Call for 6 Changes to Imaging Equipment Agreement

Call for 6 Changes to Imaging Equipment Agreement

The European Toner and Inkjet Remanufacturers Association (ETIRA) has called for important amendments to be made to a voluntary agreement about the environmental performance of imaging equipment in Europe.

The association, which represents inkjet and toner cartridge remanufacturers across the European Union (EU), says the draft agreement from EuroVAprint is a ‘useful step forward’ but has outlined at least six amendments that should be made.

The membership of EuroVAprint accounts for 97.4% of all imaging equipment sold in the European Union and includes key printer OEMs (in alphabetical order) Brother, Canon, Epson, HP, Konica Minolta, Kyocera, Lexmark, OKI, Sharp, Toshiba and Xerox.

The aim of the draft Voluntary Agreement (VA) is to improve the environmental performance of imaging equipment products across the EU, through the creation of eco-design minimum requirements, supporting the EU’s Circular Economy Action Plan.

The minimum changes have been detailed by ETIRA in a proposal and sent to all stakeholders, such as EU and member state authorities as well as non-government organisations (NGO’s). They include:

The exemptions in Articles 9.2.1, 9.4. and 9.5.2 should all be removed. Excluding cartridges under contract or subscription means that a very large part of the cartridge market is excluded from the VA, resulting in less cartridge reuse in the EU;
A clear and ambitious re-use target for all cartridges marketed by the Original Equipment Manufacturers (OEMs) must be set: 45% within two years and 60% within four years. Without fixed targets, reuse of cartridges will not grow, in particular, if contract or subscription sales are excluded;
Transparency on the Bilateral Agreements (BAs): There is a need for equal terms. Equal volume pricing, equal technical solutions, equal product range etc. need to be offered by an OEM signatory to all supporting signatories who want to agree to a BA with that OEM signatory;
Criteria for qualifying as supporting signatory: ETIRA calls for a transparent and non-discriminatory decision-making process as to who can and who cannot become supporting signatory;
The VA should be limited in time, e.g. maximum three-year period. During this period, the EU should prepare a regulation to replace the VA. ETIRA is happy to assist in this task;
ETIRA asks that the VA recognizes ISO standards EN 45552, EN 45553 to EN 45559 (resource efficiency) and also findings by the UNEP resource panel on “Value retention Processes.”

Javier Martinez (pictured), president of ETIRA, said: “ETIRA has always called for mandatory legislation to replace the Voluntary Agreement. In our view, only a mandatory approach can bring tangible and enforceable implementation of the goals defined under the Circular Economy Action Plan, because regulations are applicable to all market players.

“Legislation, therefore, continues to be our preferred option. However, ETIRA acknowledges that the October 2020 draft VA represents a useful step forward and, if the core objectives we continue to lobby for can be achieved through a more stringent voluntary agreement, ETIRA would be interested to participate and engage in the process, provided the proposal includes our suggested minimum amendments in line with EU Treaty, EU Circular Economy Action Plan and EU Eco-design directive.”

ETIRA, formed in 2003, is a Belgian registered non-profit organisation that represents the interests of the inkjet and toner cartridge remanufacturers and related service providers and is the recognised industry body for all topics affecting the industry. ETIRA provides many services to its members: legal and regulatory advice, public relations, environmental impacts, quality and standardisation forums and member contact platforms. ETIRA also manages a remanufacturing Code of Conduct and the ticked-R collective mark assuring consumers of less expensive but 100% environment-friendly remanufactured cartridges.