Introduction: Why the EU Right to Repair Matters

The EU Right to Repair Directive is a major step in Europe’s transition from a “replace and discard” model to a more circular economy. The objective is simple: make repair easier, more transparent, and more attractive for consumers.

For companies, however, the Directive is not only a consumer-rights topic. It affects product compliance, after-sales service, spare parts availability, technical documentation, software practices, customer service processes, supplier data, and sustainability reporting.

Directive (EU) 2024/1799 introduces common EU rules that promote repair both within and outside the legal guarantee. It also creates new expectations for manufacturers, importers, distributors, sellers, and repairers operating in the EU market.

For businesses, the key message is clear: repairability is becoming a compliance requirement, not just a customer-service option.

What Is Directive (EU) 2024/1799?

Directive (EU) 2024/1799 establishes common rules promoting the repair of goods purchased by consumers. It amends existing EU consumer protection rules and introduces new obligations for repairable goods covered by EU repairability requirements.

The Directive focuses on two main situations:

1- Within the legal guarantee: encouraging consumers to choose repair instead of replacement.

2- Outside the legal guarantee: giving consumers better access to repair options for certain repairable goods.

The Directive is closely linked to the EU Green Deal, the Circular Economy Action Plan, the Ecodesign for Sustainable Products Regulation, and product-specific ecodesign requirements.

In practice, this means companies need to manage the full repair compliance chain: product design, spare parts, repair information, pricing, customer communication, and evidence.

Key Dates Companies Should Know

Who Is Affected by the EU Right to Repair Rules?

The Directive mainly affects companies involved in placing consumer goods on the EU market or providing repair services.

The Directive applies to consumer goods. The direct repair obligation does not apply to goods supplied only in a business-to-business context. However, B2B suppliers may still be asked by OEMs and brand owners to provide repairability data, spare parts information, software support, or documentation.

Which Products Are Currently in Scope?

The manufacturer repair obligation applies to goods that are subject to repairability requirements under EU law and listed in Annex II of the Directive.

The current list includes:

This list is expected to evolve as more product groups become subject to EU repairability requirements under ecodesign and sustainability legislation.

What Are Repairability Requirements?

Repairability requirements are technical requirements that make a product easier or possible to repair. They may include obligations related to:

• Availability of spare parts
• Access to repair and maintenance information
• Access to repair tools
• Software and firmware support
• Ease of disassembly
• Compatibility with commonly available tools
• Availability of updates
• Repairability scoring or consumer-facing repair information

For companies, the practical challenge is that repairability is not managed by one department. It requires coordination between product design, engineering, regulatory compliance, procurement, after-sales, legal, IT, and supplier management.

Main Obligations Under the EU Right to Repair Directive

1- Obligation to Repair Covered Goods

Manufacturers must repair covered goods when the product is subject to relevant EU repairability requirements. The repair must be carried out:

• Free of charge or for a reasonable price
• Within a reasonable period of time
• Without creating unnecessary inconvenience for the consumer
• Directly or through subcontracted repair services

The manufacturer may subcontract the repair, but the responsibility remains with the obligated economic operator.

This is important for companies without an internal repair network. They may need to build agreements with authorised repair partners, local repairers, service centres, or logistics providers.

2- Obligation for Non-EU Manufacturers

If the manufacturer is established outside the EU, the repair obligation may shift to the EU authorised representative. If there is no authorised representative, the obligation may shift to the importer. If there is no importer, the distributor may become responsible.

This creates a practical compliance issue for global supply chains. Companies importing covered products into the EU should review whether contracts clearly allocate repair responsibilities, technical support, spare parts access, and consumer communication duties.

3- Reasonable Price for Repair and Spare Parts

The Directive does not set a fixed price formula. Instead, it requires that repair and spare parts pricing should not discourage consumers from using the repair option.

A practical pricing approach should consider:

• Labour costs
• Spare parts costs
• Transport or logistics costs
• Diagnostic costs
• Product value
• Market repair prices
• Consumer expectations
• Reasonable service margins

Companies should document how prices are calculated. A clear pricing methodology can help demonstrate that repair pricing is not intentionally prohibitive.

4- Information on Repair Services

Manufacturers and, where applicable, authorised representatives, importers, or distributors must make information about their repair services available in an easily accessible, clear, and comprehensible manner.

This information should be available free of charge and remain accessible for the duration of the repair obligation.

Practical website content should include:

• Product categories covered
• Models covered
• Repair request process
• Typical repair services
• Indicative prices for typical repairs
• Contact details
• Repair time expectations
• Spare parts information where applicable
• Whether repair is performed directly or through subcontractors

5- No Unjustified Barriers to Repair

The Directive restricts practices that prevent or discourage repair. Manufacturers should not use contractual clauses, hardware restrictions, or software techniques that impede repair unless justified by legitimate and objective factors.

Companies should review whether they use:

• Software locks
• Parts pairing
• Serialisation controls
• Contractual restrictions on independent repair
• Warranty language that discourages third-party repair
• Technical barriers preventing compatible spare parts
• Policies that reject repair because a previous repair was performed by another repairer

Any restriction should be carefully reviewed and justified, especially where product safety, cybersecurity, intellectual property, or regulatory requirements are involved.

6- European Repair Information Form

The European Repair Information Form is designed to give consumers clear and comparable repair information. Repairers may provide it on a durable medium before the consumer is bound by a repair contract.

The form should include key details such as:

If a repairer provides the form, the repair conditions should not be changed for at least 30 calendar days. If the consumer accepts the conditions within the validity period, the repairer must perform the repair under those conditions.

7- Legal Guarantee Extension After Repair

The Directive amends the Sale of Goods Directive by giving consumers an additional 12-month extension of the legal guarantee when they choose repair as the remedy for a defective product.

This change is especially relevant for sellers and customer service teams.

Sellers must inform consumers about:

• Their right to choose between repair and replacement
• The possible legal guarantee extension when they choose repair
• The conditions under which repair or replacement may be refused if impossible or disproportionately costly

Companies selling consumer goods in the EU should update customer service scripts, warranty policies, online return flows, and training materials before national implementation deadlines.

8- European Online Repair Platform

A European online repair platform will be established to help consumers find repairers. It will include national sections or links to national platforms.

The platform is expected to allow consumers to search by:

• Product category
• Location
• Repair service availability
• Repair conditions
• Repair time
• Availability of temporary replacement goods
• Ancillary services such as transport, removal, or installation
• Repair quality standards
• Refurbished goods or community repair initiatives where applicable

Consumers will be able to use the platform free of charge. Registration by repairers will be voluntary, but companies providing repair services may benefit from visibility on the platform.

Practical Compliance Guidelines for Businesses

Step 1: Map Your Product Portfolio

Start by identifying which products may fall within the scope of the Directive.

Create a product-scope matrix covering:

• Product category
• Model or product family
• EU market status
• Manufacturer location
• EU authorised representative
• Importer
• Distributor
• Applicable ecodesign or repairability requirements
• Spare parts availability period
• Repair information requirements
• Software or firmware dependencies

This matrix should be reviewed regularly because the scope of Annex II will evolve as new EU repairability requirements are adopted.

Step 2: Identify Your Economic Operator Role

Your obligations depend on your role in the supply chain.

Ask the following questions:

• Are we the manufacturer?
• Are we placing non-EU manufactured goods on the EU market?
• Are we the authorised representative?
• Are we the importer?
• Are we a distributor or seller?
• Do we provide repair services?
• Do we subcontract repair services?
• Do we sell refurbished goods?

A company may have more than one role. For example, a business may act as importer for one product line, distributor for another, and seller for direct-to-consumer e-commerce.

Step 3: Build a Repair Obligation Register

A repair obligation register helps companies track exactly what must be repaired, for how long, and under which conditions.

Include:

This register should become part of your product compliance management system.

Step 4: Review Spare Parts Strategy

Spare parts are central to repair compliance. Companies should verify whether spare parts are:

• Available for the required period
• Priced reasonably
• Traceable to the correct product model
• Stored or sourced reliably
• Accessible to relevant repairers where required
• Supported by installation information
• Compatible with product safety requirements

A weak spare parts strategy can create compliance, customer, and reputational risks. It can also undermine repair performance even if the company has repair policies on paper.

Step 5: Review Software and Firmware Controls

For connected products, repair is often linked to software. Companies should identify any software, firmware, diagnostic, calibration, or authentication process that may affect repair.

Review whether your business uses:

• Parts pairing
• Serialised components
• Digital locks
• Firmware-based restrictions
• Proprietary diagnostic tools
• Cloud-based activation
• Software update limitations
• Repair-related cybersecurity controls

Where restrictions exist, document the reason. The justification should be objective, legitimate, and proportionate. Product safety, cybersecurity, data protection, and intellectual property may be relevant, but they should not become blanket reasons to block lawful repair.

Step 6: Prepare Consumer-Facing Repair Information

Companies should update websites, manuals, support portals, and customer service workflows.

Consumer-facing repair information should be:

• Easy to find
• Written in clear language
• Consistent across channels
• Available free of charge
• Accessible for the full repair obligation period
• Updated when products, prices, or service partners change

Recommended sections for a repair webpage include:

• “Products Covered by Repair Services”
• “How to Request a Repair”
• “Typical Repair Prices”
• “Spare Parts Availability”
• “Repair Timeframes”
• “Temporary Replacement Options”
• “Independent Repair and Previous Repairs”
• “Contact and Support”

Step 7: Update Legal Guarantee Processes

Sellers should prepare for the 12-month legal guarantee extension where consumers choose repair.

Practical actions include:

• Update return and warranty policies
• Train customer support teams
• Add repair-choice information to customer journeys
• Update e-commerce workflows
• Record when repair is chosen instead of replacement
• Track the extended guarantee period
• Ensure complaint handling systems reflect the new rules

The most important operational point is traceability. If a consumer chooses repair, the business should be able to prove the date, product, defect, remedy chosen, repair completion, and extended guarantee period.

Step 8: Prepare the European Repair Information Form Workflow

Even where use of the form is voluntary, it can become a practical trust and compliance tool.

Businesses should prepare a standard workflow covering:

• Who completes the form
• Whether diagnostic costs apply
• How price estimates are calculated
• How maximum prices are defined
• How validity periods are tracked
• How forms are stored
• How consumer acceptance is recorded
• How repair completion is documented

Using a structured process can reduce disputes and improve consumer confidence.

Step 9: Prepare for the European Online Repair Platform

Repairers and companies providing repair services should prepare data that may be needed for platform registration.

Useful data may include:

• Company name
• Repair locations
• Contact details
• Product categories repaired
• Service areas
• Cross-border repair availability
• Repair conditions
• Temporary replacement availability
• Ancillary services
• Quality standards followed
• Refurbished goods services, where applicable

Being visible on the platform may become commercially valuable, especially for businesses that want to position themselves as repair-friendly and sustainability-focused.

Step 10: Document Evidence for Audit Readiness

The Directive creates obligations that may be enforced through national laws and penalties. Companies should therefore maintain evidence showing how they comply.

Recommended evidence includes:

• Product scope assessments
• Applicable repairability requirements
• Spare parts availability records
• Repair price methodology
• Repair service contracts
• Subcontractor agreements
• Consumer information screenshots
• Repair request records
• Repair completion records
• Customer communication templates
• Training materials
• Software restriction assessments
• Legal guarantee extension records

A defensible compliance file should answer one question: can the company prove that repair was available, reasonable, transparent, and not unfairly restricted?

Common Compliance Risks to Avoid

Risk 1: Treating Right to Repair as Only a Legal Issue

The Directive affects product design, spare parts, after-sales service, websites, pricing, data management, and customer communication. Legal review is important, but operational implementation is essential.

Risk 2: No Clear Product Scope Mapping

If a company does not know which products are covered by Annex II or product-specific repairability rules, it cannot manage obligations effectively.

Risk 3: Unclear Spare Parts Availability

Repair cannot work without spare parts. Companies should avoid relying on informal or undocumented spare parts processes.

Risk 4: Repair Prices That Look Prohibitive

Even if a repair price is commercially understandable, it may create risk if it appears to discourage repair. Pricing should be transparent and supported by a clear methodology.

Risk 5: Website Information Is Missing or Too Technical

Consumer repair information should be accessible and understandable. Technical documentation alone is not enough.

Risk 6: Software Blocks Repair Without Justification

Software restrictions should be reviewed carefully. A repair-blocking practice may create legal and reputational risk if it is not justified by objective reasons.

Risk 7: Customer Service Teams Are Not Trained

If customer support teams do not explain repair rights and legal guarantee extensions correctly, the company may face consumer complaints and enforcement exposure.

Implementation Roadmap for Companies

KPIs to Monitor Right to Repair Compliance

Companies should measure repair performance, not only policy existence.

Useful KPIs include:

•        Number of repair requests received

•        Percentage of requests accepted

•        Percentage of repairs completed successfully

•        Average repair time

•        Average repair cost by product category

•        Spare parts availability rate

•        Number of cases where repair was refused as impossible

•        Number of complaints related to repair

•        Number of repairs handled by subcontractors

•        Number of consumers choosing repair within the legal guarantee

•        Number of legal guarantee extensions triggered

•        Website repair information update frequency

These KPIs help compliance teams demonstrate progress and identify operational weaknesses.

What This Means for Product Compliance and Sustainability Teams

The Right to Repair Directive is part of a broader EU regulatory shift. Product compliance is moving from market-entry checks toward full lifecycle compliance.

Companies should connect right to repair work with:

• Ecodesign for Sustainable Products Regulation readiness
• Digital Product Passport data models
• Product lifecycle documentation
• Spare parts and repair information
• Sustainability and ESG reporting
• Supplier declarations
• Material compliance
• Customer-facing transparency
• Circular economy claims

Repairability data will likely become increasingly important in product compliance systems. Businesses that structure this information early will be better prepared for future EU sustainability rules.

Practical Checklist: Are You Ready?

Use this checklist to assess readiness:

Frequently Asked Questions

Does the Directive apply to all products?

The Directive applies broadly to repair of consumer goods, but the manufacturer obligation to repair applies only to goods for which EU repairability requirements exist and to the extent those requirements apply.

Does the repair obligation apply only after the legal guarantee expires?

No. The manufacturer repair obligation can apply from the moment the consumer buys the product, where the consumer cannot benefit from a free repair under the legal guarantee and the product is covered by the relevant repairability requirements.

Can a manufacturer refuse to repair?

A manufacturer can refuse repair where repair is impossible. However, repair should not be refused only because it is economically inconvenient or because a previous repair was performed by another repairer or person.

Does the Directive apply to non-EU manufacturers?

Yes, where covered products are placed on the EU market. If the manufacturer is outside the EU, responsibility may fall to the authorised representative, importer, or distributor depending on the supply chain.

Is the European Repair Information Form mandatory?

The form is voluntary for repairers, but where it is provided, it creates important transparency and contractual expectations. It can also help consumers compare repair offers.

What should companies do first?

The first step is a product and role mapping exercise. Companies should identify covered products, applicable repairability requirements, EU economic operator roles, and existing repair service gaps.

How ComplyMarket Can Support Right to Repair Readiness

ComplyMarket helps companies move from regulatory uncertainty to structured compliance action.

For the EU Right to Repair Directive, ComplyMarket can support businesses by helping them:

• Map product compliance obligations across affected product categories
• Connect right to repair requirements with ecodesign, product compliance, material compliance, and sustainability workflows
• Collect and manage supplier data related to spare parts, repairability, materials, and technical evidence
• Structure documentation for repair obligations, product compliance files, and audit readiness
• Monitor regulatory requirements affecting products placed on the EU market
• Support Digital Product Passport readiness where product lifecycle, repairability, and sustainability data must be organised
• Improve traceability across product, component, material, supplier, and evidence records
• Centralise compliance data in a structured platform instead of relying on fragmented spreadsheets and emails

Right to repair compliance is not only about fixing products. It is about proving that a company understands its obligations, manages product data, enables transparent repair, and supports the circular economy.

With ComplyMarket, companies can build a more reliable compliance operating model for product sustainability, repairability, supplier evidence, and EU market readiness.