Affordability of repair is a crucial aspect of a universal right to repair. The so-called Right to Repair Directive (EU 2024/1799) that EU member states need to transpose into national legislation by July 2026 begins to address this point, but still insufficiently. Meanwhile, various countries are tackling high repair costs at the national level by introducing repair funds and bonus systems to partially subsidise repair costs (see our overview of repair funds).
Repair bonuses and other financial incentives can contribute to make repair more accessible and have been widely successful after their implementation (e.g. in France and Austria), but their introduction is often hindered by a lack of public financial resources. So what if producers were required to provide funds instead?
We at Right to Repair Europe together with our members Runder Tisch Reparatur (RTR), Germanwatch and the European Environmental Bureau (EEB) discuss how Extended Producer Responsibility (EPR) could be reformed to promote repair in our recent paper summarised in this article, providing policy recommendations for the EU and national governments.
Making producers responsible to promote repair
EPR schemes across the EU already require producers to contribute to the end-of-life costs of their products, through fees paid to producer responsibility organisations (PROs) that organise collection, treatment and end-of-life management of waste generated nationally. The Waste Framework Directive (WFD) and the Directive on Waste from Electrical and Electronic Equipment (WEEE Directive) mandate EPR schemes for electronics, packaging and more. However, current EPR schemes in the EU focus heavily on waste management – recycling and recovery – and do not systematically include and promote repair and other waste prevention strategies. One way to fix this would be for fees from EPR schemes to contribute to repair bonuses, making these more stable, reliable and predictable for consumers and repair businesses.
EPR can represent a potential long-term source of funds for repair subsidies, boosting the repair economy. In France, this is already a reality. The Bonus Réparation is already entirely financed by EPR contributions paid by manufacturers through “ecomodulated” fees that take into account the repairability of products put on the market by different producers. We call for this to become the norm across Europe.
Clearly, EPR-funded repair bonuses need to be complemented by other policy measures aimed at decreasing the cost of repair and stimulating a competitive repair market. However, they do have a role to play as a parallel measure to incentivise repair and internalise negative environmental costs. To see how this works in practice, let’s have a look at the French system.
The French Bonus Réparation
Since December 2022, French consumers can benefit from a repair fund that is financed by EPR fees, which applies to repair of electric and electronic appliances, but also clothing and footwear. The system currently covers 73 products, with more to be added in the coming years. Consumers receive a discount directly upon payment in the repair shop, and repair businesses receive a reimbursement of this discount from the responsible PRO. The amount of the discount is specified for each product group, with for instance €15 being offered for the repair of an electric kettle, €25 for a phone, and €60 for a TV.
The bonuses are entirely financed by EPR contributions paid by manufacturers for each product they put on the French market, and the processing of the fees and reimbursement of the repair shops is managed by the respective PROs. Repairers need to be certified with a certain label by the state to be included in the programme – that is, to receive the discount, consumers can’t just go to any repairer, but need to check online which repair businesses are part of the scheme.
The French system doesn’t come without shortcomings, but it is being revised and improved. For instance, the discount amounts have been recently increased, and there are plans to make the governance of the scheme more inclusive. Lack of awareness and the limited number of certified repair workshops are still ongoing issues, which hopefully will be addressed in the future.
Despite the challenges, the Bonus Réparation is a great example of how EPR could be used to incentivise repair. However, exploiting the full potential of EPR for repair and waste prevention requires a wider and more holistic reform of EPR. So how can EPR be reshaped and set up to promote repair?
Transforming EPR fees and governance
EPR needs to move beyond waste management towards waste prevention. To do this, EPR in the EU needs to be reformed to include at least the following aspects:
- Set aside fees towards waste prevention, for example setting minimum shares of EPR fees nationally to be dedicated to repair and reuse (financing repair bonuses, supporting social economy actors and qualification programmes for repair skills, pilot projects…), and thereby strengthening the local repair economy and creating repair jobs;
- Establish ecomodulated EPR fees, by first requiring PROs to determine the amount of funds needed nationally and calculate the EPR fees accordingly. Secondly, since EPR fees should cover the actual environmental and societal costs (and incentivise design changes upstream) to enforce the polluter-pays principle, companies that reduce these costs by producing more repairable products should pay a lower fee. In other words, the frontrunners of design for repair and reuse should be rewarded;
- Reform the governance of EPR schemes, by mandating that PROs be managed by boards composed of all relevant stakeholders (producers, social enterprises, public authorities, waste managers, NGOs, consumer protection orgs) and not just producers. Moreover, there should be requirements for PROs to transparently provide access to data to administrative bodies on the use of their collected funds.
Policy recommendations
At the EU level, this means revising the Waste Framework Directive (WFD), the Directive on Waste from Electrical and Electronic Equipment (WEEE Directive) and other existing and future product-specific EPR legislation (e.g. for vehicles, textiles, batteries) accordingly, to systematically include repair and reuse. For instance:
- Revisit EU legislation and establish EPR fees in line with the waste hierarchy. The WFD should oblige Member States to establish mandatory EPR systems that support repair and refurbishment, instead of only providing it as an option (Art.8). Similarly, the WEEE Directive should also require EPR schemes to cover waste prevention activities such as reuse and repair, instead of only the collection, treatment, recovery and disposal (Art.12 and Art.13);
- Harmonise EPR across Member States. The WFD should establish mandatory EPR schemes in all Member States, specifying the product groups in scope (Art.8). Both the WFD and the WEEE Directive should supplement existing provisions with common guidelines for fee calculation and ecomodulation to ensure a high steering effect on producers;
- Ensure a democratic and transparent governance of EPR. The WFD should ensure that PROs are governed not only by producers but at least also social enterprises, public authorities, waste managers, NGOs and consumer protection organisations. Transparency requirements for PROs on the use of funds should also be established (Art.8).
At the national level, member states can and should already act. Although harmonisation of EPR schemes across the EU is to be pursued, the need for action is now, and member states can already establish mandatory EPR schemes with ecomodulated fees and sufficient resources earmarked for repair and reuse. In particular:
- Reform EPR nationally. Make sure mandatory EPR fees by law cover measures for repair, reuse, a reformed collection, sorting and treatment system that sorts as early as possible and checks collected devices for reuse possibilities, and awareness raising initiatives. In those EPR schemes where municipalities carry out operations, it must be legally ensured they get sufficient funds from PROs to cover all aspects mentioned above. Establish a calculation method for EPR fees that includes ecomodulation criteria which go beyond legal requirements to incentivise circular product design and business models. Lastly, establish multi-stakeholder non-profit PROs to manage EPR funds;
- Set up EPR-financed repair funds and bonuses. Ensure these receive sufficient funding to really incentivise repair vis-á-vis replacement. Repair bonuses should ensure that repair costs remain substantially lower than the price of a new product. Make participating criteria for repair businesses inclusive with low thresholds and administrative burdens. In setting up the framework conditions for repair funds, establish a multi-stakeholder entity like the Conseil National de Réparation (national repair council) in France to oversee the system. Include a wide scope of products and make sure consumers are informed about the repair bonus via communication campaigns and obligations for sellers and manufacturers to provide information at the point of sale.
Summing Up
Promoting repair through EPR is necessary, appropriate and feasible. As demonstrated and recommended, mandatory ecomodulated fees and a transparent and a more inclusive EPR governance are needed to make this happen. Reshaping EPR to promote repair has the potential to bring numerous benefits, incentivising repairability of products beyond legal requirements and making repair more attractive to consumers. As part of this, EPR-financed repair funds are a strong tool to address repair costs – one of the most crucial barriers to repair.
Clearly, such financial support must go hand in hand with other measures aimed at removing structural barriers to repair. Implementing a manufacturer-independent right to repair is necessary, including design requirements of repairability and modularity, access to spare parts for all products at reasonable prices, long-term availability of software and firmware updates, and a ban on software locks. Taxation systems should also be adapted to shift from taxing labour to taxing raw material use, envisioning tax reductions for the repair sector. Finally, access to information is key, through comprehensive repair scores for consumers and technical repair information to facilitate safe and successful repairs.
For more information, read our full discussion paper!