The Right to Repair Directive

What the right to repair directive does

The Right to Repair Directive (EU) 2024/1799 is designed to make repair a realistic alternative to replacement for consumer goods. It gives consumers a right to repair against manufacturers for certain product groups, even after the legal guarantee has expired, regulates information about repair services, prohibits techniques that obstruct independent repair and changes the remedies available against sellers when goods are defective.

Member States had to apply the new rules from 31 July 2026. Germany transposed the directive through the Act to Implement Directive (EU) 2024/1799 on Promoting the Repair of Goods, adopted by the Bundestag on 25 June 2026, which inserted a new set of provisions into the German Civil Code (BGB) starting at § 479a BGB.

For manufacturers, importers, distributors and retailers of household appliances, electronics and other covered products, the right to repair creates new obligations in two directions. Manufacturers must offer repair to consumers for products covered by EU ecodesign repairability requirements and must not hinder independent repairers. Sellers face changes to warranty law that favour repair over replacement. Both sides need new processes, pricing, information and supply chains for spare parts.

The manufacturer's obligation to repair

The core of the right to repair is the manufacturer's obligation to repair goods in the product groups listed in Annex II of the directive. Annex II refers to EU acts that set repairability requirements, currently household washing machines and washer-dryers, dishwashers, refrigerating appliances, electronic displays, welding equipment, vacuum cleaners, servers and data storage products, mobile phones, cordless phones and slate tablets, household tumble dryers and goods incorporating batteries for light means of transport, such as e-bikes. The Commission can add product groups as new repairability requirements are adopted under the Ecodesign Regulation.

In German law, § 479b BGB obliges the manufacturer of such goods to repair them at the consumer's request within a reasonable period once it has the goods or access to them, restoring them to a condition in which they fulfil their intended purpose. The duty lasts as long as, and to the extent that, the manufacturer must ensure repairability, including availability of spare parts, under the EU acts listed in Annex II, which in many cases means for several years after the last unit of a model is placed on the market.

The obligation does not exist where repair is factually or legally impossible, and the manufacturer may not refuse repair merely because the product was previously repaired by someone else. Repair outside the legal guarantee can be offered for a price; the directive requires repair free of charge or for a reasonable price.

Spare parts, information and the ban on obstruction

A right to repair is only effective if independent repairers can work on products. Section 479c BGB therefore requires manufacturers to offer spare parts and repair-related tools at a reasonable price that does not discourage repair. Section 479d BGB requires them to provide information about their repair services free of charge in an easily accessible, clear and understandable way, and to publish indicative prices for typical repairs on a freely accessible website. Consumers can use the voluntary European Repair Information Form, introduced by the directive, to compare offers from repairers.

The most consequential provision for product design is § 479e BGB. Manufacturers may not use hardware or software techniques that impede the repair of covered goods unless justified by legitimate and objective factors, such as the protection of intellectual property rights. In particular, they may not prevent the use of original, second-hand, compatible or 3D-printed spare parts by independent repairers, or block repair by consumers, where those parts comply with EU and national law. Practices such as parts pairing that disables functions when third-party components are installed must therefore be reviewed carefully and justified where retained.

Changes to warranty law for sellers

The right to repair also amends the Sale of Goods Directive (EU) 2019/771. Where goods are defective, consumers can still choose between repair and replacement, but the directive encourages repair: if the consumer chooses repair, the seller's liability period is extended once by twelve months. Germany implemented this through § 475e(5) BGB, under which the original limitation period for claims based on a defect is extended once by twelve months if supplementary performance is provided by repair. The amendment applies to sales contracts concluded after 31 July 2026.

The rule creates an incentive for consumers to opt for repair and a cost for sellers, who carry the risk of further defects for longer. Sellers should adapt warranty documentation, after-sales communication and internal systems that track limitation periods.

Sellers should also check their recourse against suppliers: § 445a BGB allows sellers of new goods to recover certain costs of supplementary performance from their own suppliers, and supply contracts should be reviewed for how extended limitation periods flow up the chain. Where consumers request repair under the manufacturer's obligation rather than the seller's warranty, the two regimes run side by side, and clear communication avoids confusion over which party is responsible.

Repair platforms and consumer information

The directive also requires a European online platform for repair, with national sections, to help consumers find repairers, refurbishers and sellers of refurbished goods. Member States could designate national platforms and had to inform the Commission by 31 July 2026. Participation is voluntary for repairers but offers visibility. In addition, Member States must take at least one measure to promote repair, such as repair vouchers, funds or tax incentives. Whether and how such incentives develop in Germany will influence demand for repair services.

For manufacturers, the duty to inform consumers about repair options connects with obligations under ecodesign law, such as the repairability information already required for smartphones and tablets, and with the future digital product passport. Consistency across product information, repair offers and marketing claims matters, because statements about durability and repairability are subject to the rules against misleading environmental claims.

Business models, service networks and contracts

The right to repair is not only a compliance topic; it changes after-sales economics. Manufacturers that previously offered repair mainly within the warranty period must now organise paid repair for the full repairability period, which can extend well beyond the life of a product line. Many will rely on authorised service partners. Section 479b BGB allows the obligation to be fulfilled through others, but the manufacturer remains responsible to the consumer. Service agreements should therefore define response times, pricing frameworks that remain "reasonable", quality standards, data protection for customer devices and the handling of complaints.

Spare parts logistics also need attention. Ecodesign rules already require certain parts to be available for defined periods, and the new requirement to offer parts at a reasonable price applies to sales to independent repairers and, where relevant, consumers. Distribution agreements that reserve spare parts to authorised networks should be reviewed against both the right to repair and competition law.

Refurbishers and repair businesses, for their part, gain new rights to obtain parts and information, and may wish to position themselves on the European repair platform. For retailers, offering repair services alongside sales can become a way to retain customers, provided responsibilities between seller warranty, manufacturer repair and third-party service are explained clearly.

Enforcement and liability risk

Consumers can enforce the manufacturer's repair obligation directly as a civil-law claim. Consumer associations and competitors can bring injunction claims where manufacturers use prohibited obstruction techniques or fail to provide required information, under the Injunctions Act and the Act against Unfair Competition. Repeated or widespread breaches are also likely to attract coordinated action by consumer protection authorities. For non-EU manufacturers, the German provisions extend the repair obligation to authorised representatives, importers or distributors in a cascade, so EU-based operators should review their exposure and their contractual recourse.

The right to repair also interacts with intellectual property and competition law. Manufacturers may invoke IP rights to justify certain restrictions, but design rights in visible spare parts have already been limited by the EU design reform's repair clause, and refusals to supply parts can raise antitrust issues where a manufacturer holds market power. A coherent after-sales strategy considers these regimes together.

Preparing for the right to repair

1. Identify products in Annex II product groups and the repairability periods under the applicable ecodesign acts.
2. Set up a repair offer, including in-house or contracted repair networks, pricing and turnaround times.
3. Publish repair information and indicative prices and prepare the optional European Repair Information Form.
4. Review spare parts pricing, availability and distribution to independent repairers.
5. Audit hardware and software features for obstruction of repair and document justifications.
6. Update warranty processes and limitation tracking for the twelve-month extension, and supply contracts for recourse.

Illustration: a manufacturer of washing machines based in Germany receives a request to repair a five-year-old machine whose warranty expired long ago. Because washing machines are in Annex II and spare parts must be available for many years under the ecodesign regulation, the manufacturer must offer repair within a reasonable period, at a reasonable price, and may not refuse because a local repair shop worked on the machine before. It may charge for the repair, but the price must be reasonable, and it must have published indicative prices for typical repairs of that model on its website. If the consumer instead buys a new machine and later chooses repair under the seller's warranty, the seller's limitation period is extended by twelve months.

How TRW & Co helps

We advise manufacturers, importers, retailers and repair businesses on the right to repair in Germany. We analyse which products are covered, design repair offers and terms, review software and parts policies against the anti-obstruction rule, update warranty and limitation processes and draft supply and service agreements that allocate costs along the chain. We combine this with advice on the Ecodesign Regulation, the EU design reform and product compliance, and work closely with our retail and consumer goods sector team. Please contact us to review your after-sales model. This briefing is general information and not legal advice.