Since January 1st 2021, France is the first country in Europe to have implemented a repairability index on 5 categories of electronic devices.
While this index is a key milestone for the Right to Repair in Europe, it isn’t without limitations. From how easy it is to obtain a good grade to self-declared scores by manufacturers and no sanctions until 2022, it comes with challenges that are important to acknowledge and discuss.
We covered the French repairability index with a very popular webinar with three experts: Jean-Paul Ventere from the French Ministry of the Environment, Laeticia Vasseur from HOP and Ernestas Oldyrevas from ECOS. They explained its development and implementation, the achievements and limitations, and what it means for the right to repair in Europe. Below the video of the event you can find a summary of the key topics covered.
Index 101
What is the French repairability index?
In 2019, the French government adopted a law regulating the mandatory display of clear information for consumers on the repairability of electrical and electronic equipment.
The objective of the index is to encourage consumers to choose more repairable products, and manufacturers to improve the repairability of their products.
It applies to 5 categories of products sold in France after 1 January 2021 including:
- Smartphones
- Laptops
- Televisions
- Washing machines
- Lawnmowers
What aspects does the index assess?
The index assesses 5 criteria:
- Documentation
- Disassembly
- Availability of spare parts
- Price of spare parts
- Product-specific aspects
The first 4 criteria are the same for all products groups, the 5th criterion looks into product-specific properties. For smartphones, laptops and TVs this includes software aspects.
Each criterion is scored on 20 points and each number is then compiled into an aggregate score out of 100, which is then divided by 10 and rounded to 1 decimal digit to make the final grade.
Who calculates the score?
The manufacturer computes the index by entering all the parameters in a spreadsheet provided by the Ministry of Environment which includes the different categories and possible answers.
Sellers are obliged to display the index near the point of sale and should ask the manufacturer for the index to make it available to the consumer. The manufacturer is obliged to make the index available to anyone who requests it.
How should the index be displayed?
The index has to be displayed near the product in shops, and online next to the price of the product using the following logo, with the colour corresponding to the level of repairability in 2 point intervals.
The manufacturer is free to find additional ways of displaying the index, such as placing the index on the product package or adding a QR code with a link to more information.
Are the scores on the different criteria of the index available?
On request, manufacturers have to provide a reporting sheet in a standardised format that details the score of their product on the different sub-criteria. You can find a list of published reporting sheets at https://www.indicereparabilite.fr. Below you can see the reporting sheet of the Fairphone 3+.
While this overview provides transparency on the score on the different criteria, it does not show the individual parameters of the calculation, such as which spare part is offered to which stakeholder for how long.
What kind of repair scenario does the index evaluate?
The index considers all the relevant target groups. Points are awarded if certain documents are provided to repairers, and additional points if they are provided to consumers. Similarly, an equal amount of points are awarded if spare parts are available for in-house repairs by the manufacturer, for spare part retailers, for independent repairers and for consumers. If spare parts are only available for in-house repairs, the product will score maximum 2.5 points out of 10 on the availability of spare parts criterion.
The challenges of the index
Who verifies the index?
French market surveillance authorities (MSA) are responsible for checking whether products comply with the necessary regulations. There are concerns that MSA might not have the resources to check this extensively. Consumers, consumer protection agencies and environmental organisations could set up a collaborative effort to verify the index, but this requires resources and the parameters of the calculation are not public.
Why do not all products and websites display the index?
The decrees detailing the computation of the index were published in December of 2020. As a result, manufacturers had limited preparation time and not everyone is ready. We expect all products to have an index by the end of 2021.
How is the criterion ‘price of spare parts’ assessed?
Price of spare parts is a major barrier to repair, but it can fluctuate over time and location. In this case, the geography is restricted to France, and prices declared are the expected prices at the time of compiling the score.
The price calculation is based on 3 parameters:
- The price of the most expensive spare part – x
- The average price of the other spare parts – y
- The price of the product – z
The following ratio is computed 0.5 * (x + y) / z. The points awarded scale linearly from full points if the ratio is less than 10%, to 0 points if the ratio is 30%.
Let’s assume a product costs 1000 euro, its most expensive spare part costs 300 euro, and the average of the other parts costs 100 euro. The ratio would be 0.5* (300 + 100) / 1000 = 0.2 or 20%. The score on this criteria would then be half the available points.
What to expect next?
Will the index be extended to other product categories?
There are hopes that the index will be extended with 3 additional product categories by the end of 2021.
Isn’t reliability an important aspect of a product as well?
It is! The repairability index will be replaced by a durability index from 1 January 2024. This durability index would combine both repairability and reliability aspects. It will also be an opportunity to tweak the repairability criteria if necessary.
When can we expect an EU-wide repairability index?
The EU institutions increasingly support the right to repair and there is strong support from the European Parliament and the EU council for a repairability index. The Commission’s research service has already performed preparatory studies but since then progress has stalled.
The European Right to repair campaign will push for a EU-wide index. There are a number of opportunities in the Circular Economy Action Plan, such as the initiative to empower citizens for the green transition, the sustainable products initiative and the circular electronics initiative. If there is political will, there could be a repairability score for smartphones, tablets and computers on the energy label as soon as 2023.
Where can I find more information?
The decrees, logos and calculation sheets can be found on the following website: https://www.ecologie.gouv.fr/indice-reparabilite