OPINION
4 Spare parts, tools, and technical access Check the availability and cost of spare parts, tools, repair information, and any software or diagnostic access needed to complete repairs.
5 Contracts and cost allocation Review supplier and distribution agreements to establish who pays for repairs, who supplies parts and technical information, who manages consumer requests, and who appoints repair contractors.
6 Consumer information Businesses with the repair obligation must provide free, clear and easily accessible information about their repair services for at least the duration of the obligation. They must also make indicative prices for typical repairs available through a free-access website. For importers and distributors,
the key point is that commercial arrangements and legal responsibility are not necessarily the same thing. Supplier agreements can determine how costs and responsibilities are allocated between businesses, but they do not automatically change which party is responsible for fulfilling the statutory repair obligation. For businesses already managing changes to import costs and supply-chain arrangements, the repair rules add another layer of complexity. This comes alongside wider developments affecting the cost and availability of imported bikes, including changes in US tariff policy.
The risk goes beyond the cost of a repair The commercial risk for importers and distributors extends beyond the price of fixing an individual product. A business that unexpectedly inherits a repair obligation
may need to establish a repair network, source spare parts, negotiate new service arrangements, or absorb costs that
28 | November 2026
were previously handled elsewhere in the supply chain. There can also be disputes over contractual
responsibility, disruption to established distribution arrangements, and reputational damage if consumers cannot obtain an effective repair. For businesses in the cycle trade, these questions sit within wider discussions about accountability between manufacturers, distributors and retailers. The Association of Cycle Traders has highlighted broader challenges around the cycle supply chain, including pricing, online sales, assembly, and after-sales service. Member States must also establish penalties for infringements of the national provisions implementing Articles 4, 5, and 6 of the directive. Those penalties must be effective, proportionate, and dissuasive.
Compliance should start with the supply chain The EU’s right-to-repair rules are designed to make repair easier for consumers, but they also shift responsibilities onto the companies behind covered products. For importers and distributors,
the key question is not simply “Can this product be repaired?” It is “Who is responsible for making sure it can be repaired?” For covered products supplied
by manufacturers outside the EU, that responsibility may move from the manufacturer to an authorised representative, importer, or, if there is no importer, distributor. Businesses that map those relationships, review their contracts and repair arrangements, and ensure the necessary parts, technical support, and customer-facing information are available will be
better positioned to manage the new requirements. ● This article provides general information on the EU repair rules and is not a substitute for legal advice on a specific product or supply chain.
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