Study on the implementation of product design requirements

The objective of this study is to provide evidence to assess the implementation of Article 4 of the WEEE Directive through the case
of re-using laser and ink-jet printer cartridges. The project has produced targeted recommendations for the consideration of the Commission to address weaknesses in the Voluntary Agreement associated with Article 4, and wider measures to improve the
robustness of both the new and the reused cartridge markets.

The process of this study has been primarily through a stakeholder consultation involving imaging equipment manufacturers (OEMs), cartridge remanufacturers, trade bodies and printer service providers amongst others. It has gathered quantitative and non-quantitative information on the markets for new and reused consumables by economic and volumetric activity, and queried business practices regarding new sales, reuse and associated barriers and enablers. It has examined actions taken to promote reuse under the WEEE Directive, complementary actions by Member States and also the effect of the industry’s Voluntary Agreement under the Ecodesign Directive.

The actions suggested in this study can address the headline issues raised by the range of stakeholders. A clear finding is that the cartridge market is very competitive (or, in economic terms, well-functioning), but the regulatory environment is not well suited to promoting reuse of products or – better – encouraging dematerialisation and greater material efficiency. For this, significant alterations to – as a minimum – EPR scheme structures are proposed.