UKCRA alarmed by EPR’s threat to cartridge reuse
February 21, 2024
UKCRA voices concerns over EPR undermining cartridge remanufacturing and calls for a redefinition of ‘waste’.
The UK Cartridge Remanufacturers Association (UKCRA) has raised concerns over the potential impact of Extended Producer Responsibility (EPR) on the remanufacturing sector, particularly regarding the reuse of printer cartridges. UKCRA suggests that the EPR, aimed at reforming Waste Electrical and Electronic Equipment (WEEE) Regulations, could inadvertently hamper the cartridge remanufacturing industry.
“Used cartridge collection programs provide a significant service,” says UKCRA spokesperson Laura Heywood. “If the EPR is too linear, it threatens the reuse of these products.”
UKCRA also challenges the current definition of waste within the WEEE Directive, arguing it should be aligned with the emerging EU circular economy’s principles. The association recommends revisiting the historical definition of waste for assets that are reused and repaired, especially in the context of remanufacturing.
“The legal definition of waste comprises a two-stage test,” explains Heywood. “Clarification is needed when a cartridge is sent to be refilled, as it remains in the chain of utility and should not be classed as waste.”
The industry body also contends that the term ‘discard’ is not appropriate when a consumer sends a cartridge for refilling or remanufacturing. “The cartridge should be reused before being sent to a designated recycler,” they argue, citing the WEEE Directive’s emphasis on product design for reuse.
Furthermore, UKCRA warns that the OEM sector could leverage WEEE and EPR to obstruct the collection of used cartridges, pushing a model focused on recycling into lower value materials rather than reuse. They suggest that the UK should encourage the development and growth of remanufacturing within the EPR framework of the WEEE Directive, echoing sentiments from the UK Government’s ‘Triple Win’ Report on remanufacturing.
“It was the UK remanufacturing Industry through UKCRA that influenced the WEEE Directive to include reuse,” they assert. “Toner cartridges are highly engineered; refilling and replacing worn parts is the only positive approach.”
This stance by UKCRA highlights the complexities and unintended consequences that new environmental regulations can have on existing circular economy practices, emphasising the need for careful consideration and inclusive policymaking.
Categories : World Focus
Tags : EPR Laura Heywood UK UKCRA WEEE
