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Revised Sustainable Procurement Guidelines for Toner Cartridges – prepared by ICLEI for UNEP-DTIE Following the comments received from Hans Wendschlag from Hewlett Packard on the Sustainable Procurement (SP) Guidelines for Toner Cartridges (Product Sheets) and Ink both at the end of November 2009 and in March 2010, ICLEI has undertaken a thorough review of the mentioned Guidelines as discussed and agreed with Farid Yaker from UNEP-DTIE. The revision of the SP Guidelines (Basic and Advanced levels) has been completed. This paper documents the responses from ICLEI on the various points raised by Hewlett Packard and, where has been deemed necessary, also provides more information to explain the decisions taken.
Approach taken Additional research was conducted into how toner cartridges are manufactured, remanufactured, and their life-cycle. Information covering the main environmental and social issues identified for toner cartridges (e.g. harmful chemicals, plastics, recycling material, social issues in production and supply chains) and for other issues relevant for SP (e.g. quality of remanufactured toner cartridges) formed the central focus of additional research work, ICLEI is unable to fund own studies or scientific research and thus must rely on already existing scientific research. Independent research qualified by independent third parties is therefore preferred and has been the primary source of information used for revising the Guidelines. In particular, three internationally known Type I Ecolabels certifying toner cartridges have been used - Blaue Engel (Blue Angel), the Nordic Swan, and the Eco Mark, Japan. According to the UNOPS “Guide to Environmental Labels for Procurement Practitioners of the United Nations System 1, Type-1 ecolabels are “most useful from the point of view of a procurement practitioner. Ecolabels are based on ambitious criteria of environmental quality, and they guarantee that the awarded products respect the highest environmental standard in that market segment. The criteria are usually developed through the involvement of a large number of stakeholders and awarded after an independent process of verification.” Ecolabels labels take into account all adverse environmental impacts of a product throughout its life cycle, for example energy and water consumption, emissions, disposal, etc.” The second step in the revision process ensured that the advice provided by national and regional governments on SP of toner cartridges, such as the guidelines provided by the Belgian and German national governments and the regional government of Catalonia, was considered. 1
http://ungm.org/Publications/sp/Env_Labels_Guide.pdf
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Finally, additional information sources provided by industry contacts (of OEMs and remanufactured toner cartridges) were also considered, such as studies and feedback provided by representatives of the European Toner and Inkjet Remanufacturers Association (ETIRA), UK Cartridge Remanufacturers Association (UKCRA), Hewlett Packard and Xerox, as well as several representatives from various quality standards including DIN, ASTM F and the ISO group. The following are ICLEI’s individual responses to each of the comments submitted by Hewlett Packard 1. Pre-qualification, comply with the ILO Core Conventions throughout the whole supply chain HP Comment: Although important, not realistic as the number of involved suppliers can be very large. The focus of the EICC members is the 1st Tier of suppliers which is recommended also here. In addition, we don’t think that remanufacturers can obtain the information about the whole sup-ply chain from a manufacturer of original cartridges. Also, how can a remanufacturer control the manufacturing operations of the OEM cartridges? ICLEI response: Although this is an issue of highest priority within the UN system, ICLEI agrees that it would currently be difficult in practice for many manufacturers to prove compliance with the ILO Core Conventions throughout the whole supply chain. HP’s recommendation has therefore been taken into account and the SP criteria contained in the Product Sheets have been altered to require that the bidder, the manufacturers of the toner cartridges (where different) and all of the first tier suppliers of the manufacturer of the product comply with the international working standards (ILO Core Conventions) listed in the criteria. Manufacturers of remanufactured toner cartridges are responsible for ensuring compliance with the ILO Core Conventions for all of their first-tier suppliers of all new material included in their operations and thus the final product (toner cartridge).
2. Pre-qualification- operational, third-party certified, environmental management system HP Comment: Although somewhat important, not realistic as the number of involved suppliers can be very large. Suggest to change to the 1st Tier of suppliers which is recommended also here. Again, we don’t think that remanufacturers can obtain the information about the whole supply chain from a manufacturer of original cartridges ICLEI response: As with point 1 above, this recommendation has been accepted. Manufacturers of remanufactured toner cartridges are responsible for ensuring that the firsttier suppliers of all new material used have an operational, third-party certified, environmental management system that meets one of three recognised systems: ISO 14001, European EMAS, U.S. EPA Performance Track or equivalent. 2
3. Minimum recycled content of 75% HP Comment: Original (OEM) cartridges are discriminated, without taking into account that many remanufactured/refilled cartridges have lower quality, which results in increased toner/ink and paper consumption. See the DIGITALEUROPE position paper on ‘Recycling, reuse, and the print cartridge life Cycle.’ For any new cartridge type put on the market, it will take at least two years before these show up in significant numbers to be of any interest for a remanufacturer. In addition, EU Public Procurement is about increasing competition, this requirement more or less eliminates originals. Suggest to remove as this is not based on science, a provision according to article 23 of the EU Public Procurement Directive. ICLEI response: Three separate points are addressed here. Firstly quality, which is of the utmost importance in procurement. The abovementioned DigitalEurope position paper which focuses on the environmental costs and benefits of OEMs and remanufactured toner cartridges, does state that remanufactured toner cartridges do not have the same level of quality as OEMs, offering several industry supported tests as proof. However, a variety of national and international quality assurance systems exist. These systems include, but are not limited to: ISO/IEC 19752, ISO/IEC 19798, ASTM F 1856 and ASTM F 2036, DIN 155, DIN 33870 or DIN 33871-1. The criteria therefore stipulates that all cartridges must have been tested using such a system. More information can be found in the Annex, Secondly, environmental impacts. Assuming quality is assured, there is clear agreement on the environmental advantages of preferring remanufactured over OEM cartridges, particularly in terms of reduced CO2 consumption during manufacturing, and reduced resource use. This is borne out by a clear preference for remanufactured cartridges from Type-1 ecolabels and national/regional SP advice. On this basis the preference for remanufactured cartridges remains in the criteria. Again more information is provided in the Annex The original criteria provided points in the award phase for both remanufactured cartridges and for cartridges containing at least 75% recycled material. This is essentially making the same point (as this is how most ecolabels define a remanufactured cartridge), so this has been reduced to one criterion. Finally, regarding product availability and competition. Sufficient availability of products on the market is another important point that has been considered in the development of the international SP Guidelines. Based on the market information gathered, criteria for remanufactured toner cartridges have been included as award criteria and not technical specifications. This means that it is up to the discretion of the procurement official to decide how much preference will be given to bids of remanufactured toner cartridges based on the number of points allocated to this criterion. 3
4. PVC in packaging and replacement parts HP Comment: An EU study on the "Life Cycle Assessment of PVC and of principal competing materials" commissioned by the European Commission in June 2004 concludes there are no grounds for discriminating PVC or that PVC should not be treated differently from other materials. The study confirms that the environmental impact of PVC is not different from other materials employed. This study is the final step in the long process followed by the European Commission to clarify the environmental performance of PVC and independently confirms that PVC is as good a material as any other, with both strong and weak points, depending on the application and on its use, and that there is no reason to treat PVC differently from any other material. The study can be downloaded from the EU DG Enterprise website: http://ec.europa.eu/enterprise/chemicals/sustdev/pvc-extended_summary_lca.pdf. ICLEI response: The majority of Type I Ecolabels for toner cartridges exclude PVC. As noted above, type-1 ecolabels are considered a reliable source of independent, scientifically-based criteria, and as such this criterion has been left in the guidelines. ICLEI cannot be expected to make an analysis of the scientific rigour of such processes. 5. Contract clause: Emissions from transport of the product HP Comment: Suggest to delete: although important, this is a premature requirement as internationally agreed technical standards are not yet available which is a provision to be able to compare bids. In 2008, such work started within CEN/TC 320 WG 10. ‘Methodology for calculation, declaration and reporting on energy consumption and GHG emissions in transport services (goods and passenger transport). A final standard can be expected 2011/12. In addition, only looking at CO2 emissions, might not be the preferred approach as see freight has substantial emissions of SO2 compared with other mean of transportation. ICLEI response: Carbon emissions from the transport of products are highly relevant when considering the environmental impact of products purchased. Translating HP’s feedback into a procurement criterion which is on the one hand reasonably achievable, fair on the bidder, non-discriminatory, and which is likely to achieve a positive environmental gain, has resulted in the development of an alternative formulation of the criterion. The criterion is proposed in the award phase and allows bidders the opportunity to propose ways in which the CO2 equivalent emissions associated with the supply of their products for the purpose of the contract or for their overall regional operations can be progressively reduced throughout the lifetime of the contract. This ensures that bidding companies willing to invest in reducing their environmental impact or at least to uncover the emissions produced by their transportation operations, are rewarded in the tendering phase. Additionally, as this is a more difficult award criterion to implement for procurers (as 4
it will likely require a degree of expert knowledge), it has only been included in the advanced version of the SP Guidelines.
6. Heavy metals in toner HP Suggestion: In the verification change ECO Declaration (EMCA-370) (version 2008 or more recent, with point P1.1 marked “yes”) to “Industry supplies IT Eco Declaration (version January 2007)or more recent with point S3.1 marked “yes” .” ICLEI response: This suggestion has been accepted and integrated into the guidelines.
7. Azo-colorants in toner HP Suggestion: In verification add “such as the Industry supplies IT Eco Declaration (version January 2007)or more recent with point S3.2 marked “yes”” as an example of a declaration from the manufacturer. ICLEI response: This suggestion has been accepted and integrated into the guidelines.
8. Requirements for case parts Plastic Parts shall: - Not contain Polybrominated biphenyls (PBBs), polybrominated diphenyl ethers (PBDEs); HP Suggestion: Must add lower concentration limit of 0.1% as defined in the EU RoHS Directive. ICLEI response: This suggestion has been accepted and integrated into the guidelines. - Not contain any chlorinated plastics; HP Suggestion: Propose to remove. Not based on science, a condition according to Article 23 of the EU Public Procurement Directive. ICLEI response: As above, this relates to principally PVC, and is based on ecolabel criteria so it is still included. - Not use cadmiated parts, except in electrical or electronic components and wires; and, HP Suggestion: Must add lower concentration limit of 0.01% as defined in the EU RoHS Directive. ICLEI response: This suggestion has been accepted and integrated into the guidelines. HP Suggestion: We would like to suggest that the following is added regarding substances 5
for case parts: chromium VI max 0.1%, mercury max 0.1% and lead max 0.1% ICLEI response: This suggestion has been accepted and integrated into the advanced version of the guidelines.
9. Take-Back Scheme HP Suggestion: Info with URL provided with the cartridges should be accepted as verification. ICLEI response: The UNEP SP Guidelines have been developed with the user in mind (i.e. the procurer), therefore providing a reference to a URL would put the onus on the procurers to research the take-back scheme of every bid. Websites may also not provide sufficient information for the procurer to make an informed decision. Additionally, by having the bidders provide information on their how their empty toner cartridges are collected and reprocessed or recycled not only allows greater transparency into the whole process, but it also may provoke companies to develop (further) a take-back scheme (see Annex point 5 for more information on the End of Life Management of toner cartridges).
10. Environmentally-friendly packaging HP Suggestion: Don’t use environmentally ‘friendly’ instead use environmentally ‘’conscious’ or preferred. ICLEI response: This suggestion has been accepted and integrated into the guidelines.
Recycled content
points
5-20
1
21-40
2
41-60
3
61-75
4
6
75
5
11. Re-used/remanufactured cartridges HP Suggestion: According to Annex 1, one hundred points will be awarded (the total is not known) if this requirement is met. None if the other award criteria have been given any points, so it is left to the purchaser to assign points to discriminate original cartridges. We believe this is not justified. Many remanufactured/refilled cartridges are of lower quality resulting in increased toner/ink and paper consumption (see DIGITAL EU-ROPE position paper). If kept, points should be assigned according to the below suggested matrix.
ICLEI response: As in all document, points are only provided for the evaluation criteria relating to environmental performance. The weight of these in the overall evaluation (including price and other aspects) is up to the individual purchaser. In each case the total points awarded for environmental criteria add up to 100 (which in turn we recommend to make up at least 20% of the overall evaluation criteria). The relative weighting of the different environmental criteria within this scheme depends on the relative importance of the environmental impact. The recommended weighting systems have been adapted in line with the revised evaluation criteria.
12. Verification for Remanufactured Toner Cartridges HP Suggestion: Instead of referring to National standards (Germany and the US) replace these by international ISO standards on print yield: ISO19752:2004 Toner Cartridge Yield for monochrome laser and ISO19798:2007 Toner Cartridge Yield for colour laser. ICLEI response: This suggestion has been accepted and integrated into the guidelines.
HP recommended the inclusion of the following additional requirements: 13. Print yield HP recommendation: according to ISO19752:2004 and ISO19798:2007 7
ICLEI response: This recommendation has been accepted and integrated into the guidelines. 14. Chemical emissions from printing system HP recommendation: in accordance with Blue Angel RAL-UZ 55, para 3.3. ICLEI response: Due to the varying methodologies used by different Ecolabels regarding chemical emissions, no further work can be spent researching HP’s suggestion due to insufficient resources. However, it should be something to take into consideration for future revisions.
Annex: Remanufactured and OEM toner cartridges This annex provides more detailed information in support of the preference within the prepared SP guidelines for remanufactured over OEM toner cartridges.
1. Ecolabels and National Guidelines that have Guidance for the Purchase of Toner Cartridges When analysing type-1 ecolabels and GPP/SPP guidance from across the world, it is clear that there is general support for remanufactured over OEM toner cartridges. The following ecolabels only certify remanufactured toner cartridges: 8
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Germany: Blaue Engel (Blue Angel) Nordic Countries: Nordic Swan North America: Ecologo Croatia Environmental Label Hungary: Környezetbarát (KvVM)
Several ecolabels certify both remanufactured and OEM cartridges, however almost all include specific criteria for OEMs to ensure that it is possible to remanufacture them (see further information below on ease of disassembly): - NF France - Korea Eco-Label - New Zealand Ecolabelling Trust - GreenLabel Thailand - Ecomark Japan - GreenLiving Taiwan Often criteria can be found for toner cartridges in an ecolabel’s Imaging Equipment Criteria, such as that produced by the Nordic Swan and the Blaue Engel. Although these criteria do not explicitly recommend remanufactured toner cartridges, they do stipulate that the imaging equipment must accept remanufactured toner cartridges and if the equipment comes with toner cartridges, they must not be designed to prevent reuse. Furthermore, several national and regional GPP/SPP guidelines make a clear recommendation to only purchase remanufactured toner cartridges: - Belgium (guidedesachatsdurables) - Germany (Umweltfreundliche Beschaffung) - USA (Responsible Purchasing Network) - Flanders region (Milieukoopwijzer) - The Basque Region, Spain - Whistler 2020 2
2. Quality of remanufactured toner cartridges Quality is one of the major issues that concern many about the usage of remanufactured toner cartridges. There have been many tests 3 conducted on the quality of OEM and remanufactured inkjet cartridges; however there have not been many independent quality studies that compare the difference of quality in toner cartridges. Papers supported by OEM manufacturers, such as
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Although Whistler is not a region the purchasing guidelines that it has are broadly relevant in their application and can serve as a good reference for sustainable procurement. 3 Tests have been conducted by organizations such as Stiftung Warentest and Consumentenbond
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the DigitalEurope 4 position paper on ‘Recycling, reuse, and the print cartridge life Cycle,’ claim that many remanufactured/refilled cartridges have lower quality, which results in increased toner/ink and paper consumption. Such papers have come to the conclusion that OEMs have a higher quality than remanufactured toner cartridges. Often the term ‘Cartridge’ is used to imply that a test is relevant for all cartridges when in fact only inkjet cartridges or laser toner cartridges have been tested, or the two terms have been used interchangeably. This is important to look out for as there are substantial differences between the technology of the two. To ensure that remanufactured toner cartridges that are bought are of a high quality, it is important to purchase them from a manufacturer that has quality procedures in place and that offers a guarantee to ensure the quality and reliability of their product. A method of verifying whether a remanufactured toner cartridge is of equal quality to an OEM is check whether they comply with any national or international quality standards. Examples of such include ISO 19752, ISO 19798, DIN 155, DIN 33870, DIN 33871-1, ASTM 1531 5 or ASTM F 1856 combined with ASTM F 2036. There are also similar industry standards such as the ETIRA Standard Toner 1000, however such standards are reserved for members of ETIRA only and have been created by the remanufactured toner cartridge industry. The majority of standards require an external independent auditor to confirm their compliance with the different standards. The tests are controlled and measure yield and image density and background. Currently an ISO group is working on developing a new standard 6 for both OEMs and remanufactured cartridges that includes both quality and environmental performance. In addition to the national, international, and industry-supported standards that maintain a certain level of quality for toner cartridges, there are several industry supported codes of conduct. Such codes of conduct are more general and are often a set of self-declared standards. Examples include the Electronic Industry Citizen Coalition (EICC) 7 which has an industry code of conduct for global electronics supply chains, and the European Toner and Ink Remanufacturing Association’s (ETIRA) Code of Conduct 8 that represents a set of guidelines for the remanufacturing industry concerning general quality, social and environmental standards, however it is only for ETIRA members.
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Additional sources include: Quality Logic, 2007. ‘HP LaserJet Toner Cartridges vs. North American Remanufactured Brands’ http://www.qualitylogic.com/assets/pdfs/consumables/Reliability_Comparison_Study-Mono_Toner%20HP_vs_NA_Reman_Brands_11-07.pdf Commissioned by HP; Quality Logic, May 2008, ‘HP LaserJet Toner Cartridges vs. North American Remanufactured Brands’ http://h41112.www4.hp.com/promo/toner-test/pdf/reliabilityblack.pdf Commissioned by HP. 5 ASTM 1531 has been withdrawn but it is still recommended in the current Nordic Swan criteria for remanufactured toner cartridges, Version 4.1. 6 Personal communication with ETIRA 7 For more information please see: http://www.eicc.info/ 8 For more information please see the ETIRA website: http://www.etira.org/w/code-of-conduct/16
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Additionally, by purchasing a remanufactured toner cartridge that has one of the abovementioned national and international standards, public authorities are ensuring that they are not purchasing so-called “Asian orphans” or “clones”. “Asian orphans” and other such “clones” are mass produced in Asian countries at a very low price and often state that they are either remanufactured or OEM when they are often of low quality and do not comply with any EU or national regulations. This makes them difficult to re-use or remanufacture in any manner and thus they often end up in landfills once depleted 9.
3. Environmental Benefits There is no question that remanufacturing offers a lower environmental impact compared to the production of a new OEM. The carbon footprint of reusing cartridge materials via remanufacturing is equivalent to burning 1.9 litres of petrol versus 3.4 litres of petrol for an OEM 10. Or stated differently, the savings of a remanufactured toner cartridge compared to an OEM is 3-13 kg of CO2 per cartridge per refill cycle, depending if the use phase is taken into account or not 11. These savings are due to the fact that remanufacturing extends the products life cycle and reduces the amount of raw materials that need to be produced to create a new cartridge. Having empty toner cartridges that end up in landfills or incinerated is the least desirable outcome as it increases the amount of carbon emissions released. This process also increases the industry’s dependence upon new raw materials. Several studies have been conducted on the environmental footprint of an OEM versus a remanufactured toner cartridge. Some of the studies are independent, produced by various universities 12 and others have been funded by the remanufacturing industry 13. Nevertheless, they all report that the use of remanufactured toner cartridges has a lower environmental impact than the use of an OEM cartridge based on life-cycle analysis (LCA). It is also often stated that the environmental benefits of remanufactured toner cartridges are displaced by paper wastage, however a recent study conducted by the Centre for Remanufacturing and Reuse 14 states that “there needs to be more than 12% paper wastage during printing to wipe away the benefit of remanufacturing. It is believed that this is an unrealistically high percentage.”
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Personal communication with UKCRA. DigitalEurope, October 2009. ‘Recycling, Reuse, and the Print Cartridge Lifecycle’ 11 Xanfeon, Dec 2008, ‘Carbon Footprints and Ecodesign of Toner Printer Cartridges’ Commissioned by UKCRA; Centre for Remanufacturing and Reuse (CCR) 2008, ‘Carbon Impact Studies: Toner cartridges’ http://www.remanufacturing.org.uk/free-reuse-publication.lasso?report=265 12 Lindahl, Sundin and Östlin. 2006, ‘Environmental Issues within the Remanufacturing Industry.’ Department of Mechanical Engineering, Linköping University, Sweden; Berglind & Eriksson. 2002 ‘Life Cycle Assessment of Toner Cartridge HP C4127X: Environmental impact from a toner cartridge according to different recycling alternatives,’ University of Kalmar, Sweden; Universita Degli Studi di Modena Reggio Emilia and LCA Lab, 2008, ‘Studio Life Cycle Assessment (LCA) Del Confronto tra una Cartuccia Originale HP 4000 e una Cartuccia Calligraphy Rigenerata.’ 13 Xanfeon. 2008; Best Foot Forward, ‘The carbon footprint of remanufactured versus new mono-toner printer cartridges’ Commissioned by the Centre for Remanufacturing and Reuse 14 Centre for Remanufacturing and Reuse (CCR) 2008, ‘Carbon Impact Studies: Toner cartridges’ http://www.remanufacturing.org.uk/free-reuse-publication.lasso?report=265 10
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Below (Fig.1) is a diagram that shows the flow of materials throughout the life-cycle of toner cartridges. The left-hand side of the diagram shows the flow from materials manufacturing, transport of materials to a component manufacturing plant, manufacturer of cartridge components, transport of components to a cartridge assembly plant, transport of the cartridge to a distribution/sales centre, and subsequent provision of the cartridge to the user. At the end of the use phase, the user either provides the spent cartridge to an end of life (EOL) process or arranges for the cartridge to go to a remanufacturing facility. In the first case, the user would then purchase another new cartridge and in the second case the user would use a remanufactured and refilled cartridge. In the remanufacturing (i.e. the central section) of figure 1, there is shown stages which are equivalent to stages on the left-hand side of the figure. Materials are manufactured and transported to a component manufacturing facility and these components (referred to as aftermarket or replacement components) are transported to the remanufacturing facility. 15 There is an additional section of the diagram in the top right-hand corner which illustrates a further remanufacturing process (called recursive remanufacturing) in which certain components in the used cartridge are individually remanufactured. The mag roller is an example of a recursively remanufactured component in which the OEM aluminium sleeve on the OEM metal core is replaced. In the event that the remanufactured cartridge reaches the end of its possible cycles, the cartridge then enters its end of life stage. 16
15 16
Excerpt from Xfaneon 2008, p.7. Excerpt from Xfaneon 2008, p. 7-8.
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NEW CARTRIDGE
REFILLED / REMANUFACTURED CARTRIDGE
N1
materials manufacturing
R1
materials manufacturing
RR1
materials manufacturing
N2
transport of materials
R2
transport of materials
RR2
transport of materials
N3
component manufacturing
R3
N4
transport of components
R4
N5
new cartridge manufacturing
N6
transport of new cartridge
N7
sale of new cartridge
N8
transport at end of life
N9
materials recovery
R5
replacement component manufacturing
transport of replacement components
RR3
RR4
transport of spent component
cartridge refill and remanufacturing
RX6 R7
remanufacturing of replacement components
return of cartridge to customer
RX7
transport of reman component
transport of reman cartridge
sale of reman cartridge
R8
N10
transport at end of life
R6
transport of cartridge to remanufacturing facility
landfill of nonrecovered materials
R9
R10
materials recovery
landfill of nonrecovered materials SYSTEM BOUNDARY
U1
cartridge use
Figure 1 The toner cartridge path, OEM and remanufactured 17
4. Recycling versus Re-use or Remanufacturing When discussing the difference between remanufacturing and recycling, the image below (Fig.2) clearly outlines the processes of recycling, remanufacturing and simple repairs. While recycling prevents cartridges from ending up in landfills and creates material that can be used in new cartridges, thereby reducing the consumption of raw materials, the recycling process consumes approximately 2 kWh/toner cartridge of electricity 18. The recycling of toner cartridges requires first separating the components, then crushing them and reprocessing them into new material for parts, which is a process that in itself requires a substantial amount of energy. 17 18
Courtesy of Laura Heywood Director of Kleen Strike (UK) Ltd.and Secretary of UKCRA Berglind & Eriksson. 2002, p.20.
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Figure 2 The Remanufacturing Process 19
5. End of Life Management To prevent toner cartridges ending up in the landfill, it is necessary that a system is in place for the reuse (preferable) and recycling of empty toner cartridges. Both OEM and remanufacturing companies dispose empty cartridges and their parts in landfills 20, be it to prevent them from being remanufactured, because they are damaged or have reached the end of their useful life, or because they are undesirable cartridges that have little or no value (i.e. so-called “Asian orphans”). It is important that the vendor of a remanufactured or OEM toner cartridge collects their products once they are empty, however, it must be clear that instead of discarding the empty toner cartridges in the landfill, that the material is reused or recycled. Remanufacturing companies must ensure that such a take-back system combined with the recycling of damaged or unusable toner cartridges is in place to avoid offsetting the benefits of remanufacturing. And 19
Source: Andrew King of the Centre for Remanufacturing and Reuse InfoTrends, 2007, ’2007 Supplies Recycling: U.S. and Europe’. http://www.capv.com/public/Content/INFOSTATS/Articles/2007/07.10.2007.html 20
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OEM manufacturers must ensure that their recycling programs actually recycle the collected toner cartridges and not dispose of them in landfills to prevent their re-use. The ultimate end-of-life management is a crucial factor that shapes the full lifecycle footprint of a toner cartridge. The majority of both OEMs and remanufactured companies claim to have a zero landfill policy in place 21, however when purchasing a toner cartridge purchasers should look deeper into what are the details of the zero landfill policy. 6. Ease of Disassembly / Ecodesign A wide range of anti reuse devices (ARUDs) are now used in toner cartridge production. As a result toner cartridges have become more complex to remanufacture. A number of smart chips or other ARUDs have become more difficult to re-engineer and there have been cases where a cartridge has been prevented from remanufacture for two years because of this. Without replacing the smart chip that controls the pre-programmed counter a remanufactured cartridge will not function. Some other specific examples include 22: -
Sonic welding – some cartridges are welded sonically and the only way to remanufacture a sonically welded cartridge is to cut it open and then screw it together again, a process which is time consuming and expensive. Some welds are made in a zig-zag pattern which makes remanufacturing even more difficult.
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Unnecessary adhesive tapes – although designs with plastic clips and screws have served the market well, there has been the introduction of using ultra-strong double-sided adhesive tapes to prevent disassembly.
Today more and more printers are sold with ‘starter’ cartridges that include a minimum of toner, because of the low volume and if these ‘starter’ cartridges are not designed to take even a standard fill, they are not cost effective or an environmental advantage to remanufacture. A short-life cartridge (SLC) and a long-life cartridge (LLC) are different on account of the number or remanufacturing cycles each can be taken through while still delivering high quality printing capability. Typically an SLC can be taken through about 1-3 refilling cycles whereas an LLC can be taken through about +15 refilling cycles. A single-cycle cartridge (SCC) is a special case in that it is designed to be used for one use cycle only, after which the cartridge goes directly to its end of life phase. 23 In the 2010 Draft Version of Industry Voluntary Agreement to Improve the Environmental Performance of Imaging Equipment Placed on the European Market 24, there is a preference for 21
UKCRA personal correspondence & DigitalEurope, 2009, ‘Recycling, Reuse, and the Print Cartridge Lifecycle.’ Excerpt from Xfaneon 2008, p.20. 23 Excerpt from Xafeon 2008, p.6. 24 Industry Voluntary Agreement to Improve the Environmental Performance of Imaging Equipment Placed on the European Market, Draft Version 2.5, 19 February 2010. http://www.eupnetwork.de/fileadmin/user_upload/Produktgruppen/Lots/Working_Documents/Lot_04_Imaging_Equipment/Voluntary_ Ind_Agreement_EUP_LOT_4_Imag_Equipment_2010-03.pdf 22
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toner cartridges to be designed in such a manner that their disassembly for re-use or recycling is easy. Following is an excerpt from the Agreement, “From 1 January 2011, toner modules and containers as well ink modules and containers placed on the market by Signatories along with the original equipment, as well as those recommended in the product documentation for use in the respective device, must be so designed as to enable their channelling to reuse or material recycling”. Organisations contacted during the revision work on the UNEP toner cartridges purchasing guidelines -
Ecolabelling Sweden New Zealand Ecolabelling Trust Duurzame Consumptie en Productie - Consommation et Production durables Japan Environment Association (JEA), Ecomark Office Responsible Purchasing Network King County Procurement Section, Environmental Purchasing Program National Research Centre for the Working Environment Centre for Remanufacturing & Reuse ASTM International DIN Deutsches Institut für Normung Normenausschuss NIA und NDR Xerox Corporation Hewlett-Packard Sharp Electronics (UK) Ltd. UKCRA (UK Cartridge Remanufacturing Association) ETIRA (European Toner & Inkjet Cartridge Remanufacturing Association) Kleen Strike (UK) Ltd. Promax Imaging Ltd Green Cartridges Ltd
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