Handling Ink Cartridges and Toner

Q: When processing ink cartridges and toner, does an R2 facility need to audit a downstream vendor according to Appendix A or Appendix E?

Since print cartridges are not included in the definition of Focus Materials, they are considered an Unrestricted Stream and are not subject to R2 processing or DSV verification requirements.  However, print cartridges are identified as a non-focus material that requires specific management, and there are two defined requirements related to print cartridges:

1. 1. Under Appendix E – Materials Recovery, requirement (6) indicates that print cartridges must be removed prior to shredding or materials recovery of equipment; and
   2. Core Requirement 8.(b), indicates that print cartridges must be managed in accordance with the Core Requirement 2, the Hierarchy of Responsible Management Strategies.  This means that where practical, cartridges should be directed to a reuse application, and when not suitable for reuse, materials recovery should be considered prior to any disposal options.