Today marks an important day for repair in Europe. Four types of electrical appliances will have to be made more easily repairable and longer-lasting following the entry into force of new EU Ecodesign measures.
The new measures will apply to washing machines, dishwashers, fridges and displays (including TVs) across Europe while similar rules for servers and welders came into force earlier this year.
While these new rules are an important step as the first ever regulations on repair for electronic and electrical devices, they do not mean that we have the Right to Repair in Europe. Yet. Here’s why:
1. Limited application
The regulations coming into force today only apply to new models of household appliances placed on the European market such as displays, washing machines, dishwashers and fridges, with specific rules on servers and welding equipment having taken effect earlier in the year.
Not included are devices such as smartphones and laptops, which are particularly affected by premature obsolescence and most often found to be discarded prematurely.
While these two categories of products are currently being investigated under their own Ecodesign study, it will still be years until any sort of repair requirements will be applicable to them, limiting considerably the scope of the new “Right to Repair” legislation.
2. Restricted access of some spare parts and repair manuals to professional repairers
While new Ecodesign rules might be a turning point when it comes to repair, this might benefit primarily professional repairers. The new laws will require producers to make most spare parts and repair manuals available to professional repairers only (for 7 to 10 years after retiring the product from the market, depending on product).
The regulation doesn’t guarantee access to key replacement parts and repair information to consumers as well as to non-profit and educational initiatives such as repair cafés. Our campaign is fighting for a universal Right to Repair, meaning everyone should be able to access spare parts and repair manuals for the entire lifetime of a product.
This is clearly not the case with those new rules.
““Professional repairers are finally granted the right to obtain some spare parts and repair information which is an important step towards a right to repair and must now be extended to more spare parts and additional product groups. However we are concerned that the new regulations explicitly distinguish between professional and non-professional repairers. In order to achieve the sustainability potential of repair, all consumers, volunteer repairers and professional independent repair shops should be able carry out a repair and access spare parts and information.”
Katrin Meyer, coordinator of Runder Tisch Reparatur
Moreover, the current definition of “professional repairer” remains very vague in the legislation. To qualify as such, a repairer would need to demonstrate coverage by insurance for their activity and technical expertise to repair a particular product and compliance with applicable regulations or be included in an official registration system as a professional repairer in European countries where such a system exists. As it currently stands, very few countries are working on official “repair registries” or are working to develop one, which allows manufacturers to decide who qualifies as a professional repairer or not.
Additionally, when it comes to repair information, the regulations don’t mention availability of “schematics”, which would be needed by repairers to perform component-level repairs.
Katrin Meyer adds: “Arguing with safety concerns while withholding safety information for repairs is not consistent.”
3. Long delivery time of spare parts
Everyone has already been in the situation of a broken home appliance, usually essential, that needs to be repaired or replaced as soon as possible. Speed of repair is often a deciding factor for many consumers between keeping a product or replacing it with a new one.
According to the new legislation, spare parts should be provided within 15 working days. This is extremely long for someone with a broken washing machine or fridge and could incite consumers to favour replacement over repair.
Additionally, the regulations allow manufacturers to restrict access to repair manuals, as well as spares, for the first 2 years from a product’s launch, potentially retaining an initial monopoly on repairs, irrespective of the warranty status.
4. Unaddressed software issues
Under the new regulation, manufacturers for the first time must make available the latest available firmware, software and security updates to professional repairers for the same amount of time they make available spare parts. While details differ by product category, the regulation doesn’t include any specific requirement for manufacturers to continue updating software throughout the lifetime of a product. This means that a manufacturer could comply with the regulations, while not committing to support products with software or security updates for the entire lifetime of their products. This is a worrying precedent, particularly at a time when appliances connect to the internet more and more.
5. Pricing and authorised bundling of spare parts
Unfortunately the regulation doesn’t address the pricing of spare parts, often considered as a key barrier in between a product being potentially repairable and repaired in practice.
Additionally, bundling of some spare parts will be allowed – meaning that instead of replacing a faulty part, repairers might be required to replace a larger part. Let’s take the example of a washing machine: instead of replacing the bearings in a washing machine drum, you might have to replace the whole drum. This is a clear victory for the industry, as the regulation doesn’t require manufacturer to redesign some key parts for repairability. But it’s very problematic for consumers and repairers as it keeps the price of some repairs high, which, in turn, can affect the choice to replace rather than repairing a product.
We urgently need a universal Right To Repair
The Ecodesign measures coming into force today are a great step forward. Energy labels are improved and combined with the repairability measures, they’re expected to jointly deliver 167 TWh of energy savings every year by 2030, as much as the final annual energy consumption of Denmark .
But the many restrictions for consumers and independent repairers are a good illustration of how far we still are from having a true universal Right to Repair in Europe.
This is why the Right to Repair movement has been campaigning in Europe for the past year, pushing for more ambitious rules that extend products’ lifetime, support consumers’ desire for more repairable products and benefit a sustainable economy.
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