Spare parts, repair services and right to repair

• Directive (EU) 2024/1799 — common rules promoting repair
• Regulation (EU) 2023/988 — GPSR
• Ecodesign regulations with spare part obligations
• Directive (EU) 2019/771 — sale of goods

Who has to appoint one

Manufacturers and sellers of spare parts and repair services for the EU market. Ecodesign rules impose spare part availability and delivery time obligations on manufacturers for a growing list of product groups, and the repair Directive adds a duty to repair for certain goods.

Thresholds and exemptions

Obligations attach per product group under the ecodesign rules, with availability periods ranging from seven to ten years depending on the category.

What must appear on the label

Parts must be identifiable and their compatibility stated. Manufacturer and responsible person details apply as for any product placed on the market.

Marketplace fields

Independent repairers and consumers can require access to parts and to repair information under the ecodesign rules, and refusing access is an infringement rather than a commercial choice.

Documentation you must hold

Spare part availability commitments and evidence of delivery times, repair information made available to professional repairers under the applicable regulation, technical documentation for the parts themselves, and the European Repair Information Form under the repair Directive where it applies.

Standards and testing

Parts must meet the same requirements as when supplied with the original product, which for safety-relevant components means the same testing.

Language requirements

Repair and installation information in the language of the member states where the parts are supplied.

When it applies

Availability periods run from the last unit of the model placed on the market. The repair Directive is being transposed with application from mid-2026.

How long records are kept

Ten years for documentation, and the availability period for the parts themselves.

What happens if you do not comply

Enforcement under the ecodesign rules, consumer claims under the sale of goods Directive where repair is refused, and reputational exposure in a policy area under active political attention.

Who enforces it

Market surveillance authorities, energy agencies for ecodesign, and consumer protection authorities.

Where the boundary lies

Software locks that prevent a genuine part from functioning after replacement are increasingly treated as an obstacle to repair, and the repair Directive prohibits contractual and hardware or software techniques that impede repair with second-hand or third-party parts.

Questions we are asked

Must we supply spare parts to independent repairers?

For the product groups covered by ecodesign rules, yes, with defined availability periods and delivery times, and not only to authorised networks.

Can we pair parts to the device in software?

Techniques that prevent the use of legitimate parts are restricted under the repair Directive, and the practice is under active scrutiny.