OPINION
This creates a practical risk for businesses that have
historically assumed the overseas manufacturer would handle repairs. An importer may find itself responsible for a product it did not manufacture, while a distributor may face the same obligation if there is no importer. The resulting costs could include repairs, logistics,
spare parts, service contracts, and renegotiated supplier arrangements.
Repairability is not just about having a repairer The directive goes beyond requiring businesses to arrange physical repairs. It also addresses the practical barriers that can make a product difficult or impossible to repair. Manufacturers must make required spare parts and tools
available at a reasonable price that does not deter repair. They cannot use contractual terms, hardware, or software techniques that impede repair unless there is a legitimate and objective justification, including protection of intellectual property rights. Additionally, manufacturers cannot refuse a covered repair solely because the product has previously been repaired by another person or repairer. For importers and distributors, these requirements matter because having a repairer available does not necessarily mean a product can actually be repaired. The repairer may also need access to spare parts, diagnostic tools, technical information, software, or compatible components. If those resources are controlled by an overseas
manufacturer, an importer or distributor that inherits the repair obligation may not be able to fulfil it without the manufacturer’s cooperation. Supplier agreements and technical arrangements therefore
deserve particular attention. Businesses should establish in advance how required parts, information, tools, software access, and technical support will be provided if the repair obligation falls to them.
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Right to Repair survival guide: six areas to review The new rules create several areas that importers, distributors and other businesses in the supply chain should review.
1 Product scope Identify which products are covered by Annex II and check the specific repairability requirements applying to each one.
2 Supply-chain roles Establish who is legally the manufacturer, whether that manufacturer is established in the EU, whether an authorised representative has been appointed, and who is the importer or distributor.
3 Repair arrangements Determine who will physically carry out repairs, how products will be collected and returned, what turnaround times are realistic, and whether repairs can be subcontracted.
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