Businesses that design, manufacture or supply consumer products need to be aware that the EU's sustainability agenda has moved well beyond energy labels and efficiency ratings. The European Commission has opened a public consultation and call for evidence on future ecodesign requirements intended to make products easier to repair. Although the UK is no longer bound by EU product rules, those who sell into the EU single market or alongside it will want to watch this development closely.
Background: the Ecodesign Regulation
The Ecodesign for Sustainable Products Regulation ((EU) 2024/1781) (ESPR) entered into force on 18 July 2024 and is the cornerstone of the EU's approach to more sustainable and circular products. It applies to almost any physical goods placed on the EU market, and allows requirements to be set on matters such as durability, repairability, recycled content and carbon footprint. The detailed obligations for particular product groups are set out over time in Commission delegated acts, with at least 18 months for businesses to comply.
Repairability has long been flagged as a priority and the Commission's 2025–2030 working plan identified a horizontal repairability measure covering products such as consumer electronics and small household appliances.
The new update: the repairability consultation
The Commission has now opened a consultation and call for evidence to inform the impact assessment for a possible delegated act under the ESPR. The stated aim is to make a wide range of products on the EU market easier to repair, so that they last longer, generate less waste and support the move to a more circular economy. The initiative is also framed as supporting the Clean Industrial Deal objectives on circularity.
The consultation asks for views on the repairability challenges that consumers and repairers currently face, and on possible measures to address them, including:
- access to spare parts;
- availability of repair and maintenance information;
- software and firmware requirements;
- easier disassembly and reassembly; and
- repairability scores or information at the point of sale.
On scope, the Commission is looking at product families where repairability can play a key role in extending product lifetimes. Based on preliminary findings from the preparatory study, and subject to confirmation in the impact assessment, products expected to be covered include:
- consumer electronics: certain audio and video equipment, wearables and peripherals;
- light means of transport: certain e-bikes, self-balancing devices and some e-scooters; and
- small household appliances: kitchen appliances, personal care devices and other small electrical appliances.
Products already covered by product-specific rules, voluntary agreements or other regulatory frameworks are expected to fall outside this measure, to avoid overlap.
Impact on product suppliers
If adopted, the requirements would apply to products placed on the EU market, so UK businesses selling into the EU under their own brand would be within scope. Obligations under the ESPR also extend along the supply chain to importers, distributors and online sellers, so EU trading partners may look for firmer contractual assurances on compliance.
In practical terms, measures on spare parts, repair information, software and disassembly would go to the heart of product design and after-sales support, while a point-of-sale repairability score would make repairability a visible point of competition.
What businesses can do now
There is no obligation yet, but the direction is clear enough to justify some early work:
- Monitor the process. The consultation runs until 9 February 2027, and a draft act is expected to follow for further feedback.
- Engage. The consultation is open to businesses and other stakeholders, and responses can be made in any official EU language. Suppliers whose products may be in scope, directly or through trade associations, have a real opportunity to shape the technical detail.
- Map your portfolio. Identify which product lines may fall within the indicative categories and which may already be covered by product-specific rules.
- Review design and supply chains. Consider how easily products can be taken apart, how long spare parts can realistically be supplied, and whether key component suppliers could support longer availability commitments.
- Review contracts. Check that distribution, supply and marketplace agreements allocate ecodesign compliance responsibilities, information flows and liability appropriately, given how obligations fall along the supply chain.
- Join it up. Repairability work should be aligned with digital product passport readiness, Right to Repair obligations and any sustainability claims made about products.
As this is only a consultation, the final scope and detail of any requirements remain to be seen and may well change before a measure is adopted. For now, this is very much a watch this space development, and suppliers trading into the EU should keep a close eye on how it evolves.
