German Gov. & Hp Now Have Chinese Toner Resellers On Surveillance

[news]

German Government & Hp Now Have Chinese Toner Resellers On Surveillance Over DecaBDE Toner Cartridges.
The True Cost of Toner Cartridge Imitations From The Far East.

In North Rhine-Westphalia (NRW), the central market surveillance office has already become active and has written to first traders who are suspected of selling decaBDE-contaminated China cartridges.  Hp will be co-hosting a webinar with DI – Digital Imaging on April 2. Dealers looking for first-hand information on the controversial topic can sign up for the webinar via the following link: http://tinyurl.com/y5z66zyr 

(Google Translated)
The scandal over China's decaBDE-loaded toner cartridges keeps the industry on its toes. In recent weeks, we have examined in detail the toxicological side of the whole and brought to light both reassuring and worrying. In addition, Paperworld held talks with those responsible at the Federal Environment Agency (UBA). Now the market supervision in the federal states is on the train, finally to impose sanctions against the distributors of the forbidden cartridges. The first measures have already been taken in NRW. Last but not least, Druckerprimus HP has given this issue a very high priority: Together with DI – Digital Imaging, HP will hold a webinar on April 2, where partners and customers will be informed about the dangers of Chinese toner imitations.

 

Those responsible at the Federal Environmental Agency have learned first-hand about the DecaBDE scandal at Paperworld: It is now time for market surveillance to finally impose sanctions. The first measures have already been taken in NRW.

 

When we started our research in September, we could not even begin to guess how huge the scale of the scandal is and what kind of explosive power it is. We now know that hundreds of thousands of decaBDE-loaded Chinese toner imitations are likely to circulate in the German market. And we also know that the flame retardant effect of decabromodiphenyl ether was probably not the reason to mix the substance with the toner modules. Rather, there is some evidence that we are dealing with a case of global eco-monopoly.

 

For example, DecaBDE was added to many electronic devices until a few years ago. As a flame retardant. A significant proportion of waste was landed in China, where plastic recyclates were recovered from their enclosures and used in the production of new plastic products. In the meantime nobody in Europe wants anymore decaBDE-loaded recyclates. The grow in the Middle Kingdom therefore to ever larger mountains. Which of course have to be dismantled sometime. Toner cartridges seemed ideal for this: inconspicuous volume products, which are rarely nibbled on by anyone. According to our information, there should even be veritable 'incentives' in China: those who accept contaminated plastic recyclate will be compensated accordingly. And already the DecaBDE mountain is a bit smaller, and the 'dirt' back at the original producer.

 

"The German online retailers are rightly confused, because as a distributor of contaminated China cartridges they are the first in the liability". 
 

False Claims and Smoke Candles.

From the point of view of the trade and the users, the scandal has basically two sides – I) a legal and II) a health. ad I) In accordance with the REACH Regulation, DecaBDE may not be legally manufactured or placed on the market in Europe since 2 March 2019. DecaBDE has been banned in Europe since July 1, 2008 (!) In electrical and electronic equipment. Microchip toner cartridges fall into this product category. Although this point is clear in and of itself, all sorts of false statements circulate in the market. In particular, the affected Chinese providers like to claim that decaBDE-loaded toner cartridges according to the German Electro-Electric Ordinance (ElektroStoffV) – the national implementation of the RoHS Directive (Directive 2011/65 / EU on the restriction of the use of certain hazardous substances in electrical and electronic equipment) – until be placed on the market on 21 July 2019. They refer to a transitional provision of the Ordinance on the use of electrolytes. The assertion becomes more true by repeating it several times, but not …

 

"DecaBDE-loaded China cartridges are not only illegal and harmful to health, but also a heavy burden on the waste cycles".
 

Because this point is the Casus Knaxus in the whole case, we asked the Federal Environmental Agency (UBA) to give us a legal assessment. That was clear. Here are the most important excerpts: "We do not consider the assumption that the transitional provision applies to toner cartridges according to § 15 Abs. 2 ElektroStoffV. (…) The substance bans for the placing on the market of electrical and electronic equipment regulated in § 3 (1) of the German Ordinance on the Use of Electromagnetic Compounds are to be applied to printer cartridges and toner cartridges. They may therefore only be placed on the market if the maximum permissible concentration of certain substances is not exceeded. For DecaBDE, the maximum concentration of 0.1% by weight must not be exceeded. "

 

Thus, this crucial point is clearly clarified – after all, the UBA next to the Federal Environment Ministry (BMU) technically the highest German authority on such issues. And the statements of our Chinese friends are what they are: misrepresentations and smoky candles to distract from the massive violations of the law.

 

The fact that under normal conditions only small amounts of decaBDE are released from the cartridges, as a general all-clear or even free license to evaluate, would be extremely cynical – after all, DecaBDE is a strong nerve poison and is even classified as potentially carcinogenic in the US! 

 

ad II) So far little has been published on the second aspect of the DecaBDE scandal – the health risks for users. There are two reasons for this: On the one hand, the study on the toxicological effects of polybrominated diphenyl ethers is rather thin. On the other hand, the purely toxicological profile of a substance does not give any indication of how much of it a human receives under normal conditions.

 

DecaBDE is considered a bioaccumulating, toxic substance, and the EU classifies it as POP (persistent organic pollutant). In addition, the substance is on the list of substances of very high concern (SVHC) of the European Chemicals Agency (ECHA). If an SVHC is contained in a product with a concentration of> 0.1%, the supplier must actively inform commercial customers – for example via corresponding data protection sheets. The affected Chinese suppliers have also infringed this directive.

 

About the scientific studies in Europe: An experimental study in mice concludes that decaBDE is neurotoxic and damages the central nervous system. A second study indicates an increased concentration of decaBDE in breast milk: the scientists conclude that the substance has embryotoxic effects. European studies that detect a carcinogenic (cancerous) effect of DecaBDE, there is not yet.

 

The situation is different in the USA, where the United States Environmental Protection Agency (EPA) classified DecaBDE as potentially carcinogenic as early as 2009 ("Evidence of carcinogenic potential is suggested for DecaBDE"). This corresponds to classification level C for carcinogenic substances. This classification is based inter alia on laboratory experiments in rats, where a significant increase in liver carcinomas was observed after administration of decaBDE. Only recently (2019) did the EPA confirm its classification of decaBDE as a potential carcinogen in a recent publication. 

 

Mathematical Migration Modeling

Hundreds of thousands of loaded cartridges, DecaBDE is also classified in the US as potentially carcinogenic: That sounds less edifying. It was therefore all the more important for us to get a realistic scenario of the release of the substance from the toner cartridges. According to Prof. Heidi Foth, head of the Institute of Environmental Toxicology at the University of Halle, the key question with additive additives such as flame retardants is: how firmly are they linked to the polymer polymer? If they are firmly connected to the polymeric network, then the toxicological risk is classified as low. However, if the decaBDE is only loosely associated with the polymer – then there is a real danger of delay, explained Foth.

 

In order to be able to realistically estimate the 'ability to migrate' of DecaBDE, we requested Angela Störmer, Study Manager Migration at the Fraunhofer Institute for Process Engineering and Packaging IVV in Freising, Germany, for her expertise. The bad news first: Flame retardants are basically not firmly connected to the plastic polymer but capable of migration. However – and that is the good news – flame retardants made of hard plastics escape only very slowly. Since toner cartridge housings are largely made of polystyrene – a very hard plastic – Störmer estimates the amount of released decaBDE from the loaded China cartridges rather low. To make a scientifically sound statement,

 

Giant luck in misfortune.

Because DecaBDE has a very low vapor pressure, virtually no decaBDE escapes into the ambient air under standard conditions. The most probable route for human ingestion is diffusion of the substance into the toner tank, transfer to the paper during printing, and recording over the printed paper and skin. In conservative assumptions, Störmer came to the conclusion that with a cartridge loaded with 1.5% by weight of decaBDE at room temperature, 7 ng of DecaBDE would transfer to a printed side (calculated for a one-year storage of the cartridge). At 45 degrees – the temperature that a cartridge reaches during printing is 21 ng per sheet (when printing 1,000 sheets in ten days). That is fortunately (!) Significantly lower than the threshold, which is defined as an acceptable risk for carcinogenic substances: 0.15 μg per person per day. This would require a user to record the total amount of DecaBDE adhering to seven printed pages, based on the 45 degrees used for printing, to exceed the limit.

 

This is great luck for the users – and also for our Chinese friends: If the cartridge cases were made of softer plastics, then we would have the horror scenario of a massive poisoning of unsuspecting users across the board. And let none of the affected Chinese manufacturers tell us that they were even aware of this enormous risk …

 

The situation in the waste cycle is completely different: Since Chinese replica cartridges are generally unsuitable for reprocessing, a large part of them ends up in thermal recycling. At the latest in the incinerators most likely high amounts of decaBDE are released. To what extent modern systems filter out the substance is difficult to assess. It certainly can not be the case that some (Chinese suppliers) clog the waste and empties cycle with contaminated cartridges and the others (waste disposal companies and remanufacturers) pay for it … 

 

The official mills grind slowly – but they grind .

It is completely incomprehensible to everyone involved why the relevant authorities have not long since become active and that the traders who sell decaBDE-loaded cartridges are penalizing. As long as that does not happen, the blatant distortion of competition continues. Here you sometimes have the feeling that Brussels and Berlin each other put the buck. In this context, the Federal Environment Agency must be sure that the head of department responsible for product responsibility has informed himself in detail during a longer meeting at Paperworld about the problem. Following this, she informed the market authorities in the federal states. Now it is up to this – the market supervision is in Germany country thing – finally sanctions on the way to bring.

 

In North Rhine-Westphalia (NRW), the central market surveillance office has already become active and has written to first traders who are suspected of selling decaBDE-contaminated China cartridges. Admittedly, the rules on enforcement of infringements in waste law are much less spicy than, for example, in food law; In addition, the responsible authorities are chronically understaffed and therefore the official mills are slow to grind. But they grind. And every dealer based in Germany, which sells contaminated Chinese cartridges in this country, must seriously expect to receive soon post from the market supervision.

 

Ignorance does not protect against punishment

Very high priority has given the topic of the printer world market leader HP: In view of rising market shares of Chinese toner imitations the US company observes the goings on the hard copy offerers from the Far East with Argus eyes. The DecaBDE scandal is seen by HP internally as clear evidence that the Chinese are gaining advantages over such distortions of competition. To educate its partners and major end users about the risks associated with the sale or use of Chinese toner imitations, HP will be co-hosting a webinar with DI – Digital Imaging on April 2. Dealers looking for first-hand information on the controversial topic can sign up for the webinar via the following link: http://tinyurl.com/y5z66zyr Ignorance is not known to protect you from punishment. At most, inaction by the competent authorities – at least until now. But that can be over overnight. And if there is a letter from the market surveillance department in your mailbox, then a webinar will not do any more.
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March 14, 2019 at 11:51 AM