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Repair obligations wired into the systems that must deliver them

Since 31 July 2026, covered consumer goods must be repairable on request under Directive (EU) 2024/1799. The practical work is product-specific: connect the correct parts, prices, manuals, eligibility rules, repairers, case states, and evidence without pretending one generic catalogue satisfies every ecodesign act.

Start with a scope decision, not a parts feed

Article 5 does not cover every product sold in Europe. It applies when a consumer requests repair of a good for which an Annex II act provides a repairability requirement—and only to the extent of that product-specific requirement. See the Directive and Annex II.

  1. Transaction and actor

    Confirm this is a consumer request, identify the exact manufacturer and EU responsible actor, and keep seller legal-guarantee remedies separate from the manufacturer repair route.

  2. Product classification

    Resolve the commercial model to the correct regulated product group, applicable market date, variants, and any exclusions in the product-specific act.

  3. Requirement coverage

    Map the actual part, information, tool, firmware, delivery, duration, price, and audience requirement. Do not expand one product group's rule to the whole portfolio.

  4. National execution

    Bind the EU baseline to the consumer's Member State, responsible entity, language, service terms, enforcement route, and any longer national legal-guarantee period.

Product groups currently named in Annex II

  • Washing machines and washer-dryers
  • Household dishwashers
  • Refrigerating appliances
  • Electronic displays
  • Welding equipment
  • Vacuum cleaners
  • Servers and data-storage products
  • Mobile and cordless phones; slate tablets
  • Household tumble dryers
  • Goods incorporating LMT batteries

Annex II is designed to evolve. New ESPR or other Union acts can add product groups, and the Commission must update the list by delegated act. Keep scope rules versioned rather than hard-coded into storefront logic. See the ESPR framework.

Separate binding outcomes from the software used to deliver them

A connector should faithfully operationalize the law while leaving legal judgement—especially impossibility, reasonable pricing, and justified restrictions—with accountable owners.

Binding Article 5 outcomes

  • Repair covered goods on request unless repair is impossible.
  • Perform repair free or for a reasonable price and in a reasonable time.
  • Offer available parts and tools at prices that do not deter repair.
  • Publish accessible repair-service information and indicative typical-repair prices.
  • Do not unjustifiably block compliant independent repairs or reject solely because of a previous repair.

Recommended integration controls

  • A versioned product-to-rule matrix and effective-date engine.
  • Canonical parts, supersession, compatibility, price, stock, and SLA records.
  • Public and professional-repairer views generated from one governed source.
  • A repair-case state machine with quote, logistics, outcome, and reason evidence.
  • Monitoring for stale manuals, unavailable required parts, price anomalies, and missed service clocks.

One repair control plane, several controlled projections

Avoid maintaining a consumer page, repairer portal, call-centre script, and service catalogue as unrelated copies. Normalize source data once, evaluate the applicable rule, then publish only what each audience is allowed to use.

Source systems

  • PLM and product master
  • ERP, prices and stock
  • Manuals and firmware
  • CRM and commerce
  • Repairer network

Repair control plane

  • Scope and rule registry
  • Parts compatibility graph
  • Access and entitlement
  • Repair-case workflow
  • Evidence and monitoring

Service surfaces

  • Consumer repair website
  • Professional repair portal
  • Parts ordering adapter
  • Contact-centre workspace
  • Audit and legal export

A rule-aware parts response

Illustrative API
{
  "modelId": "WM-EU-4821",
  "market": "CZ",
  "requester": "consumer",
  "evaluatedAt": "2026-09-04T09:00:00Z",
  "ruleSet": "EU-2019-2023@2021-05-01",
  "part": {
    "partId": "DOOR-SEAL-48",
    "compatibility": ["WM-EU-4821-A", "WM-EU-4821-B"],
    "availableTo": ["consumer", "professional_repairer"],
    "availabilityEnds": "2038-06-30",
    "indicativePrice": { "amount": "34.90", "currency": "EUR" },
    "orderUrl": "/parts/DOOR-SEAL-48/order",
    "repairInstruction": "/manuals/WM-EU-4821/door-seal?v=3"
  },
  "decision": {
    "status": "eligible",
    "evidenceRef": "decision_01J6R2...",
    "manualReview": false
  }
}

The example is an implementation pattern, not a prescribed EU schema. Store the exact legal version, audience, model mapping, and evidence reference behind each result so a changed rule or corrected product classification can be replayed safely.

Product rules disagree by design. Your data model must express the difference.

Annex II is an index of legal acts, not a harmonized operational table. Part audiences, availability periods, delivery limits, manual access, verification, software tools, and calculation methods must remain product-specific.

Washing machines

Regulation 2019/2023 separates parts reserved for registered professional repairers from doors, hinges, seals, locking assemblies, and plastic peripherals available to both repairers and end-users. It requires the listed parts for at least ten years after the last model unit is placed on the market and delivery within 15 working days. Ordering procedures and repair information have their own timing and audience rules.

Source: Commission Regulation 2019/2023.

Smartphones and tablets

Regulation 2023/1670 applies from 20 June 2025 and uses detailed part lists and access conditions. Critical parts must remain available for seven years after end of model sales; delivery is no later than five working days during the first five years and ten during the final two. It also addresses indicative part prices, repair information, disassembly, serialised parts, and non-discriminatory access to necessary software or firmware.

Sources: Regulation 2023/1670 and the Commission supplier guide.

Never infer compatibility from a product name

Use engineering-approved model, revision, region, serial range, and supersession relationships. A technically similar part is not automatically a compliant substitute.

Never infer access from document sensitivity alone

Public, end-user, registered-repairer, authority, and internal views need explicit legal and safety policy with recorded verification and expiry.

Never infer availability from current stock

Regulatory availability is a time-bound supply obligation. Track last-placement dates, required end dates, backorders, substitutions, lead time, and permanent exceptions separately.

A repair request is a traceable business process

The catalogue is only one dependency. A defensible service records how each request was classified, offered, fulfilled, or declined and who approved any judgement call.

  1. Identify and classify

    Capture consumer market, product identifier, serial and purchase context, defect, possession or access route, accessibility needs, and consent for diagnostic data.

  2. Choose the legal route

    Determine seller legal-guarantee remedy, manufacturer Article 5 repair, commercial warranty, paid out-of-scope service, or manual review—without silently downgrading a statutory route.

  3. Build the repair offer

    Resolve parts, repairer, logistics, diagnostic cost, repair price or calculation method, maximum price, completion estimate, temporary replacement, and ancillary services.

  4. Fulfil and evidence

    Reserve parts, dispatch or route the product, record work and firmware events, test the outcome, issue documents, update guarantee dates where applicable, and preserve decision evidence.

Inside the legal guarantee

The seller's conformity-remedy workflow remains distinct. The Directive amends the Sale of Goods Directive so choosing repair instead of replacement extends the seller's liability period once by at least 12 months; Member States may provide longer periods. Store the original and extended dates and tell the consumer about the choice and effect.

Outside the legal guarantee

Article 5 gives consumers a route to the manufacturer—or the EU authorised representative, importer, then distributor when the manufacturer is outside the Union and the earlier actor is absent. The obligated actor may subcontract repair but remains responsible for delivering the legal outcome.

The information form and repair platform solve different problems

European Repair Information Form

A repairer may issue the Annex I form on a durable medium. It covers identity and contact details, the good and defect, proposed repair, price or calculation method and cap, timing, temporary replacement, handover, ancillary services, and validity. When used, the offer conditions remain unchanged for at least 30 calendar days.

Model this as a signed, immutable quote snapshot—not a live web view whose price and terms can change after issue.

European Repair Platform

The platform is a Commission-built common interface with national sections or links to qualifying national platforms. It is meant to help consumers find repairers and request the form from repairers who offer it. Registration is voluntary for repairers. It is not defined as a central manufacturer parts catalogue.

The Directive sets 31 July 2027 for the common interface; the Commission's current implementation page forecasts operation in January 2028. Keep any future adapter isolated until stable technical onboarding rules exist.

A pilot should close one real repair loop

Start with one regulated product family and one Member State. Prove model classification, consumer and professional-repairer views, parts fulfilment, case evidence, and content ownership before rolling the pattern across brands and markets.

Scope and obligation matrix

Map models, market dates, responsible actors, product acts, part and information duties, audiences, durations, delivery limits, pricing controls, and national execution owners.

Canonical repair model

Define model and serial identity, parts compatibility and supersession, manuals, firmware, price versions, inventory, repairer eligibility, case states, decisions, and evidence references.

Adapters and service surfaces

Connect PLM, ERP, document, commerce, CRM, and service tools; publish a consumer site, governed repairer access, case workspace, and focused API contracts.

Control and handover

Test wrong-model denial, expired access, backorders, price changes, missing manuals, previous-repair cases, warranty extension, impossible-repair review, exports, alerts, and operational ownership.

Pilot input

One product family, representative models and serials, EU placement dates, applicable product act, parts files, price and stock feeds, manuals, repairer rules, and sample repair cases.

Pilot output

Working scope engine, canonical data model, governed catalogue and documents, request workflow, consumer and repairer views, audit export, monitoring, and a rule-gap register.

Go-live gate

Legal owners accept the scope matrix; model and part mappings reconcile; required information is current; access tests pass; repair cases preserve reasons and timestamps; operators own every alert.

EU right-to-repair FAQ

Does the EU Right to Repair Directive require a spare-parts API?

No. Directive (EU) 2024/1799 requires outcomes such as accessible repair-service information, indicative prices for typical repairs, reasonable prices for parts and tools, and repair on request for covered goods. Product-specific ecodesign acts add detailed catalogue, ordering, manual, delivery, and access duties. Neither creates one universal API specification. An API is an implementation choice that can keep websites, repair portals, inventory, pricing, and evidence consistent.

Which products are covered by the obligation to repair?

The Article 5 obligation applies to consumer goods only where, and only to the extent that, a Union act listed in Annex II provides repairability requirements. The current list covers ten groups: washing machines and washer-dryers, dishwashers, refrigerating appliances, electronic displays, welding equipment, vacuum cleaners, servers and data-storage products, phones and slate tablets, tumble dryers, and goods incorporating light-means-of-transport batteries. The Commission must update Annex II as new qualifying acts are adopted.

Must the manufacturer always repair a covered product for free?

No. Outside the seller's legal-guarantee remedy, Article 5 says the repair must be free or offered for a reasonable price and completed within a reasonable period. Repair may be refused where it is impossible, but not purely because it is uneconomic or solely because someone else repaired the product before. The legal-guarantee route and the post-guarantee manufacturer obligation must be classified separately.

Can technical manuals be restricted to professional repairers?

Sometimes. The audience, verification procedure, permitted fee, start date, duration, and required information are product-specific. Washing-machine rules, for example, distinguish parts and information available to professional repairers from items available to end-users. Smartphone rules likewise distinguish access while requiring some public information. Build entitlement from the applicable product act rather than publishing or restricting every document alike.

Can a manufacturer require only original spare parts?

Not as a blanket policy for covered goods. Article 5 prohibits contractual, hardware, or software techniques that impede repair unless justified by legitimate and objective factors. It specifically protects the use by independent repairers of compliant original, second-hand, compatible, and 3D-printed parts, subject to product-safety and intellectual-property law and more specific product rules.

Is the European Repair Information Form mandatory?

Providing the standardized form is voluntary for repairers. If a repairer uses it, it must be supplied on a durable medium before the consumer is bound, normally free of charge, and its repair conditions cannot be changed for at least 30 calendar days. Necessary diagnostic work may be charged if the consumer is informed of that cost. The form is a useful canonical quote output even when another lawful pre-contract format is used.

Will the European Repair Platform order manufacturers' spare parts?

The Directive defines the platform primarily as a searchable directory for repairers and, where Member States choose, refurbishment actors and community initiatives. It must support repairer search and requests for the European Repair Information Form from repairers offering it. The Directive does not establish a universal manufacturer parts-ordering API. The legal deadline for the common interface is 31 July 2027; the Commission currently forecasts operation in January 2028.

Is an EU repairability score required for every covered product?

No. Repairability scoring comes from product-specific measures, not automatically from Directive (EU) 2024/1799. Smartphones and slate tablets already carry an A-to-E repairability class under their energy-labelling rules. Treat each score, label, EPREL field, and calculation method as its own versioned product rule rather than deriving a universal score from the right-to-repair workflow.

Primary sources and legal status

Reviewed 4 September 2026. Directive 2024/1799 requires Member State transposition; Member States had to apply their measures from 31 July 2026. The listed ecodesign regulations and ESPR are directly applicable within their scope. The Commission overview and supplier guide explain implementation but do not replace the legal acts. Yarify's control-plane, API, data-model, evidence, monitoring, and pilot recommendations are engineering guidance, not legal advice or a conformity assessment.

  1. Directive (EU) 2024/1799 — common rules promoting repair of goodsBinding EU directive behind the consumer repair obligation, repair-service information, reasonable parts pricing, European Repair Information Form, platform, and Annex II scope.
  2. European Commission — Directive on repair of goodsCurrent implementation overview explaining application from 31 July 2026, product scope, the extra legal-guarantee year, the optional information form, and the January 2028 platform forecast.
  3. Commission Regulation (EU) 2023/1670 — smartphones, phones and slate tabletsProduct-specific binding ecodesign rules for spare-part availability, delivery, repair information, prices, disassembly, software, firmware, and professional-repairer access.
  4. European Commission — smartphone and tablet supplier guidelinesPractical Commission guidance on the 5-to-10-working-day delivery periods, seven-year availability period, replacement conditions, and software-tool access.
  5. Commission Regulation (EU) 2019/2023 — washing machines and washer-dryersProduct-specific binding requirements covering different part lists for professional repairers and end-users, ten-year availability, ordering procedures, repair information, and delivery within 15 working days.
  6. Regulation (EU) 2024/1781 — Ecodesign for Sustainable Products RegulationBinding framework under which future product-specific ecodesign measures may add repairability, spare-parts, software-support, and Digital Product Passport requirements.

Bring one product family and one broken repair journey.

Tell us the product group, EU markets, model volume, PLM and ERP stack, parts and manual systems, repairer model, service workflow, and the gaps consumers currently hit. We'll scope a pilot that connects the applicable rule to an operational repair outcome.