Printech Archives, November 1997: Re: Recycling Printer Cartridges

Re: Recycling Printer Cartridges

Wayne Pferdehirt (
Thu, 20 Nov 1997 16:26:56 CST

More follow-up on the printer cartridge discussion. Forwarded from
the P2Tech listserv:

------- Forwarded Message Follows -------

Now that my phone number was posted, I guess I'll enter this
discussion. First, though, let me request that you don't call me
because I don't want to be inundated with phone calls about ink jet
cartridges. Also, I want to emphasize that the performance of
remanufactured toner cartridges is a separate issue. EPA has found
that remanufactured toner cartridges perform adequately, and we
designated this product for government procurement in 1995.

Last year, as part of our procurement guidelines program to designate
recycled content products for government agencies to purchase, we
proposed to designate refilled/remanufactured ink jet cartridges. We
received significant comments opposing the proposed designation. In
researching the issues raised by commenters, we found that, unlike
toner cartridges, there were no industry, ASTM, or government
standards for recycled ink jet cartridges. Government agencies had
divergent experiences with recycled cartridges and with the cartridge
recycling kits. While some companies provided a quality product,
others did not.

In addition, we found conflicting information about whether ink jet
cartridges are designed to be refilled. Unlike toner cartridges, ink
jet cartridges are designed to be obsolete after the original supply
of ink is used. According to the original equipment manufacturers,
the print heads and the internal components wear out as the ink is
used. However, there is evidence that ink jet cartridges can and are
being refilled and can perform adequately.

One of our key criteria for designating items is that the designation
will have a significant impact on the solid waste stream. We found
that the type of plastic used in ink jet cartridges is not currently
recyclable and cannot contain recovered materials. Thus, we concluded
that designating ink jet cartridges would not create end-use markets
for the types of plastics typically recovered from municipal solid
waste and would not have a significant impact on the solid waste

Commenters also raised concerns about violation of patents and
trademarks. While EPA did not research this particular issue, I
wanted you to be aware that the original equipment manufacturers claim
that there have been violations by some of the refillers.

As a result, EPA concluded that it is premature to designate ink jet
cartridges at this time. Our discussion of the issues can be found in
the April 14, 1997 Federal Register at pages 18072-18074. We did not
receive any comments from refillers/remanufacturers addressing these
issues even though we actively solicited comments from the industry
trade association. Only one company with a refilling technology
submitted comments, but the comments did not address the quality and
performance standards concerns or the solid waste issues.

EPA would like to see the refilling/remanufacturing industry develop
standards for properly refilling ink jet cartridges. These can be
industry standards, ASTM standards, or government agency standards, as
long as they assure the quality and performance of the
refilled/remanufactured products. We believe that such standards will
reduce or eliminate the types of performance problems experienced by
some users. We encourage those refillers/remanufacturers that are
producing a quality product to lead an effort to develop standards.

EPA will continue to monitor developments in ink jet cartridge
refilling/remanufacturing technology.



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