Market surveillance in the office imaging consumables industry has failed to deliver effective enforcement under Regulation (EU) 2019/1020. Despite multiple, well-documented denunciations at Member State and county level of distributors of non-compliant newly build single use plastic cartridges from China flooding the EU market, widespread breaches of CE marking, RoHS, Low-Voltage directive, WEEE and packaging…
DKW
DKWU
Industry association · Germany
3
positions filed
in the 583 files tracked
3
legislative files
of 583 tracked
1
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 583 consultation files tracked so far (42,224 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
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Their record over time
DKWU filed 3 positions between 8 May 2018 and 28 Jan 2026, across 3 of the 583 legislative files tracked here, attaching a full position paper 1 time.
2018 · 1 filed2023 · 1 filed2026 · 1 filed
What they argued
Considering the use of materials remanufacturing is one of the most preferable alternatives because the geometrical form of the product is retained and its associated economic value is preserved. The DKWU Networks main concern in regard to remanufacturing are imaging devices (Printers, Multi Functional Printers (MFPs), Copiers and Fax machines) as well as their consumables (cartridges, drum units, etc.).
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.
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers — not evidence of coordination, and we do not suggest any.
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