Since 31 July 2026, member states have applied the rules of the EU Right to Repair directive. Germany transposed it into the Civil Code (BGB) with the act of 16 July 2026 (BGBl. 2026 I No. 212); the amended sales law applies to all purchase contracts concluded since 31 July 2026. Most of the new duties fall on manufacturers, but some also affect the seller. A repair portal can turn this into a service that keeps customers connected beyond the purchase.
What is the Right to Repair?
Directive (EU) 2024/1799 aims to extend product lifespans and reduce electronic waste. In the German Civil Code (BGB) it splits the duties between two addressees: manufacturers must repair goods of the product groups listed in Annex II at the consumer's request where no warranty rights against the seller exist, offer spare parts and tools at a reasonable price and publish indicative prices for typical repairs online (Sections 479a to 479d BGB). Sellers must point out the right to choose and the longer limitation period before carrying out a cure (Section 475(4) BGB).
Less e-waste, longer product lifespans, strengthened consumer rights, and a sustainable single market.
For consumers, this means: if they choose repair instead of replacement for a defect, the original limitation period for their warranty claims is extended once by twelve months (Section 475e(5) BGB, Art. 16 of the directive). The seller must point this out before the cure (Section 475(4) BGB).
Which Products Are Affected?
The manufacturer's repair obligation covers the product groups in Annex II of the directive – goods for which EU acts already lay down repairability requirements (Section 479a BGB):
- Mobile phones, cordless phones and slate tablets – since 20 June 2025, smartphones and tablets carry the energy label with a repairability class (EUR-Lex)
- Household washing machines and washer-dryers – spare parts for at least 10 years after the last unit of a model was placed on the market (EUR-Lex)
- Household dishwashers and refrigerating appliances – requirements from the respective ecodesign regulations
- Electronic displays – such as televisions and monitors
- Vacuum cleaners and welding equipment – each with its own ecodesign requirements
- Servers and data storage products, household tumble dryers and goods containing batteries for light means of transport
The Commission amends Annex II by delegated act when new acts with repairability requirements are added (Art. 5(9) of the directive). The longer limitation period after a repair, by contrast, applies to consumer sales regardless of the product group.
What Affects Online Retailers in Practice
Most obligations under the directive are aimed at manufacturers. For online retailers, the main points are the amended sales law and the energy label duties in distance selling. There is also a special case: if a manufacturer established outside the EU has no authorized representative in the EU and there is no importer, the manufacturer's duties fall on the distributor (Section 479f BGB). Anyone sourcing Annex II goods directly from third countries should check this.
Notice Before Cure
Before a cure, inform the consumer of the right to choose and the longer limitation period after repair (Section 475(4) BGB)
Limitation Plus Twelve Months
After a repair, the original limitation period is extended once by twelve months (Section 475e(5) BGB)
Replacement During Repair
Optional: provide replacement goods free of charge for the duration of the repair, including refurbished goods (Section 475(6) BGB)
Check Your Range
For Annex II goods without an EU representative and without an importer, the manufacturer's duties fall on the distributor (Section 479f BGB)
Energy Label in the Shop
Provide the label and product information sheet in distance selling, with the label near the product price (Regulation (EU) 2023/1669)
Repair Form
The European Repair Information Form is voluntary; the seller can also be a repairer (Art. 245 EGBGB)
The Repairability Class: A to E
Since 20 June 2025, smartphones and slate tablets have carried an EU energy label with a repairability class (EUR-Lex). The scale runs from A (most repairable) to E (least repairable) and is derived from the repairability index R. Retailers selling at a distance provide the label and the product information sheet; the label appears near the product price and may be reached via a nested display.
| Class | Repairability index R |
|---|---|
| A | R ≥ 4.00 (most repairable) |
| B | 4.00 > R ≥ 3.35 |
| C | 3.35 > R ≥ 2.55 |
| D | 2.55 > R ≥ 1.75 |
| E | 1.75 > R ≥ 1.00 (least repairable) |
Repair Portal: The Opportunity for Retailers
The new obligations are also an opportunity for differentiation. With a professional repair portal, you can build customer loyalty, generate additional revenue, and position yourself as a sustainable provider.
An in-house repair service keeps the customer relationship alive beyond the purchase. A self-service portal also reduces support inquiries.
Features of a Repair Portal
- Online Repair Request – customers report defects with photos/videos
- Automatic Diagnosis – fault trees for pre-qualification
- Cost Estimate – transparent real-time price calculation
- Spare Parts Shop – direct sale of original spare parts
- Status Tracking – live tracking of the repair
- Repair History – documentation of all service processes
This is what your repair and spare parts section could look like:
Writing Instrument Workshop
Technical Implementation: How We Integrate Your Portal
A repair portal should fit seamlessly into your existing system landscape. We connect it to common shop systems and ERP solutions.
Shop Integration
For Shopware shops, we develop a custom plugin that integrates seamlessly into the frontend. We also offer solutions for WooCommerce (WooCommerce agency) and Magento.
ERP Integration
Integration with SAP, Microsoft Dynamics or JTL-Wawi for automated workflows
RMA System
Connection to an existing RMA system or a custom development for structured returns management
Shipping Providers
Automatic label creation for DHL, DPD, UPS – customer prints and sends
Communication
Automatic emails on status changes, SMS notification optional
Spare Parts Management
An integrated spare parts shop can bring additional revenue: customers carry out simple repairs themselves and order the matching parts directly from you.
- Product Mapping – spare parts automatically displayed with main product
- Availability Check – real-time sync with warehouse and suppliers
- Compatibility Check – only matching parts are shown
- Instructions – PDF downloads or video tutorials for self-repair
EmpCo Directive: Additional Obligations for Environmental Advertising
In addition to the Right to Repair, the EmpCo Directive (EU) 2024/825 must be observed: the start of application of the national transposing measures is 27 September 2026 (EUR-Lex). It tightens rules for environmental advertising and demands even more transparency.
Statements like "climate neutral", "environmentally friendly" or "sustainable" without proof are prohibited under the EmpCo rules. More in our article on Greenwashing.
Implementation: The Steps at a Glance
- Check your range: Which goods fall under Annex II, and for which manufacturers outside the EU is there neither a representative nor an importer in the EU (Section 479f BGB)?
- Check the energy label: Integrate the label and product information sheet for smartphones and tablets near the price
- Adapt defect handling: For purchase contracts concluded since 31 July 2026, inform customers of the right to choose and the longer limitation period before a cure, and extend deadlines in your system by twelve months after a repair
- Optional: Plan and implement a repair portal to bundle service and spare parts sales
Frequently Asked Questions About Right to Repair
No. The manufacturer's repair obligation covers the product groups in Annex II of the directive, such as smartphones, washing machines, dishwashers, refrigerating appliances and displays. The Commission can extend the list by delegated act. The longer limitation period after a repair, by contrast, applies to consumer sales regardless of the product group.
Usually not. The repair obligation under Section 479b BGB lies with the manufacturer. If it is established outside the EU and there is neither an authorized representative in the EU nor an importer, the obligation passes to the distributor (Section 479f BGB). The seller remains responsible for defects in the goods sold and must point out the right to choose and the longer limitation period before a cure (Section 475(4) BGB).
Missing or incorrect notices can lead to warning letters from competitors or consumer protection associations. For the energy label, Regulation (EU) 2017/1369 requires member states to lay down penalties and enforcement mechanisms (Art. 7(4)).
The Ecodesign Regulation sets this per product category. For household washing machines and washer-dryers it is at least ten years after the last unit of a model was placed on the market, for smartphones and tablets at least seven years after they stopped being placed on the market (EUR-Lex).
It depends on your range. For retailers with electronics or tech products it can be worthwhile: besides customer loyalty, spare parts and repair services can bring additional revenue.
A basic portal with request and status tracking is usually feasible within a few weeks. With ERP integration and spare parts shop, correspondingly more time is needed. We provide a reliable schedule after the initial assessment.
Both Obligation and Opportunity
The Right to Repair is more than just another regulation – it's a paradigm shift toward sustainable consumption. For online retailers, this means short-term adaptation effort, but long-term opportunities for stronger customer loyalty and new revenue streams.
We analyze your current situation and develop a roadmap for implementation – from compliance to a full-fledged repair portal.
Whether notices in your defect handling, energy labels on your product pages or a complete repair portal with ERP integration – we support you with the implementation.
This article draws on Directives (EU) 2024/1799 and (EU) 2024/825, Regulations (EU) 2017/1369, (EU) 2019/2023, (EU) 2023/1669 and (EU) 2023/1670 (EUR-Lex) and the German act implementing Directive (EU) 2024/1799 of 16 July 2026 (BGBl. 2026 I No. 212). As of September 2026.