Feedback to the preparatory Study for the Setting of Horizontal Ecodesign Requirements on Repairability – 2nd version

Publication date: May 2026
Resource added: 31 May 2026

The Ecodesign for Sustainable Products Regulation (ESPR) and the Directive on Common Rules Promoting the Repair of Goods (Right to Repair Directive) have paved the way for so‑called horizontal requirements (i.e. applying across a wide range of products) regulating the repairability of products. 

We provided feedback on the first version of the preparatory study in December 2025. This is our feedback for the second version of the study, submitted in May 2026.

This second version represents a clear improvement on the initial draft, in particular through the clearer explanation of the three‑tier horizontality structure and the broader reach of the horizontal requirements, including on spare parts price caps and anti‑part‑pairing. We also welcome the more coherent framing of the B2B/B2C scope, the inclusion of additional product groups, the explicit recognition that there are no meaningful trade‑offs between reliability and repairability, and the removal of the market‑relevance quick‑scan criterion. 

At the same time, we identify a number of issues that still need to be addressed to ensure an ambitious and internally coherent horizontal framework, including the treatment of product scope and screening criteria, the duration and affordability of spare parts and software updates, equal access to repair resources for all repair actors, and robust verification methods for price caps and software‑based barriers to repair.

Our feedback on the Preparatory Study for the Setting of Horizontal Ecodesign Requirements on Repairability can be found on the attached document, in the table format requested by the Joint Research Center