Sustainable Consumption Law 2026 and the toner block
Actualizado 18 julio 2026Share
If you've ever fitted a perfectly full cartridge and your printer threw an "unauthorized cartridge" message and dug its heels in, this is for you. On 1 July 2025 the Council of Ministers approved, at first reading, the draft bill for the Sustainable Consumption Law, and for the first time a Spanish rule puts a name to that move: blocking a working consumable by software. The law isn't in the BOE yet —we'll come back to that— but the substance points squarely at the firmware that decides for you which cartridge you can use. Let's translate it into what it means for your wallet, without overstating what it does or doesn't do.
Key takeaways
- The draft bill was approved in the Council of Ministers on 1 July 2025 and is expected to take effect between July and September 2026 (EL PAÍS, 2025).
- EL PAÍS cites literally "generic-brand printer cartridges" as an example of what the law protects.
- It doesn't ban firmware: it bans hiding that an update will degrade your machine and lying by saying a non-original cartridge will damage it.
- The backing already exists: HP was fined 10 million euros in Italy (2020, appeal dismissed in 2024) for not warning that its updates blocked compatibles (AGCM, 2020).
- It's a draft bill in the parliamentary process, not settled law. It still has to pass public consultation and the Congress.
What is the Sustainable Consumption Law and who does it affect?
The Sustainable Consumption Law is the Spanish rule that transposes two European directives —2024/825, against greenwashing, and 2024/1799, on the right to repair— and strengthens consumer protection against planned obsolescence. Its draft bill was approved on 1 July 2025 and is expected to take effect between July and September 2026 (The Conversation, 2026).
Driven by the Ministry of Social Rights, Consumer Affairs and Agenda 2030 (minister Pablo Bustinduy), it amends the Unfair Competition Law (Law 3/1991) and the TRLGDCU, Royal Legislative Decree 1/2007, which is the backbone of consumer rights in Spain. It affects you as a buyer of any product with "digital elements": phones, home appliances and, yes, printers.
Greenwashing is presenting a product or practice as more environmentally friendly than it really is. The law goes after it in the same package as the blocking of non-original parts, because both share a root: selling the consumer a story that doesn't hold up in order to extract more money.
Why does this law mention printer cartridges?
Because the text itself and its press coverage put them forward as a textbook example. In describing which practices it prohibits, EL PAÍS gives the literal example that the law bans hiding the deterioration of a product's functionality when non-original consumables are used "as happens with generic-brand printer cartridges" (EL PAÍS, 2025). It's not a stretched reading on our part: it's the example they chose.
The draft bill prohibits four things that, translated into your wallet, describe point by point what printer firmware does:
- Hiding that a software update will negatively affect the operation of a product with digital elements.
- Falsely claiming that deterioration will occur from using a non-original consumable, spare part or accessory.
- Presenting as necessary an update that only improves non-essential functions.
- Blocking or penalizing the use of non-original spare parts or accessories.
elDiario.es puts it bluntly: this last practice, penalizing non-original parts, is "common in sectors like printing or smartphones" (elDiario.es, 2025). Printing is named directly. If you've got this far searching for why your compatible toner stops working from one day to the next, you now have the institutional answer.
What exactly is HP's Dynamic Security?
Dynamic Security is HP's system that, via firmware, validates the cartridge chip and blocks printing if it doesn't recognize it as original, even if the consumable is full. It shows messages like "Cartridge Problem," "Non-HP cartridge installed," "Supply Protection Enabled" or "Used, Refilled or Counterfeit Cartridge." It's not a fault: it's a commercial policy applied by software, almost always with an update after purchase.
That "after purchase" is the legal key. When you bought the printer, the compatible worked. Months later, an update cripples it. That's where the Sustainable Consumption Law hits the mark: the problem isn't so much that the firmware exists, but that the degradation arrives without warning and disguised as an improvement.
Citable capsule: Dynamic Security isn't a cartridge defect. It's firmware that checks the chip and stops printing a full but "non-HP" consumable. The Sustainable Consumption Law 2026 doesn't prohibit it directly; it prohibits hiding that an update will degrade the machine and falsely claiming that a non-original cartridge will damage it (EL PAÍS, 2025).
We have the complete timeline of this system, with all the firmware versions and affected models, in our guide to why HP firmware blocks cartridges. Here the angle is different: the new rule and what it lets you claim.
Does the law ban the firmware that blocks cartridges?
No, and it's worth saying clearly to avoid misleading anyone. The law does not prohibit Dynamic Security nor force HP to accept compatibles automatically. What it does is reinforce transparency: it bans hiding that an update will degrade the machine, lying about a non-original cartridge damaging it, presenting updates for non-essential functions as necessary, and penalizing the use of non-original parts as a practice of obsolescence (elDiario.es, 2025).
The difference matters. A headline like "the law bans HP's firmware" is false and would leave you high and dry if you try to make a claim on that basis. The correct version is: the law recognizes planned obsolescence as a sanctionable practice for the first time and gives you transparency tools. It's a strengthening of rights, not a magic button that unblocks your printer.
Does that mean the law has no teeth? On the contrary. It has them, and they've already been seen in Europe even before this rule existed.
Are there already real sanctions for blocking cartridges with firmware?
Yes, and this is the part that clears up the "this is future smoke" doubt. In December 2020, the Italian competition authority (AGCM) fined HP Inc. and HP Italy 10 million euros for misleading and aggressive commercial practices, precisely for not informing that its Dynamic Security updates blocked non-original cartridges; HP appealed and in 2024 the court dismissed the appeal, so the fine is final (AGCM, 2020).
It's the toughest EU sanction in this field, and its basis —not warning that an update degrades the machine— is exactly what the Spanish law now turns into a defined infringement. Across the Atlantic, the "Carolina" class action (Mobile Emergency Housing Corp. et al. v. HP Inc., 5:20-cv-05624, Northern California) closed in March 2025: with no compensation for the class, but requiring HP to keep the updates that incorporate Dynamic Security optional (The Register, 2025).
Citable capsule: The Italian AGCM fined HP 10 million euros in December 2020 for not warning that its updates blocked non-original cartridges; HP appealed and lost in 2024. It's the most solid European precedent for any claim about firmware blocking (AGCM Resolution 28522/2020, case file PS11144) (AGCM, 2020).
What can I claim in Spain if the firmware blocks a cartridge?
You can claim for an unfair commercial practice, relying on the TRLGDCU and the European unfair-practices directive, with a now-final sanctioning precedent in your favor. The specific legal basis: arts. 116 and 120 of the TRLGDCU (RDL 1/2007), Directive 2005/29/EC (arts. 20 and 49) and AGCM Resolution 28522/2020 as a citable precedent. You don't have to wait for the new law to be in the BOE to invoke these rights.
The first thing is to gather evidence while it's fresh. Save:
| Evidence | Why it matters |
|---|---|
| Printer invoice | Proves the purchase date and that the machine worked with that consumable |
| Previous firmware version | Shows the degradation arrived with a later update |
| Photo of the block message | "Non-HP cartridge installed," "Supply Protection Enabled," etc. |
With that, you file a complaint form with the seller or manufacturer and, if they don't respond, you go to the Consumer Affairs office of your autonomous community. Citing the Italian resolution and the articles of the TRLGDCU tells the other party that you know what you're talking about. We've broken down the legal terrain, with what the rule does and doesn't cover, in our guide on the legal warranty on compatible cartridges in Spain.
Do I lose the printer's warranty for using compatible cartridges?
No. The law cannot condition the machine's warranty on the exclusive use of the manufacturer's consumables, unless the consumable causes demonstrable damage (art. 117 of the TRLGDCU and EU Directive 2019/771). That HP, Brother or Epson would prefer you buy their brand doesn't mean using a compatible voids your right. It's a very profitable myth for the manufacturer, full stop.
What you are now entitled to, and in generous figures: a legal warranty of 3 years; if you choose to repair rather than replace a product under warranty, it extends 12 months more, up to 4 years (The Conversation, 2026).
Once the warranty is over, the manufacturer, marketer or importer must co-finance the repair on a decreasing basis: 20% of the cost in the first year, 10% in the second and 5% in the third. And there's an obligation to maintain technical service and spare parts for 10 years after the last manufacturing date, at a reasonable price (EL PAÍS, 2025).
And if you're worried about the difference between a legal compatible and a counterfeit —which are different things— we clarify it in counterfeit vs. compatible cartridges.
How much can the law fine someone for greenwashing?
Enough that it doesn't pay to break it. The TRLGDCU's sanctioning regime sets minor infringements from €150 to €10,000 (or up to 2-4 times the illicit benefit) and serious ones from €10,001 to €100,000 (or up to 4-6 times the illicit benefit obtained). The sanctions must be "effective, dissuasive and proportionate" (Vida Sana, 2025).
Beware the easy headline: the €100,000 is the ceiling for serious infringements, not a fixed fine. But the "up to 4-6 times the illicit benefit" nuance is what really bites a large company, because it scales with what it earned by deceiving. That design is deliberate: to remove the economic incentive to lie to the consumer.
And the European right to repair? Directive 2024/1799
It strengthens your position from outside Spain. Directive (EU) 2024/1799 on the repair of goods is applicable in all member states, Spain included, from 31 July 2026, and it grants independent repairers the right to use compatible parts with protection against software blocks (European Commission, 2026).
Translated: it doesn't depend solely on the Spanish Congress finishing the process. European law pushes in the same direction with an exact date. An independent workshop repairing your machine will have coverage to use non-original parts without the manufacturer blocking it on the sly. It's the same principle applied to printing: your consumable, your decision.
For our part, we don't sell this law as a magic wand, because it isn't one. What we do notice, every time a manufacturer releases a firmware version that breaks compatibility, is a wave of the same queries in a block: full cartridges, block messages, angry people. We print and test our compatibles before selling them, and we update the chips when the current firmware changes. The rule proves us right on something we already saw every day: the problem is almost never the cartridge.
When does it take effect and why is it called a draft bill?
It's called that because that's what it is: a draft bill approved by the Council of Ministers at first reading, not a law passed by the Cortes. After the public consultation it will go back to the Council of Ministers and then through the parliamentary process in the Congress (Noticias Jurídicas, 2025).
The expected entry into force is between July and September 2026, with no exact date settled. Honesty is in order: anyone telling you today that "blocking cartridges is already banned" is ahead of reality. What is already in force are the TRLGDCU, Directive 2005/29/EC and the Italian precedent, which is what you lean on while the new law completes its journey.
Protect yourself now: reliable compatibles with an updated chip
You don't have to wait until July 2026 to stop overpaying. While the law completes its process, the practical route that already works is buying reliable compatibles with an updated chip —2024 revision or later— that get past the current firmware and avoid the block message. A serious seller tells you whether the chip is up to date and replaces the cartridge if your printer cripples it.
And if you also want to see with your own eyes that a compatible performs just as well, look at how we print it side by side against the original, and if your machine is already giving you grief, start with what to do when it doesn't recognize the compatible toner.
In our laser toner collection you have compatible cartridges from every brand with an updated chip, tested by us and with replacement if the firmware causes problems. The law is starting to take your side; we already had.
Frequently asked questions
Is the Sustainable Consumption Law already in force?
No. The draft bill was approved in the Council of Ministers on 1 July 2025, but it still has to pass public consultation and the parliamentary process. Its expected entry into force is between July and September 2026 (The Conversation, 2026). Until then you lean on the current TRLGDCU.
Does the law ban HP's firmware that blocks cartridges?
Not directly. It bans hiding that an update will degrade the machine, falsely claiming a non-original cartridge will damage it, and penalizing non-original parts as planned obsolescence (elDiario.es, 2025). It's a strengthening of transparency, not a ban on the system.
What evidence do I keep to claim over a block?
Three things: the printer invoice, the firmware version prior to the update and a photo of the block message. With that you can cite the TRLGDCU (arts. 116/117/120), Directive 2005/29/EC and AGCM Resolution 28522/2020, the precedent that fined HP €10M (AGCM, 2020).
Do I use a compatible cartridge and lose the printer's warranty?
No. The warranty cannot be conditioned on the exclusive use of the manufacturer's consumable except for demonstrable damage (art. 117 TRLGDCU and EU Directive 2019/771). The legal warranty is 3 years, extendable to 4 if you repair instead of replace. More detail in our legal warranty guide.
How much can the law fine for unfair practices?
Minor infringements range from €150 to €10,000 and serious ones from €10,001 to €100,000, or up to 4-6 times the illicit benefit obtained (Vida Sana, 2025). The €100,000 is the ceiling for serious ones, not a fixed fine; the multiple of the benefit is what scales with large companies.
Sources
- EL PAÍS — This is the sustainable consumption law: a veto on gasoline ads, a crackdown on greenwashing and the end of fear advertising — https://elpais.com/clima-y-medio-ambiente/2025-07-01/asi-es-la-ley-de-consumo-sostenible-veto-a-los-anuncios-de-gasolina-cerco-al-ecopostureo-y-fin-de-la-publicidad-del-miedo.html
- elDiario.es — Consumer Affairs prepares measures against planned obsolescence, such as unnecessary updates — https://www.eldiario.es/tecnologia/consumo-prepara-bateria-medidas-obsolescencia-programada-ecopostureo_1_12409326.html
- Noticias Jurídicas — The draft Sustainable Consumption Law approved: planned obsolescence, greenwashing and shrinkflation — https://noticias.juridicas.com/actualidad/noticias/20391-aprobado-el-anteproyecto-de-ley-de-consumo-sostenible:-adios-a-los-anuncios-de-gasolina-y-a-la-reventa-de-entradas-inflada/
- The Conversation (University of Castilla-La Mancha) — The new draft Sustainable Consumption Law requires repairing certain products beyond the warranty period — https://theconversation.com/el-nuevo-anteproyecto-de-ley-de-consumo-sostenible-obliga-a-reparar-ciertos-productos-mas-alla-del-periodo-de-garantia-269738
- Vida Sana (EFEverde) — Sustainable Consumption Law: €100,000 fine for greenwashing — https://vidasana.org/ley-de-consumo-sostenible-100-mil-euros-de-multa-para-el-ecopostureo/
- AGCM (Autorità Garante della Concorrenza e del Mercato) — ICA: HP fined 10 million Euros for misleading and aggressive commercial practices (PS11144) — https://en.agcm.it/en/media/press-releases/2020/12/PS11144
- The Register — HP settles printer toner lockout lawsuit with a promise to make firmware updates optional — https://www.theregister.com/2025/03/19/hp_printer_lawsuit_settled/
- European Commission — Directive on repair of goods (EU Directive 2024/1799, applicable from 31/07/2026) — https://commission.europa.eu/law/law-topic/consumer-protection-law/directive-repair-goods_en
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