Measures addressing the environmental impact of imaging equipment including consumables

We favour Option 4 and propose a 'landing zone' on which to develop improved environmental outcomes in this highly competitive - and slowly declining market. The European Remanufacturing Council represents businesses that remanufacture and refurbish used products in many sectors but including imaging equipment and cartridges.

DIGITALEUROPE, representing the digitally transforming industries in Europe, supports the initiative's objectives of increasing the material and energy efficiency of imaging equipment incl. consumables, and welcomes the opportunity to respond to the European Commission's call for evidence. Please see attached our more detailed position on the initiative.

The Right to Repair Europe coalition includes environmental NGOs and repair actors such as community repair groups, social economy actors, self-repairers, repair and refurbishing businesses, and any citizen who would like to advocate for their right to repair.

On behalf of the European advertising and media associations we represent, the Advertising Information Group (AIG) (transparency number: 11220347045-31), we welcome the opportunity to respond to the European Commissions call for evidence on Environmental impact of imaging equipment, including consumables.

Remanufacturing (= reusing and reparing) as a business model is becoming more and more difficult as American and Japanese printer manufacturers or OEM companies doing everything to block cartridge reuse. Most of the blocking barriers are based on dynamic chip technologies that make reuse of the cartridsge impossible as some of the cartridge functionalities are partially or completely blocked.

Environmental NGOs including the Right to Repair Europe and Coolproducts campaigns welcome the publication of the call for evidence for an impact assessment on imaging equipment including the Commission's understanding of the problem and possible solutions. We call for the implementation of Option 4 a combination of ecodesign requirements and energy labelling.

BEUC strongly welcomes this initiative by the European Commission that has the objective of making imaging equipment more material and energy efficient and reducing its overall environmental impact. We agree with the decision to opt for mandatory regulatory measures, as opposed to a voluntary agreement.

ANEC strongly welcomes this initiative by the European Commission that has the objective of making imaging equipment more material and energy efficient and reducing its overall environmental impact. We agree with the decision to opt for mandatory regulatory measures, as opposed to a voluntary agreement.

Representing the European Toner & Inkjet Cartridge Remanufacturers', ETIRA has promoted cartridge reuse as a cartridge since 2003. However, the American and Japanese printer manufacturer multinational OEM companies do everything they can to block cartridge reuse as a cartridge because they make their profit on selling a new cartridge each time the old one runs empty.

Recycling is the most important process in the circular economy and targets for secondary materials in new products is therefore a priority. Other important issues are end-of-waste legislation and terminology Please refer to the added documents - PM - Call for evidence - Printer - toner ink cartridges

Re-use and preparing for re-use of toner and ink cartridges are often defined as remanufacturing. The term remanufacturing, in this case, is misleading based on current legislation and the definition in EN 45553. WEEE AUDITS propose special legislation for second life of toner and ink cartridges based on a new definition of this process.

Having started in 1987 in the remanufacturing of toner cartridges and their components (e.g. with semi-conductive coatings for magnetic transfer rollers for mono-component toners - allowing to re-use the existing magnetic rollers) we built a lot of experience in "re-use" in the past 35 years.

EVAP agrees that all the issues identified in the Commissions communication are relevant for consideration in developing the regulation. EVAP also supports the high-level objectives, the range of aspects and the range of four options set out by the Commission.

HOP welcomed the solutions proposed by the Commission to regulate the design of imaging equipment sold on the European market. We affirm that an Ecodesign Regulation and Energy Labelling in this product sector (Option 4) is the best way forward in order to effectively address the environmental impacts of printers and their consumables.

Filed in French · English published by the European Commission

EERA welcomes the overall objectives and aspirations of the proposed Regulation on Ecodesign for Sustainable Products (ESPR), as it has long been our viewpoint that the key to good recycling opportunities to recover secondary materials must begin at the design stage.

We are licensed and engaged in the remanufacturing of toner cartridges for use in laser printers as well as the refurbishing of printers/copiers since 1999. As founding members of the European Remanufacturing Council, we would like to share our facts on this topic. We have remanufactured and sold under our various brands (ECOPLAN, GT Premium, Lion) over 1 million toner cartridges since inception.

As an organization dedicated to promoting human rights and sustainable development, we are pleased to provide feedback on this initiative. Firstly, we would like to commend the Commission's effort to address the environmental impact of these products, as it is a critical issue that has far-reaching consequences for our planet and future generations.

Given an Opinion. Dear European Commission, The Senior Corporate Silver Spoon, Environment & Nature Association we give the following Opinion on behalf of: By providing the following Opinion for the Initiative called "Environmental impact of imaging equipment, including consumables", we inform the European Commission and its Institutions of the following.

The collection and preparation for re-use of IE cartridges has grown to a very professional business starting in the early 1990. That means that systems now in place matured for over 30 years. In addition, single-use by design IE cartridges produce a lot of e waste (370 Mio. IJ cartridges * 40gr/cartridges + 135 Mio.

only equipment and consumables that recycle 100 % should be allowed to be marketed on the domestic market. The service must be developed in such a way that the lifetime of the equipment is extended to at least 10 years. Advertising for new equipment must also be reduced to advertising about servicing and extending the life span. More than that, the recycling rate of the components should be given by advertising.

Filed in Romanian · English published by the European Commission