1 List of issues relevant for adding non
AT - Fed. Min. for Agriculture, Forestry, Environment + Water Management (Sonja Loew)
NL – VROM (Herman Hofman)
Sept. 2008
List of issues
relevant for adding non-listed wastes to Annex IIIB
of Regulation (EC) No 1013/2006 on shipments of waste
The information marked by an asterisk (*) is recommended to be provided. The other information
may be provided in addition.
Composite material [B3010+B1010+B3040+B4010]
Sorted cartridges and drum:
- sorted** toner cartridges containing non-hazardous toner residues:
- drum-driven cartridges not containing any hazardous materials (e.g. unproblematic (OPC) organic
photo-conductive drums:
- drums with a scratch-resistant amorphous silicon layer or zinc oxide coating):
- black inkjet cartridges and other cartrigdes containing residues of non-hazardous inks (see safety
data sheets)
** sorted by manufacturer and model/type.
1. Usual description*: sorted toner and ink cartridges containing non-hazardous toner residues
In addition, for each fraction of the mixture: Give the name or names by which the material is commonly known
or the commercial name and the names of its major constituents (in terms of quantity and/or hazard) and their
relative concentrations (expressed as a percentage), if known:
Major constituents: empty cartridges contain a variety of steel, aluminium and plastic materials, rubber
and traces of printing inks and toners (e.g. plastic housing, tabs, handles and gears, metal drum, axles,
springs and screws, and residual toner/ink )
2. Waste identification (fill in relevant codes)*
European Community list of wastes:
Presently different member states use different codes for empty toner and ink cartridges; Grey marked
EWC-codes are the most appropriate codes for non-hazardous toner cartridges
08 03 18
20 01 28
waste printing toner other than those mentioned in 08 03 17*
paint, inks, adhesives and resins other than those mentioned in 20 01 27*
16 02 16
components removed from discarded equipment other than those mentioned in 16 02 15*
discarded electrical and electronic equipment other than those mentioned in 20 01 21*,
20 01 23* and 20 01 35*
20 01 36
Grey marked EWC codes are the most appropriate codes for non-hazardous ink cartridges
08 03 13
20 01 28
16 02 16
waste ink other than those mentioned in 08 03 12
paint, inks, adhesives and resins other than those mentioned in 20 01 27
components removed from discarded equipment other than those mentioned in 16 02 15*
20 01 36
discarded electrical and electronic equipment other than those mentioned in 20 01 21, 20
01 23 and 20 01 35
Basel Annex IX (if appropriate): no specific entry for empty toner and ink cartridges at the moment;
AT - Fed. Min. for Agriculture, Forestry, Environment + Water Management (Sonja Loew)
NL – VROM (Herman Hofman)
Sept. 2008
composite material plastic+metal+rubber+toner/ink [B3010+B1010+B3040+B4010]
Potential codes for classification at the moment:
Entry B1110 does not apply for shipments within OECD area; some authorities use the GREEN LIST
CODE GC 020 electronic scrap (e.g. printed circuit boards, electronic components, wire, etc.) and
reclaimed electronic components suitable for base and precious metal recovery (on the basis of the
former Correspondents Guidelines) or classify the waste as “non-listed”, requiring NOTIFICATION.
OECD code (if appropriate and if different from Basel code): GC020 or non-listed;
Customs code(s) (HS) (if appropriate):
Industrial standards (if appropriate):
3. Physical characteristics*
X solid
other (specify)
If appropriate, indicate also details, such as pellets, briquettes, etc.:
Cartridge may contain residues of powder or liquid - viscous-pasty toner /ink residues
Toner cartridges
Composition: The toner cartridge is filled with toner. Toner is an electrostatically charged powder,
consisting primarily of pigment and plastic (Æ toner compositions vary – see safety data sheets). The
pigment provides the color, and the plastic provides the electric charge and, when melted in the fuser,
the adhesion to the paper. In addition to the metal drum, the cartridge's plastic shell houses a number
of latches, gears and axles.
Drum-driven cartridges without hazardous components are such containing unproblematic (OPC)
organic photo-conductive drums, drums with a scratch-resistant amorphous silicon layer or zinc oxide
coating. The toner cartridge contains a photo-sensitive drum, primary charging roller, developing
station, toner reservoir and cleaning station. The drum is an aluminium cylinder coated with a layer of
non-toxic, organic-photoconductive (OPC) material. The OPC material becomes electrically conductive
when exposed to light. During the printing process, a laser beam traverses the surface of the OPC
drum and selectively discharges parts of the surface. It thereby composes a latent, electrostatic image
on the drum. The developing process then changes the latent image into a visible image by depositing
negatively charged toner particles on the exposed areas of the drum.
Many so-called re-manufactured toner cartridges are not fitted with a new OPC drum as this reduces
the cost of manufacture. These cartridges may print quite well when first used but their print quality will
gradually deteriorate.
In some printers the primary charge roller (PCR) is located in the printer, external to the cartridge. It is a
solid rubber roller with a metal core. It is located beside the OPC drum. During the printing process, a
high voltage is applied across the PCR and it rotates against the drum thereby coating the light
sensitive surface with a negative electrostatic charge. The surface of the PCR will gradually be coated
with a grey film of unused toner and it should be cleaned each time a new cartridge is installed into the
printer. After many prints, the surface of the rubber roller can wear or be damaged by contaminants,
necessitating its replacement. In other printers, the PCR is located inside the toner cartridge. It is also
coated with conductive rubber and it must be cleaned, inspected and replaced if necessary during the
re-manufacturing process.
Some cartridges contain a solid rubber developer roller which assists the transfer of toner from the
reservoir onto selected areas of the OPC drum. The developer roller needs to be carefully examined
and refurbished or replaced during the cartridge re-manufacturing process.
In specific printers, the developing station consists of a metallic cylinder that rotates around a fixed
magnetic core. It is usually referred to as the magnetic roller or “mag” roller. These parts also wear
AT - Fed. Min. for Agriculture, Forestry, Environment + Water Management (Sonja Loew)
NL – VROM (Herman Hofman)
Sept. 2008
and need to be inspected and replaced if necessary.
Toner: Laser printer toner is a powdery substance made of black plastic resin (e.g. styrene acrylate
copolymer) bound to iron oxide particles. Over time, After-market toners may differ slightly in chemical
composition to the original manufacturer’s formulation and hence they may not be truly compatible.
Therefore it is important to remove any old, unused toner from the reservoir before any new toner is
The cartridge contains a cleaning blade which sits in contact with OPC drum. As the drum rotates
during printing, excess toner is removed from the drum surface and stored in the waste toner
receptacle inside the toner cartridge. This receptacle must be emptied when the cartridge is remanufactured or it will subsequently over-fill and leak waste toner into the printer. At the same time,
the cleaning blade should be replaced to ensure its surface seals well against the drum.
After all wearing parts have been cleaned, inspected and replaced if necessary, the cartridge is
carefully re-assembled and any damaged seals replaced. It is then filled with an after-market toner that
can vary in quality and price from one brand to another.
Inkjet cartridges
Composition: The two main technologies in use are the bubble jet (HP and Canon) and the piezoelectric inkjet system (patented by Epson.). In the former, each of the 300-600 channels is equipped
with a resistor that functions as an independently operating heating element. When the channel is
heated, a bubble forms and ultimately pops, spraying a miniscule amount of ink onto the paper. This
happens at a very high speed of some 6,000 droplets per second. In Epson's system, each channel
contains a piezo crystal, which vibrates when exposed to an electrical current, spraying a miniscule
amount of ink onto the paper.
Inkjet cartridges use both oil-based and water-based inks. The water-based inks contain significant
amounts of water-soluble organic solvents. The exact composition of the ink depends strongly on the
manufacturer and on the technology used (Æsafety data sheets). Unlike piezo-electric inkjets, bubble
jet systems for example require inks that are stable at higher temperatures.
Thermal Inkjets: Most consumer inkjet printers, such as Canon, HP, and Lexmark (but not Epson
printers) use a thermal inkjet; inside each partition of the ink reservoir is a heating element with a tiny
metal plate or resistor. In response to a signal given by the printer, a tiny current flows through the
metal or resistor making it warm up, and the ink immediately surrounding the heated plate is
vapourised into a tiny air bubble inside the nozzle. As a consequence, the total volume of the ink
exceeds that of the nozzle. An ink droplet is forced out of the cartridge nozzle onto the paper. This
process takes a matter of milliseconds.
Desktop inkjet printers, as used in offices or at home, all use aqueous inks based on a mixture of
water, glycol and dyes or pigments. Aqueous inks are mainly used in printers with disposable, socalled thermal inkjet heads, as these heads require water in order to perform.
Some professional wide format printers use aqueous inks, but the majority in professional use today
employ a much wider range of inks, most of which require piezo inkjet head (e.g. solvent inks, UVcurable inks consisting mainly of acrylic monomers with an initiator package).
4. Chemical characteristics
Attach an analysis if appropriate. Depend on type of toner or ink
Black print ink cartridge
Agri-based inks are predominately made from non-toxic soybean oil instead of petrochemicals.
Typically, soy-based ink contains 20 percent to 100 percent soy oil, which is also a renewable
resource. Using soy and other vegetable oils reduces VOC emissions.
AT - Fed. Min. for Agriculture, Forestry, Environment + Water Management (Sonja Loew)
NL – VROM (Herman Hofman)
Sept. 2008
The following black ink is non-hazardous and not classified according to EU Directive 1999/45 EC:
Pure carbon black, a minor component of the black ink, has been listed by IARC as group 2B (possible
carcinogen). This classification is based on rat "lung particulate overload" studies performed with
airborne particulate carbon black. Studies performed in animal models other than rats did not show
any association between carbon black and lung tumors. Moreover, a two-year cancer bioassay using a
typical toner preparation containing carbon black demonstrated no association between toner
exposure and tumor development in rats. Ink is not listed by IARC, NTP, or OSHA.
Color printing inks
Some color printing inks may be hazardous, others not (e.g. in the following example cartridges
containing residues of cyan-ink may be classified as hazardous substance due to the risk phrase
R52/53 - Harmful to aquatic life with long lasting effects; however this depends on on the national
definition of “ecotoxic”
Relevant R-Phrases:
contact with combustible material may cause fire
Harmful in contact with skin.
Harmful if swallowed.
Toxic by inhalation.
Toxic if swallowed.
Irritating to eyes.
Irritating to respiratory system.
Irritating to skin.
Danger of very serious irreversible effects.
Danger of serious damage to health by prolonged exposure.
May cause cancer by inhalation.
Very toxic to aquatic organisms.
Toxic to aquatic organisms.
Harmful to aquatic organisms.
May cause long-term adverse effects in the aquatic environment.
AT - Fed. Min. for Agriculture, Forestry, Environment + Water Management (Sonja Loew)
NL – VROM (Herman Hofman)
Excerpt of a material safety data sheet of a Color Laser Printer Yellow Dry Ink
Sept. 2008
AT - Fed. Min. for Agriculture, Forestry, Environment + Water Management (Sonja Loew)
NL – VROM (Herman Hofman)
Sept. 2008
Excerpt of a material safety data sheet of a black print toner cartridge
5. Potential for contamination*:
Description on any potential for contamination by other materials to an extent which
(a) is sufficient for submission to the procedure of prior written notification and consent, or
(b) prevents the recovery of the wastes in an environmentally sound manner:
no risk of contamination if the safety data sheets of the specific toner or ink do not show hazard
characteristics (one problem should be mentioned: illegally refilled counterfeit toners; composition of
the toner can deviate from the original toner/ink and may even contain heavy metals)
Possible hazardous characteristics (cf. Annex III to Directive 91/689/EEC on hazardous waste): none
H1 explosive H2 oxidizing H3-A highly flammable H3-B flammable H4 irritant H5 harmful H6 toxic H7 carcinogenic
H8 corrosive H9 infectious H10 teratogenic H11 mutagenic H12 substances and preparations which release toxic or very toxic
gases in contact with water, air or an acid H13 Substances and preparations capable by any means, after disposal, of yielding another
substance, e.g. a leachate, which possesses any of the characteristics listed above H14 ecotoxic
AT - Fed. Min. for Agriculture, Forestry, Environment + Water Management (Sonja Loew)
NL – VROM (Herman Hofman)
Sept. 2008
6. Information on the process(es) by which the mixture of waste is produced*:
Renewal of toner or ink-cartridges in copying machines or printers – collection centers for take back
1. Technological capacity
Estimated capacity for recovery in the EU in tonnes: 1,2 million tonnes
Estimated amount of facilities for recovery in the EU:
X >100-1000
Possible third countries where recovery facilities are located: Asia
2. Packaging types
Wooden barrel
Composite packaging
Pressure receptacle
x Bulk
Other (specify):
In most cases the cartridges are packed in cardboard boxes on pallets
3. Storage
Methods of storage at the recovery facility (if appropriate):
In boxes on pallets - indoor storage or storage in freight containers like in case of new products
4. Trade aspects
Amount of waste shipped within the EU (rough indication): 350.000 tonnes
Amount of waste export from the EU or import to the EU from third countries (rough indication): no data
5. Recovery operation(s) for the mixture of waste* (cf. Annex IIB to Directive 2006/12/EC on waste):
X R1
X R3
Use principally as a fuel or other means to generate energy
Solvent reclamation/regeneration
Recycling/reclamation of organic substances which are not used as solvents (including composting and other biological
transformation processes)
X R4 Recycling/reclamation of metals and metal compounds
Recycling/reclamation of other inorganic materials
Regeneration of acids or bases
Recovery of components used for pollution abatement
Recovery of components from catalysts
Used oil re-refining or other reuses of previously used oil
R10 Land treatment resulting in benefit to agriculture or ecological improvement
R11 Use of wastes obtained from any of the operations numbered R 1 to R 10
R12 Exchange of wastes for submission to any of the operations numbered R 1 to R 11
x R13 Storage of wastes pending any of the operations numbered R 1 to R 12 (excluding temporary storage, pending collection,
on the site where it is produced)
6. Description of recovery operation(s)*
Indicate the technologies employed for the non-interim recovery operation(s):
AT - Fed. Min. for Agriculture, Forestry, Environment + Water Management (Sonja Loew)
NL – VROM (Herman Hofman)
Sept. 2008
A re-manufactured toner cartridge is a used cartridge that has been dismantled, cleaned and rebuilt
using a combination of old and new components.
This differs from a re-filled toner cartridge which has not been dismantled and cleaned but simply
refilled with new toner.
The recycling/up-grading process includes the change of spare and wear parts (e.g. axels), the
recovery or disposal of residual toners and the recovery of the plastic cartridge after its useful lifecycle.
Toner returns are unpacked from their boxes, booked in to a computer tracking system and
segregated by model into pallet boxes (resulting wastes: cardboard, styrofoam, plastic bags and foil
bags) On an average basis approx. 85% of returns are re-filled, 15% are unsuitable for refilling. Usable
toners (85%) are refurbished, tested, and refilled.
Non-usable toners (15%) are dismantled, and the high impact polystyrene body is recovered as a raw
The toner cartridges are cleaned using high pressure air to remove any dust from the outside case
with the dust and dirt being captured in a high volume extraction system. The remaining toner dust
from inside of the toner carriage of is then extracted using a high pressure vacuum system (wastes –
toner dusts captured in high pressure and volume extraction systems)
Parts used in the remanufacturing of the toner cartridges are unpacked in this area to ensure that no
paper or cardboard enters the clean room (wastes –cardboard, paper and plastic bags).
After the residue toner has been removed, reusable cartridges are identified and separated from those
deemed non-recoverable, before being put through a sophisticated refurbishment and refilling process
Non-recoverable parts (rollers, gears and labels) area removed from the toner cartridges before new
parts are fitted
During the upgrading/refurbishment process of laser printer toners the old wiper blade is removed and
replaced with a new blade. The old OPC-drum is replaced with a new OPC-drum. The waste hopper
side of the cartridge is stripped out, the “mag-roller” removed. Then the cartridge is ready to
remanufacture. After the new toner has been filled in, the cartridge is reassembled; The cartridge is
cleaned, individually tested and placed in a sealed mylar foil bag.
The toners are packed into cardboard boxes and stacked on wooden pallets, before being shrink
wrapped ready for shipment ( wastes – cardboard)
The cartridge is crushed in a crushing step while particles such as toner are collected by suction,
particles including toner are further separated in a screening step, metal materials are separated in a
magnetic selection step, a drum magnetic selection step, and an eddy current step, particles including
toner and foreign matter are separated in an air selection step, a secondary crushing step, a peeling
step, and a dry gravity separation step, and a plastic material having a specific density is separated in
a color selection step.
Inkjet cartridges:
Inkjet cartridges undergo a multi-phase recycling process that reduces them to raw materials such as
plastics and metals. A few companies combine plastic from the inkjet cartridges with recycled bottle
resin and a suite of compounding additives to ensure all recycled materials meet high-performance
standards. The amount of recycled content in these inkjet cartridges may vary between 70 to 100
percent of the total plastic used, but the reliability results for each product are stringently tested. In
case of ink cartridge re-fill no wear parts are removed, the tank is re-filled. After refilling a print
cartridge several times, the print head will wear out. Depending on the type of cartridge a change of
the print head may be economically feasible.
Value of empty toner cartridges: prices paid for empty cartridges are between € 2,50 and € 5,00 a piece.
Indicate the technologies employed for any interim recovery operation(s):
AT - Fed. Min. for Agriculture, Forestry, Environment + Water Management (Sonja Loew)
NL – VROM (Herman Hofman)
Sept. 2008
Take-back centres for empty toner /ink cartridges store the cartridges prior to upgrading/
refurbishment/ recycling (R13); sometimes customers can return their used toner cartridges via
respective freepost programmes in their country.
7. Use of recovered materials (e.g. compliance with technical/industrial quality standards):
material recovery (R3) or energy recovery of plastics (R1); Sometimes whole empty cartridges
containing a variety of steel, aluminium and plastic materials are ground into small particles for
use in making “composite plastic” products such as outdoor furniture.
metal recovery of metals (R4)
energy recovery (R1) or sometimes disposal (D10) of ink/toner residues
8. Recovery quota (rough indication)*
Amount of recovered material in relation to non-recoverable waste:
• For every ton of toner cartridges returned, an average of 650 kg of materials is directly re-used
within a new product (approx. 65%).
• The remaining 350 kg (approx. 35%) is recycled externally.
• Normally no waste materials are land-filled.
Non-recoverable fraction (list typical fractions and their major constituents): toner and ink residues
Typical method of disposal (operation) for the non-recoverable fraction:
normally incineration of toner residues
Overall environmental benefits of the recovery of the mixture of waste*:
x Virgin material conservation x Energy conservation x Emission reduction (e.g. reduction of greenhouse gas emissions)
x Reduction of the amount of waste destined to disposal
Other (please describe):
Per 100.000 recovered toner-cartridges approx 9599 kg Aluminium, 40 tons of plastics can be
saved (corresponds to 1.000.000 litre oil)
Possible methods for the control of compliance of the mixture of waste with the proposed entry for Annex
IIIB by enforcement officers (e.g. simple tests)*:Optical control; safety data sheets
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