Today's Repair Duty Covers Devices You Already Sold

Two commencement rules landed on the same date

A compliance lead at a European display manufacturer spent the spring preparing one slide. From 31 July, a buyer who chooses repair over replacement gets an extra twelve months of legal guarantee. It was a clean, bounded change: it applied to contracts signed from that date, finance could model it as a warranty accrual, and nothing already in the field was touched.

That slide describes half of Directive 2024/1799, and it is the half that behaves the way people expect a new rule to behave. The other half does not attach to a sale at all. The manufacturer repair obligation attaches to the product. Manufacturers of the goods listed in Annex II must repair them at a consumer's request within a reasonable time and for a reasonable price, must supply spare parts and tools at prices that do not discourage repair, and may not use contract terms or technical measures to obstruct repair. Nothing in that construction asks when the item was sold.

Germany's implementing bill, published by the Federal Ministry of Justice and Consumer Protection with a consultation that closed on 13 February 2026, states the split without ornament: the new sales-law provisions apply to contracts concluded from 31 July 2026 onward, while the manufacturer repair obligations apply from entry into force regardless of when the product was bought. The guarantee limb grows one transaction at a time. The repair limb arrives whole.

What is actually on the list

Annex II is short, and it is not the list most coverage describes. It draws on goods that already carry repairability requirements under EU law: washing machines and washer-dryers, dishwashers, refrigerators, electronic displays, welding equipment, servers and data storage products, mobile phones, cordless phones and tablets, tumble dryers, local space heaters, and batteries for e-bikes and e-scooters from 18 February 2027.

The duty runs to consumers, which is why servers and data storage sit on that list without changing much for a rack in a colocation hall. Displays, phones and tablets are a different matter. They are sold to consumers in volume, they already carry ecodesign repairability rules, and their installed base in any single member state is measured in millions of units that were never modelled as a service liability.

The obligation is not merely to accept a repair. A manufacturer must publish indicative prices for typical repairs on a freely accessible website, and a repairer who issues a European Repair Information Form is bound by the conditions in it for 30 days. A quotation stops being a conversation and becomes a document with a shelf life, which is the point at which repair pricing becomes comparable across a market for the first time.

A member state that is late is a member state that is larger

By 30 July, according to Right to Repair Europe, only a handful of the twenty-seven had formally notified the Commission that transposition was complete. Several more had published draft legislation or were well advanced. Many were neither.

Lateness does not shrink the obligation. It postpones the moment it lands and enlarges what it lands on. Because the repair duty attaches to products rather than to contracts, every unit a manufacturer ships into a slow member state between today and that state's commencement date joins the population the duty will eventually cover. A market that switches the rule on in March 2027 has not granted its manufacturers eight quiet months. It has added eight months of installed base to a liability that then arrives in one step.

So a manufacturer selling across the union now holds one obligation with twenty-seven start dates and no corresponding variation in scope. Planning to the earliest date is the only version of this that does not require a separate spare-parts forecast per country, and it is cheaper than it looks, because the parts inventory a late market will demand in 2027 is the same inventory an early market demands today.

The infrastructure arrives seventeen months after the duty

The directive also builds a discovery mechanism. A European online platform for repair, extending the Your Europe portal, will let consumers find registered repairers, with the Commission running the IT and member states running registration. The interface is due on 31 July 2027 and the platform becomes operational in January 2028. Member states have until 31 July 2029 to put their own repair-promotion measures in place.

The duty is live today and the machinery meant to route demand into it is seventeen months out. That gap decides first-year volume more than the legal text does. Until the platform exists, the number of repair requests a manufacturer receives is set by whoever tells consumers the right exists, which in practice means national consumer bodies, retailers competing on after-sales, and independent repairers with an obvious commercial interest in publicising it.

Planning for a quiet first year is therefore a bet on nobody advertising, and the people best placed to advertise are the ones who profit from the traffic. The more defensible assumption is a slow first twelve months followed by a step change in early 2028, and a spare-parts commitment sized for the second period rather than the first.

Publish a price before someone else sets yours

The word this directive leans on hardest is reasonable, and it defines it nowhere. Right to Repair Europe has made exactly that criticism of the spare parts and tools provisions, and said it will monitor implementation on that basis. A price that does not discourage repair is a standard that will be filled in by enforcement and litigation rather than by the text.

The requirement to publish indicative prices for typical repairs is where that gets decided in public. The first credible price tables in a category become the reference point everyone else is measured against. When a national authority has to judge whether a screen replacement at 189 euro discourages repair, it will look at what comparable manufacturers publish, and the tables that exist first are the tables it will look at.

For a British manufacturer the asymmetry is sharper still. The United Kingdom sits outside this directive and has no equivalent manufacturer repair duty, so a company in Sheffield selling displays domestically at 165 pounds carries no such obligation at home and carries the full obligation the moment the same unit ships to Dublin or Rotterdam. The compliance boundary is the shipping address, not the head office.

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