Blogpost written by Katrin Meyer, Director of Runder Tisch Reparatur (Roundtable Repair)
Germany’s parliament (Bundestag) recently passed a landmark Ecodesign Act which is a major victory for the non-commercial repair movement. For the first time, members of volunteer repair initiatives obtain a legal right to spare parts and repair information that manufacturers need to make available to “professional repairers”. Thanks in part to the persistence of Runder Tisch Reparatur, member of the Steering Group of the Right to Repair Coalition, the law requires remarkably little bureaucracy to verify eligibility. However, a significant regulatory gap remains unresolved despite vocal criticism.
EU Ecodesign regulations have required manufacturers since 2021 to grant professional repairers access to spare parts and repair information. Yet the term ”professional repairer” remained undefined in German law for years, and in practice was almost exclusively interpreted as ”commercial repairer.” Germany’s new law clarifies that volunteer repair initiatives where repairs are conducted without charge but with genuine expertise are equally entitled to these spare parts and repair manuals.
How non-commercial repairers can gain access
Under the new law, non-commercial repairers are now legally defined as: licensed electricians qualified for specific tasks, or representatives of repair initiatives that provide repair services free of charge (§2 Abs. 1 Nr. 12).
Manufacturers must not refuse non-commercial repairers access to spare parts and repair information once they have provided the required evidence (§15 Abs. 4 Nr. 3).
The bar for providing this evidence is deliberately low which is a direct result of Runder Tisch Reparatur’s input during the legislative process. Non-commercial repairers must provide manufacturers with three types of evidence to access restricted spare parts and repair information:
1. Proof of membership in the sector
Proof that you operate as a non-commercial repair initiative. This can take several forms: membership in a repair organization, a power of attorney from a repair network, or formal qualification as an electrician for specified tasks. Crucially, the law states that this proof of affiliation simultaneously serves as proof of technical competence. No separate competency exam or certification is required for volunteers.
2. Liability insurance
Proof of insurance that covers liability from repair activities. This can be shown as a simple yes/no declaration. Group liability insurance is explicitly permitted.
3. Compliance with safety standards
A self-declaration of compliance with generally recognized rules for repairing electrical equipment.
Once these three types of evidence are submitted, manufacturers are legally prohibited from denying access.
Commercial repairers: A two-tier system
The law creates a clearer but more complex pathway for commercial repair businesses, depending on their legal status.
For craft businesses (registered under the Craft Trade Act): The process is straightforward. A craft card (Handwerkskarte, a standard credential issued by local craft chambers) serves as complete proof of expertise and compliance with electrical equipment repair regulations. Only proof of liability insurance is additionally required.
For unregistered commercial repairers: Any business not formally registered as a craft trade must independently demonstrate three things to each manufacturer: proof of business registration, a self-declaration of expertise and compliance, and proof of liability insurance.
The critical gap: Independent repair shops
Commercial repair businesses operating outside the formal craft system such as independent smartphone repair shops fall into a legal gray zone. They must individually negotiate with each manufacturer to prove their competence, with no standardized pathway. Unlike repair cafés or registered craft businesses, they face no legal protection if manufacturers simply reject their evidence.
This gap has been criticized by Runder Tisch Reparatur during the legislative process. Today, this gap affects a manageable number of repairers. But as European Ecodesign regulations will expand to small appliances (under EU Regulation 2024/1781) and potentially other product categories, thousands of independent repair businesses will face this issue.
Professional repair businesses should have the same legal certainty as volunteer repair cafés. A technically competent independent smartphone repair shop deserves the same guaranteed access to parts and manuals as a registered craft business.
What happened instead of a fix
During the parliamentary hearing in late May, Runder Tisch Reparatur submitted a concrete proposal: allow the federal materials research institute to recognize additional registration or certification systems as proof of competence. This would have solved the problem pragmatically without waiting for the next law revision.
The German parliament acknowledged the regulatory gap but stopped short of implementing a solution. Instead, it merely asked the federal government to study how commercial repairers outside the craft system could be better accommodated, effectively deferring the issue indefinitely.
What’s at stake
Germany’s repair movement has achieved something significant with the recent passage of the Ecodesign Act: volunteer repair initiatives are now legally empowered. But the law stops short of fully protecting independent professional repairers. As Europe moves toward stronger right-to-repair legislation, this inconsistency will become increasingly problematic, especially as smaller, independent repair shops are vital to thriving local repair ecosystems across the continent.