The statement that it would not be necessary to qualify printer cartridges as electrical devices was made regarding the field of application of the Electrical and Electronic Equipment Act (ElectroG/WEEE) in the FAQ of the commission and the original notes of the German Federal Ministy for the Environment, Nature Conservation and Nuclear Safety. From the point of view of the Foundation EAR (=German national registration board) this statement is no longer applicable in this way.
Furthermore, printer cartridges are available on the market which are equipped with electrical or electronic functions. Such cartridges are equipped with a chip, a sensor, an RFID chip or an LED status display (as the case may be also a combination of these items) – depending on the type. In this case, the printer cartridge requires electrical currents or electromagnetic fields in order to fulfill their functions.
Therefore, in these special cases the Foundation EAR assumes that such printer cartridges come under the field of application of the Electrical and Electronic Equipment Act (ElektroG). Of course, in order to be sure in cases of doubt, manufacturers can make an application for assessment at the Foundation EAR.
The team of take-e-way will be glad to support you, if you are concerned with it and will support you in registering your items according to the Electrical and Electronic Equipment Act (ElektroG). We are looking forward to your call: +49 / 40 / 21 90 10 - 65.
Source: Foundation EAR/Stiftung Elektro-Altgeräte Register (EAR Insight Newsletter 03/2012, October 1st, 2012). Also refer to: https://www.stiftung-ear.de/fileadmin/download/newsletter/ear-insight-03-2012.pdf