What EmpCo requires on product pages since 27 September 2026

The wording of points (u) and (v)

Directive (EU) 2024/825, known as EmpCo (empowering consumers for the green transition), added two points to the pre-contractual information list for distance and off-premises contracts in Directive 2011/83/EU.

“(u) where applicable, the reparability score for the goods;

(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)(u) and (v), Directive 2011/83/EU as amended by Directive (EU) 2024/825

A reparability score must be “based on harmonised requirements established at Union level” (Article 2(14d)), so national scores such as the French repairability index do not count. Member States transpose the points into national law; Germany, for example, added them as Article 246a § 1(1) no. 20 and 21 EGBGB (Federal Law Gazette 2026 I No. 28).

The EU right to repair (Directive (EU) 2024/1799, from 31 July 2026) is a separate rule on producers’ repair obligations and legal guarantees, not on information before purchase. See Right to repair or EmpCo?

Score first, otherwise repair information

The two points are tiered. Where an EU score exists, only the score is required and spare parts information is optional. Otherwise point (v) applies. As of October 2026:

It is open whether a smartphone’s index (scale up to 5) must be shown alongside its class, and whether point (v) applies to older tumble dryers without a class. See Repairability class A to E and Spare parts and manuals.

The producer condition

Point (v) covers information the producer has given you or shows on the product, its packaging, tags or labels. Recital 36 of Directive (EU) 2024/825 adds that “the trader should not be required to actively seek such information from the producer, for example, by searching on the product-specific websites”. Recitals are not binding, but they guide interpretation.

“Producer” includes the importer into the EU and anyone who puts their name or brand on the goods (Article 2(4) of Directive (EU) 2019/771). Whether the condition still applies when you sell in one of these roles yourself is not settled. Both readings are set out in When the manufacturer provides nothing.

Online or in store

When and where the information must appear

The information must be given before the consumer is bound by the contract (Recital 34). German law also requires it to be clear, comprehensible and adapted to the means of distance communication (Article 246a § 4 EGBGB). In an online store the product page is the natural place. Neither point says where exactly, or whether the information may sit behind a click; while that is open, showing it without a click is the cautious choice. You do not have to repeat it right before the order button, as Article 8(2) of Directive 2011/83/EU does not list points (u) and (v).

What to do now

1. Check the requirement per product group. The obligation check returns point (u), point (v) or no duty after a few questions, with citation.
2. Get the data. The EPREL lookup returns class and index for a registration number. For other goods, the barcode check shows what the French repairability index data holds for an EAN.
3. Show it on the product page, with source and date, for example the EPREL registration number. In Germany the information becomes part of the contract and the seller must prove it was given (§ 312d(1) and § 312m(2) BGB).
4. Ask for what is missing. The manufacturer request covers every item of point (v). Keep the request and any reply.

For a whole Shopify catalogue, the RepairInfoEU app handles steps 2 to 4. Essential ($6.99 a month) shows the block on every product page in the 24 official EU languages and loads class and index by EPREL registration number, refreshed every week. Pro ($14.99 a month) checks the whole catalogue by barcode, knows the repair portals of 49 brands, marks manufacturer requests as due after 14 days and produces a printable record. Free 14-day trial.