The EU Right to Repair Directive: What UK Manufacturers and Supply Chains Need to Know

In June 2024, the EU adopted its groundbreaking Right to Repair Directive ((EU) 2024/1799), designed to empower consumers, extend product lifespans, and reduce e-waste. These pioneering common rules promoting the repair of goods will require manufacturers and supply chains to change their practices significantly. While the legislation is a big step forward for sustainability and consumer rights, it brings some challenges and opportunities for businesses — particularly those operating across the EU or exporting to its markets.

What the Right to Repair Directive requires

The directive took effect on 30 July 2024. Member states have to transpose it into national rules and apply it from 31 July 2026. The rules apply to a wide range of consumer products, including household appliances, electronics, mobile phones, cordless phones and slate tablets. The list of consumer products within scope will be expanded on an annual basis. Key provisions include:

• Obligation to repair – manufacturers must offer a repair if a defect occurs or becomes apparent after the statutory warranty period has expired, unless a repair is impossible. This will apply for some products placed on the market before July 2026 (where those products are subject to other product-specific EU legislation requiring repairs when they are first placed on the market).
• Warranty terms cannot hinder repairs – manufacturers will be prohibited from using contractual clauses or hardware or software techniques that obstruct the repair of the product, unless justified by legitimate and objective factors.
• Extension of warranty if chosen to repair – provides consumers with an extra year of the statutory warranty if they choose to repair the product instead of replacing it.
• Spare parts availability – Manufacturers must ensure spare parts are accessible for consumers and third-party repairers for up to 10 years after a product’s launch.
• Repairability Scores – Products must carry ‘repairability’ ratings to help consumers make informed choices.
• Technical documentation – Repair manuals and technical information must be provided to consumers and independent repairers.
• Affordable Repairs – Spare parts and repair services must be reasonably priced to encourage repairs over replacements.

Although the UK is not obliged to bring the directive into UK laws post-Brexit, manufacturers and those supplying or distributing consumer goods in the EU market will need to comply—and similar laws may emerge in the UK in the future.

What happens to the right of repair if the manufacturer is based outside the EU?

If the manufacturer is based outside the EU, the Right to Repair Directive still applies to any products sold within the EU market. In such cases, the obligation to comply shifts to the importer, distributor, or authorised representative established within the EU. These entities become legally responsible for ensuring that the repair obligations, including spare parts availability, provision of repair manuals, and warranty extensions, are met.

This means non-EU manufacturers must collaborate closely with their EU-based partners to:

• Guarantee product compliance with EU repairability requirements.
• Provide technical documentation and spare parts.
• Align contractual responsibilities for handling repair requests.

Failing to establish clear responsibilities may result in penalties for non-compliance, legal disputes, or restrictions on market access. Therefore, manufacturers outside the EU should proactively update their supply chain agreements and designate compliant EU representatives to effectively manage their repair obligations.

How will this affect warranties?

The Right to Repair Directive directly reshapes warranty practices, with implications for manufacturers, suppliers, distributors and consumers:

• Longer warranty obligations – If a defective product is repaired, the warranty is automatically extended by 1 year. With spare parts mandated for up to 10 years (depending on the product), warranties may need to align, extending repair coverage for products beyond their typical lifespan.
• Independent repairs/parts: Manufacturers may need to revise their warranty terms to prevent coverage from being voided for repairs carried out by third parties or the use of non-proprietary parts.
• Repair-first focus: Warranties must emphasise repairs over replacements, reflecting the regulations’ sustainability goals. The seller must inform consumers of their choice between repair and replacement, and that the warranty period will be extended by one year if they opt for repair.
• Dispute management: If independent repairs result in product damage, manufacturers may face challenges in determining warranty eligibility.

Proactively updating warranty terms and policies not only ensures compliance but can also build trust and loyalty among eco-conscious consumers.

Challenges and opportunities for manufacturers and supply chains

Compliance with the Right to Repair regulations requires significant operational shifts:

• Product Ecodesign – Manufacturers must embrace modular designs, standardise components, and replace adhesives with fasteners to improve repairability.
• Inventory Management – Maintaining a decade’s worth of spare parts requires robust inventory systems and effective supplier collaboration.
• Greater supply chain collaboration – Consumers will have the right to approach any party in the supply chain to request a repair, including manufacturers, importers, distributors, authorised representatives, and their subcontractors. There will need to be greater collaboration and contract amendments to ensure clarity on who takes responsibility.
• Cost Pressures – Increased costs related to redesign, spare parts, and extended warranties will necessitate strategic reviews of pricing.
• Regulatory Complexities – Varied repairability requirements and enforcement measures across EU member states when the Directive is implemented into national laws could add layers of complexity for cross-border businesses.

Failure to comply could lead to penalties, market restrictions, reputational harm, and strained supply chain relationships. Each EU member state will implement its enforcement measures and penalties for non-compliance.

Adapting to these regulations will bring opportunities for businesses to demonstrate their commitment to sustainability and increase brand loyalty. This will require a strategic and legally sound approach.

Here’s how we can support you:

• Regulatory Guidance: interpreting the directive and tailoring advice to your industry, market, and operational model.
• Compliance Audits: evaluating product designs, warranty terms, and supply chain processes to identify and address gaps.
• Contractual Updates: drafting and/or updating supply chain agreements and customer terms to align with repairability obligations.
• Dispute Resolution: managing conflicts over warranty claims or third-party repairs to protect your interests to improve corporate reputation, and investor appeal.

The clock is ticking.

The two-year implementation period offers a window of opportunity to adapt and innovate. Manufacturers and supply chains that act now can ensure compliance, minimise disruption, and potentially emerge as leaders in sustainable business practices.

Contact us today to learn how we can support your business with these upcoming changes.