In Europe as of August 15th 2018 printer cartridges containing electrical parts such as a chip will have to be reported and compliant with WEEE legislation in each EU member state.
It is already the case in some countries such as Germany or Belgium before this date, but it is not yet required in all other EU countries.
Categories for WEEE registration
Cartridges as well as remanufactured cartridges, containing an electrical part (chip) will have to be declared to the authorities in units and weight.
It will be up to the national authorities to decide how to classify them into the WEEE categories. Some countries already integrated such requirement into their national law. Cartridges in many cases fall into the category “small equipment” or “small IT and telecommunication equipment” usually with a connection to the previous categories (annex 2 of directive 2012/19/EU).
Moreover, each country will decide whether they keep on using the “old categories” (annex 2 of directive 2012/19/EU), or the new categories based on annex 3 of directive 2012/19/EU. More often, the two systems will coexist.
Take back and recycling
Consumers and businesses can give back their empty cartridges to service providers, OEMs, distributors or remanufacturers. The entry into force of the new obligations for printer cartridges shall not change the existing models.
Compliance schemes already collect printer cartridges within old printers and copying equipment.
However, authorities expect to get a transparent reporting system. Such transparency goes along with audit systems and controls to ensure a fair and compliant shipment and recycling of cartridges.
Producers' obligations
Obligated producers of printer cartridges will have to declare their put on the market, either individually or through collective take back and recycling schemes.
In general, compliance will be easily handled and delegated to collective take back and recycling schemes whereas in some countries individual compliance will be made available to producers at least theoretically.
Specific case study: France
Last week, Ecologic, the French WEEE partner of WEEElogic hosted a meeting in Paris to present its compliance solution for printer cartridges to OEMs, remanufacturers, distribution channel and empty cartridges collectors.
The purpose of the meeting was to present how Ecologic plans to address the introduction of printer cartridges into the scope of WEEE from August 2018 and the solutions offered to the entire industry stakeholders.
In France authorities decided to integrate consumer cartridges within the current category 3 of the directive (annex 2 of directive 2012/19/EU), although professional cartridges will be classified in a new specific category 14.
Producers will first need to assess which of their cartridges will be classified as “Consumer” and “Professional” based on the type of hardware the cartridge is used. If this method is not sufficient, they need to use further relevant criteria such as type of selling contract, yield etc., enabling them to justify their choice. Depending on the nature of their products, producers will then have to proceed as follows:
- For consumer cartridges, they can use the current Ecologic service to setup, manage and maintain registrations and compliance
- For professional cartridges a choice will have to be made:
- Producers organize their compliance individually facing an increased complexity to setup registrations and financial guarantees, operations and audits protocols, and meet administrative requirements
- Producers rely on Ecologic to manage administrative, financial and operational requirements.
Currently, OEMs, remanufacturers, distribution channel and importers are trying to understand both, the requirements and their compliance solutions that will affect their existing organization in terms of costs or new set-up requirements.
Ecologic and WEEElogic will support producers to simplify proceedings and guarantee full compliance solutions.
Get access to our France WEEE country profile here:
Romain Letenneur
April 5th, 2018
