Directive (EU) 2024/1799, commonly called the Right to Repair Directive, introduces binding repair obligations for product manufacturers selling into the European Union. From 31 July 2026, the date by which all EU Member States must have transposed and applied the rules, manufacturers of certain consumer goods will be legally required to offer repairs, supply spare parts and tools at non-deterrent prices, and publish indicative repair costs on a publicly accessible website. The directive is not a soft recommendation: it creates enforceable obligations that apply even to products already in consumers’ hands before the deadline arrives. If your organisation has not yet mapped which products fall under the directive’s scope or assessed whether your authorised representative structure is adequate, now is the time to act. This article sets out the practical compliance picture for manufacturers, covering product scope, specific obligations, the chain of responsibility for non-EU manufacturers, and the changes the directive makes to EU warranty rules.
What Is Directive (EU) 2024/1799?
The Right to Repair Directive sits within the EU’s broader circular economy agenda. Its stated aim is to shift consumer and commercial behaviour away from early product replacement and toward repair. To achieve this, the directive operates on three levels. First, it creates a new direct repair obligation for manufacturers of specific product categories. Second, it amends the Sale of Goods Directive (2019/771) and the Consumer Rights Directive (2011/83/EU) to make repair a more attractive option for consumers exercising their statutory rights. Third, it establishes the legal framework for a European online repair platform that will help consumers locate repairers, though this platform is not expected to be operational until 2027.
The directive was published in the Official Journal of the European Union in 2024 and gives Member States until 31 July 2026 to adopt and apply the national measures necessary to comply. Some Member States, including Germany, have already begun the transposition process.
Which Products Are Covered by the EU Right to Repair Directive?
The current scope of the repair obligation is defined by reference to Annex II of the directive, which lists the EU legal acts whose reparability requirements trigger the obligation to repair. In practice, the product categories covered at launch include the following goods, subject to the reparability requirements already set in their respective Ecodesign implementing regulations.
The categories currently in scope are: household washing machines and washer-dryers, household dishwashers, household refrigerating appliances (including refrigerators, freezers and wine storage appliances), vacuum cleaners, electronic displays (including televisions and monitors), mobile phones, cordless phones and tablets, and servers.
An important structural point: the specific repairability requirements that manufacturers must meet, including minimum availability periods for spare parts, are set not in Directive 2024/1799 itself but in the Ecodesign implementing regulations applicable to each product category. The directive creates the repair obligation and the price and accessibility rules; the Ecodesign regulations define what spare parts must be available and for how long. For mobile phones and tablets, for example, the relevant Ecodesign regulation requires that spare parts be available for a minimum period after the last unit of a given model is placed on the market. As new Ecodesign regulations are adopted under the Ecodesign for Sustainable Products Regulation (ESPR), additional product categories will be added to Annex II over time.
What Must EU Right to Repair Manufacturers Do?
The core obligations under Article 5 of Directive 2024/1799 apply to manufacturers of goods covered by Annex II. The obligations are as follows.
The Obligation to Repair
Manufacturers must repair in-scope products within a reasonable time and for a reasonable price. The directive does not prescribe fixed turnaround times or price ceilings for every product category; these are expected to be defined at Member State level or through market practice. What the directive does prohibit is using certain defences to avoid the repair obligation: manufacturers cannot refuse to repair a product solely on the grounds that it was sold before 31 July 2026.
This retroactivity is one of the most operationally significant aspects of the directive. A consumer who bought a washing machine in 2022 will be entitled to request a manufacturer repair under the directive from 31 July 2026 onwards, provided the product is still covered by the applicable Ecodesign parts availability period. Manufacturers who have not planned for this volume of legacy repair requests may find themselves exposed.
Note: The obligation to repair can be fulfilled by the manufacturer directly or delegated to a third-party repair network, provided the manufacturer retains responsibility for compliance. Subcontracting repair activity does not transfer liability.
Spare Parts, Tools and Technical Documentation
Manufacturers must make spare parts, repair tools and technical documentation available to both consumers and independent repairers. Critically, these must be offered at a price that does not deter repair. A manufacturer who sets spare part prices so high that repair becomes economically irrational compared to replacement would be in breach of the directive’s intent, and potentially subject to enforcement action by national market surveillance authorities.
The specific parts that must be available, and for what minimum period, are governed by the Ecodesign regulations applicable to each product category. Manufacturers should review the relevant implementing regulation for each product in their portfolio and confirm that their supply chain can meet those parts availability commitments throughout the required period.
Tip: If your supply chain relies on a single third-party component supplier for a critical spare part, now is the time to assess whether that supplier can commit to a supply arrangement that covers the full regulatory period. A contractual gap here becomes a compliance gap.
Publishing Indicative Repair Prices
Manufacturers subject to the repair obligation must maintain a free-access website where consumers can find indicative prices for typical repairs of their in-scope products. The directive does not require that the published price be binding, but it must be realistic enough to allow a consumer to make a meaningful comparison.
This requirement has practical implications for manufacturers who do not currently operate a consumer-facing repair portal. A dedicated repair pricing page, linked from the product support section of the manufacturer’s website, would satisfy the requirement. The page should be accessible without registration, without payment, and without the need for any software download.
Who Bears the Obligation When the Manufacturer Is Based Outside the EU?
The directive’s repair obligation follows the same logic as other EU product legislation on economic operator responsibility, and the answer here matters greatly for manufacturers in the UK, North America and Asia. If the manufacturer is not established in the EU, the obligation to repair falls on the manufacturer’s authorised representative in the EU. This mirrors the structure that compliance managers will recognise from the General Product Safety Regulation (GPSR). The GPSR responsible person guide provides a detailed breakdown of how those economic operator chains work in practice.
If the manufacturer has no authorised representative established in the EU, the obligation passes to the importer. The importer may subcontract the actual repair work to a third party, but the importer remains liable for compliance. Distributors bear obligations only in specific circumstances set out in the directive.
The practical consequence is straightforward: any non-EU manufacturer selling into the EU market must confirm, before 31 July 2026, that their authorised representative is aware of and prepared to fulfil repair obligations. A representative who has been appointed purely to handle CE marking documentation may not be contractually or operationally equipped to manage repair requests and spare part fulfilment. Review those agreements now.
Note: Market surveillance authorities across the EU will have enforcement powers over the repair obligation from 31 July 2026. The structures established under Regulation (EU) 2019/1020 on market surveillance apply, as covered in the market surveillance and product safety article. Non-compliance can result in corrective measures, fines at national level, and restrictions on market access.
How the Right to Repair Directive Changes EU Warranty Rules
Beyond the direct repair obligation, the directive amends existing consumer law to make repair more financially attractive relative to replacement. The most significant change is a 12-month extension to the statutory warranty period when a consumer chooses repair over replacement during the minimum warranty period.
Under current EU rules, consumers benefit from a statutory guarantee of at least two years from delivery (with some Member States applying longer periods). If a defect manifests within that period and the consumer opts to have the product repaired rather than replaced or refunded, the warranty for the entire product, not only the repaired component, is extended by a minimum of 12 months from the date the repaired product is returned.
This change is designed to make repair financially attractive for consumers who might otherwise assume that repair resets only a partial or component-level guarantee. For manufacturers, it means that accepting a repair request during the warranty period carries a longer tail of statutory liability than declining one and offering a replacement.
What the Directive Does Not Require from Manufacturers (Yet)
Two topics that frequently appear in coverage of this directive are worth clarifying for compliance teams.
The EU online repair platform, which will allow consumers to search for local and online repairers and register their products for repair, is provided for under Article 7 of the directive. The Commission’s IT infrastructure for this platform is not expected to be operational until 2027. Manufacturers are not required to register on the platform by July 2026, though they should monitor the Commission’s implementation timeline.
Repairability scoring and labelling requirements, where applicable, derive from the underlying Ecodesign implementing regulations for each product category, not from Directive 2024/1799 directly. If your product category’s Ecodesign regulation requires a repairability index or label, that requirement exists independently of the Right to Repair Directive. Review the applicable Ecodesign regulation for your products separately.
Practical Steps for Directive 2024/1799 Compliance Before July 2026
The following actions represent the minimum compliance groundwork for manufacturers with products in the Annex II categories.
The first step is to confirm which of your products fall within Annex II scope and identify the Ecodesign implementing regulation that applies to each. Documenting this mapping is essential before any further action.
The second step is to audit your spare parts supply chain for each in-scope product against the parts availability period required by the applicable Ecodesign regulation. Identify any gaps, particularly for models approaching end of production.
The third step is to review your authorised representative arrangements if you are a non-EU manufacturer. Confirm that the appointed representative understands the repair obligation and has the contractual authority and operational capacity to fulfil it. If not, renegotiate or seek a specialist representative before the deadline.
The fourth step is to establish or update a consumer-facing repair pricing page on your website. This must be freely accessible and must contain indicative prices for typical repairs of your in-scope products.
The fifth step is to review your post-warranty and repair service policies to account for the retroactive application of the repair obligation and the 12-month warranty extension rule.
For manufacturers designing new products, repairability is increasingly a factor that intersects with regulatory compliance from the earliest design stages, as discussed in the article on designing for compliance to avoid costly deviations. Designing-in accessible components, standardised fasteners, and documented disassembly procedures reduces the cost of meeting spare parts and repair obligations over the product’s regulatory lifetime.
Frequently Asked Questions
Does the EU Right to Repair Directive apply to business-to-business products? The directive’s repair obligation applies to goods placed on the market for consumers. Products sold exclusively in business-to-business contexts, where the end user is not a consumer within the meaning of EU consumer law, fall outside the directive’s consumer-facing repair and warranty provisions. However, manufacturers should check whether the Ecodesign regulations applicable to their products impose independent repairability requirements that apply regardless of the sales channel.
Which products are covered by the EU Right to Repair Directive at launch? At the July 2026 application date, the directive’s repair obligation covers products whose Ecodesign implementing regulations already include reparability requirements. These include washing machines, dishwashers, refrigerating appliances, vacuum cleaners, electronic displays, mobile phones and tablets, and servers. Additional categories will be added as further Ecodesign regulations are adopted under ESPR.
Can a manufacturer charge for repairs under the Right to Repair Directive? Yes. The directive requires that repairs be offered at a reasonable price, but it does not make repairs free of charge. What it prohibits is pricing spare parts or repair services at a level that effectively deters consumers from choosing repair over replacement.
What happens if a non-EU manufacturer has no authorised representative in the EU? The obligation to repair passes to the importer. The importer may subcontract the actual repair work, but retains full legal liability for compliance. Distributors may also bear obligations in certain circumstances. Non-EU manufacturers should review their economic operator chain carefully before July 2026.
Does the 12-month warranty extension apply to all repairs? The 12-month extension applies when a consumer exercises their statutory warranty rights and chooses repair as the remedy. It extends to the whole product, not just the repaired component. Member States may choose to extend this period further in national transposition.
Conclusion
Directive (EU) 2024/1799 introduces real, enforceable obligations for manufacturers of consumer goods in its defined product categories, and the July 31, 2026 deadline is not distant. The three actions that carry the most immediate urgency are:
Confirming your Annex II product scope
ensuring your authorised representative structure is fit for the repair obligation
Establishing a publicly accessible repair pricing page before the application date.
The retroactive reach of the repair obligation, covering products already in consumers’ hands, means that the volume of potential repair requests from day one could be significant for manufacturers who have not prepared. Compliance here is not a single document exercise; it requires coordination across supply chain, legal, and after-sales service functions. Start that coordination now.
For further context on how EU product legislation assigns responsibility across the supply chain, see the Digital Product Passport implementation guide, which covers a parallel framework within the same EU circular economy legislative agenda.
