is an opportunity to close this loophole in an upcoming WEEE revision if it cannot be addressed in the current regulation, as it concerns cartridges when they reach waste status.

A revised WEEE Directive should:
Reflect the waste hierarchy set out in DIRECTIVE 2008/98/EC and make it clear and mandatory that the use of a lower step is only allowed if the higher step is not possible.

The current combined target for preparing for reuse and feedstock recycling (e.g., for categories 2, 5, 6, 7, 8, or 9 of Annex I: 75% to be recovered and 55% (preferably much higher) to be prepared for reuse and recycled) should be split into separate targets for preparing for reuse and recycling.

IE cartridges or cartridges with consumables in general should be included in a separate EEE category in a possible WEEE revision. This would also make it much easier to measure the achievement of reuse targets.

Additionally, the IE regulation and/or a possible WEEE revision should set guidelines on how collected empty cores are to be handled. It is important that all collected cartridges are disposed of and automatically become e-waste in the ownership of the entity that collected them, provided that entity has the necessary MS license to handle e-waste.

[Author]

June 26, 2024 at 3:59 PM