Sellers owe information on spare parts, repair manuals and repair restrictions only “provided that the producer makes the information available to the trader” (Article 6(1)(v) of Directive 2011/83/EU, inserted by Directive (EU) 2024/825). If the manufacturer provides nothing, the wording does not trigger the duty.
Under recital 36, you pass on what the manufacturer gives you or shows on the product, packaging, tags or labels; you are not required to search product websites for it. Ask, and keep the request and the reply. Whether this also applies when you are the manufacturer, own brand or importer is an open question.
What the rule says
“(v) where point (u) is not applicable and provided that the producer makes the information available to the trader, information about the availability and estimated cost of, and procedure for ordering, spare parts that are necessary to keep the goods in conformity, about the availability of repair and maintenance instructions and about repair restrictions.”
Article 6(1)(v) of Directive 2011/83/EU, applicable since 27 September 2026; in store Article 5(1)(j)
The condition applies only to point (v). Smartphones and slate tablets fall under point (u), the repairability class, which you can find with the EPREL lookup. The directive says “producer”; Germany, for example, implements the rule in Article 246a § 1(1) No. 21 EGBGB.
What counts as “made available”
The directive does not define the term. Recital 36 of Directive (EU) 2024/825 names two routes: information the producer has provided to the trader, and information it shows on the product itself, its packaging or tags and labels that consumers would normally consult before buying.
“The trader should not be required to actively seek such information from the producer, for example, by searching on the product-specific websites.”
Recital 36 of Directive (EU) 2024/825
Recitals explain a directive; they are not part of its operative text.
Where to look first
- product data, data sheets and price lists the manufacturer has sent you
- the manufacturer’s dealer portal or B2B area, if you have access
- packaging, labels, tags and the product itself
What the manufacturer gives you or shows on the product and packaging belongs on the product page. If it is missing, ask.
What is still open
Four questions have not been settled. Where the RepairInfoEU app has to take a position, that is the app’s decision, not the legal position.
| Question | Status | The app’s decision |
|---|---|---|
| You are the manufacturer, own brand or importer. | Reading A: you have the information anyway; recital 36 (“if different from the trader”) and the broad definition of producer in Article 2(4) of Directive (EU) 2019/771 support this. Reading B: the wording describes a step between two parties; without it, no duty arises. | For own-brand products the app offers no “manufacturer provided nothing” status. |
| The manufacturer must publish information online anyway, such as spare parts lists under the ecodesign regulations. | Whether publication on its website counts as making the information available to you is unclear. Recital 36 speaks against a duty to search. | The manufacturer directory suggests such pages; you decide whether to use them. |
| Who has to prove what? | Sellers bear the burden of proving they met their information duties (in Germany § 312m(2) BGB). Whether that includes proving the manufacturer provided nothing is open. | The app records request and result with dates in its record. |
| Must the store say “no manufacturer information”? | Transparency might suggest a notice; such a notice could, however, read as a negative statement about the product. | No notice. The product then shows no block. |
How to document your request
- Send a requestOnce per manufacturer for all products, with the five points of the rule plus model and barcode per product. The free manufacturer request writes the letter in English, German or French.
- Set a deadlineThe law sets none. The template asks for a reply within 14 days.
- Remind onceIf no reply comes, send one written reminder. The tool creates a calendar file for it.
- Keep everythingRequest, reminder and reply or silence, each with its date and linked to the product.
For many brands: the Shopify app
With many brands in your range, the request turns into a list. The Pro plan of the Shopify app RepairInfoEU ($14.99 a month, free 14-day trial) keeps it for you. The manufacturer directory covers repair portal, spare parts shop and manuals for 49 brands. For all others, the app writes one request per brand covering all its products, marks it as due after 14 days and logs reply or silence with the date in a record you can print or save as PDF.
Frequently asked questions
Do I have to ask the manufacturer at all?
The law does not require a request. A request is, however, the simplest evidence that you received nothing.
What exactly do I ask for?
Availability of spare parts, estimated cost, ordering procedure, repair and maintenance instructions and repair restrictions, with model and barcode for each product.
What if the manufacturer replies later?
From then on you have the information, and point (v) applies to that product. Update the product page.
Is a link to the manufacturer’s price list enough for the estimated cost?
That has not been decided. The RepairInfoEU app has opted to allow a link; the opposing view holds that the rule requires the information itself, not a reference.
Sources
Laws and regulations in their current version, linked to the source.
- Directive (EU) 2024/825 (empowering consumers for the green transition)EUR-Lex · EU directive · 6 Mar 2024
- Directive 2011/83/EU on consumer rightsEUR-Lex · EU directive · 26 Mar 2024
- Directive (EU) 2019/771 (sale of goods)EUR-Lex · EU directive · 20 May 2019
- Article 246a § 1 EGBGB (German pre-contractual information duties, distance contracts)Bundesministerium der Justiz · Law · 27 Sept 2026
- Sections 312 to 312m BGB (consumer and distance contracts)Bundesministerium der Justiz · Law · 27 Sept 2026