- Directive 2014/35/EU — Low Voltage
- Directive 2014/30/EU — EMC
- Regulation (EC) No 1272/2008 — CLP for inks and toners
- Directive 2012/19/EU — WEEE
- Regulation (EU) 2023/988 — GPSR
- Directive (EU) 2015/2436 on trade marks for compatible products
Who has to appoint one
Manufacturers and sellers outside the Union placing printers or consumables on the EU market. Compatible and remanufactured cartridges are a large cross-border category with its own trade mark exposure alongside the product duties.
Thresholds and exemptions
None. Cartridges are in scope of WEEE in several member states and of packaging EPR everywhere.
What must appear on the label
For printers: CE marking, manufacturer and EU representative details, model and serial number, rated data and the WEEE symbol. For cartridges: manufacturer and responsible person details, batch identification, CLP information where the ink or toner is classified, and a clear indication that a compatible product is not made by the original brand.
Marketplace fields
Marketplaces enforce the responsible person on consumables and act quickly on trade mark complaints, which in this category are as commercially significant as product compliance. Listings describing a compatible cartridge in a way that suggests it is original are removed.
Documentation you must hold
EU declaration of conformity and technical file for the printer, CLP classification and safety data sheets for inks and toners, poison centre notification with UFI where classified, and WEEE and packaging registrations. For compatible products, evidence of the design being independent and non-infringing.
Standards and testing
EN IEC 62368-1 for the printer, EMC testing, emission testing for particles and volatile compounds from laser printers where claims are made, and CLP classification for the ink or toner formulation.
Language requirements
Instructions and safety data sheets in the language of each member state of sale.
When it applies
Before placing on the market, with EPR registrations before the first shipment into each country.
How long records are kept
Ten years for documentation and EPR declarations per national law.
What happens if you do not comply
Withdrawal and fines, marketplace suspension for missing EPR numbers, and separately customs seizure and civil injunctions where a compatible cartridge infringes a trade mark or patent.
Who enforces it
Market surveillance authorities, chemicals authorities, WEEE registers, customs and the courts for intellectual property.
Where the boundary lies
Intellectual property is the distinctive risk in this category: compatible cartridges are lawful in principle, but chip designs, brand references in listings and patented ink delivery mechanisms generate seizures at the border that no product compliance file can prevent.
Questions we are asked
- Are compatible cartridges legal?
- Yes in principle, provided they do not infringe patents or trade marks and are not presented as original. The listing wording matters as much as the product.
- Do cartridges need WEEE registration?
- In several member states yes, and packaging registration applies everywhere. Check per country before shipping.
Who signs for you
EU representative Europe Services, SE — Na Čečeličce 425/4, Smíchov, 150 00 Praha 5, Czech Republic
UK representative REP27 LTD — Unit 82a James Carter Road, Mildenhall, Suffolk IP28 7DE, United Kingdom