The repair market of vehicles has long demonstrated what happens when design for longevity meets strong consumer-friendly regulations ensuring fair competition and a level playing field between manufacturers and independent aftermarket businesses. Today however, with changing technology and markets, repairability is getting increasingly challenged by non-dismantlable designs, unavailable spare parts or services, anti-repair practices, and electronic components prone to early obsolescence.
Vehicle reparability is important in terms of sustainability – it’s essential to reduce resource use and support EU independence from imports of critical raw materials, especially when it comes to batteries in electric vehicles (EVs) – but also from a socio-economic perspective. Given the strong reliance of Europeans on cars (88% of households own at least one) and their high cost, automotive longevity is a major issue for consumers. Jeopardising the right to repair for vehicles means driving up maintenance costs, insurance premiums, and pushing towards premature replacement. It also means making it difficult for European aftermarket actors such as independent repairers and spare parts distributors to stay in business.
The EU Commission has proposed a Regulation on circularity requirements for vehicle design and on the management of end-of-life vehicles. However the proposal misses a number of opportunities to secure strong provisions on repair, reuse, and design for circularity. Together with the EEB, ECOS, iFixit, HOP, The Restart Project, DUH and actors in the automotive sector namely the FIA European Bureau, FIGIEFA, Insurance Europe and MOBILIANS, we published a joint statement with our recommendations to protect consumers’ and businesses’ right to repair vehicles. Our main points of improvement concern design, spare parts and repair information, anti-repair practices, as well as repairability and replaceability of batteries in EVs.
The next step in the legislative process will be the publication of a draft report by the EU Parliament on the Regulation proposed by the EU Commission. We therefore urge the co-legislators to take into account our input as the right for consumers and businesses to repair vehicles must be safeguarded and strengthened. We also invite organisations working on vehicle repairs and spare parts to join our coalition and advocate together for more repairable vehicles, more accessible spare parts, less software tricks blocking repair, and much more! Learn more about membership and how to join here.
Design for repair and access to spare parts
The EU has a long history of regulating products under ecodesign, including aspects of durability and repairability. As it’s the case for many other sectors, spare parts are crucial for vehicle repairs. For this reason, minimum requirements should be introduced with regards to availability of spare parts for at least 20 years after the end of placement of a vehicle on the market. Furthermore, spare part prices should not deter repair and encourage replacement. In addition, the design of components should ensure vehicle reparability by maintenance operators during the use phase, addressing design practices such as giga-casting through requirements on disassembly depth. Finally, making sure repairs can be carried out without the need for brand-specific tools is necessary to avoid restricting competition.
Anti-repair practices and software obsolescence
Practices such as software part-pairing are major barriers to repair, hindering consumer choice and the repair market at large by allowing manufacturers to establish monopolies on repairs and spare parts, which drives up costs. Techniques impeding independent repair should be banned, and interoperability measures should be mandated to allow repair operators to e.g. deregister parts from a vehicle and register them onto another.
Similarly, as vehicles become more and more connected and dependent on operating systems, they also create risks of software obsolescence. As we demand for spare parts availability, software updates should also be guaranteed for at least 20 years, given that the average lifespan of a vehicle is currently around 19 years. As a comparison, smartphones, which have an average lifespan of 4 years, have their software maintenance obligation set at a minimum of 5 years under their Ecodesign Regulation.
Access to repair information
A competitive repair market requires that access to information be non-discriminatory and does not make repair more expensive. As such, access to repair information should be free of charge and for a duration equal to the duration of spare parts and software update availability.
A repairability score should also be introduced, making sure it is effective in distinguishing best-performing products. In other words, vehicles merely compliant with minimum requirements should only be assigned the minimum repairability score, so as to leave room for innovation and competition for excellence. Given that internal combustion vehicles (ICVs) will be phased out as of 2035, and considering obvious differences between ICVs and EVs that could mislead comparisons, a score should only be developed for EVs.
Repairability of electric vehicle batteries
Given the increasing electrification of road transport, ensuring that batteries used in EVs are replaceable and repairable is crucial. While European manufacturers still allow dismantling and replacing of their battery modules, several non-European manufacturers are making this difficult through the use of resins and thermal interface material sealing modules together and preventing repair. The EU Batteries Regulation does not currently address this issue, which should be tackled in the proposed Regulation through replaceability and repairability requirements for EV batteries.
Read our full joint statement here!