Right to repair or EmpCo: which rule applies when

31 July or 27 September 2026?

What the right to repair changes for sellers

“Before the seller provides the remedy to bring the goods into conformity, the seller shall inform the consumer about the consumer’s right to choose between repair and replacement, as well as about the possible extension of the liability period, provided for in Article 10(2a).”

Article 13(2a) of Directive (EU) 2019/771, inserted by Directive (EU) 2024/1799

These changes do not apply to sales contracts concluded before 31 July 2026 (Article 21 of Directive (EU) 2024/1799).

What falls on the manufacturer

At the consumer’s request, the manufacturer must repair goods listed in Annex II of the directive outside the legal guarantee, free of charge or for a reasonable price. It may not refuse only because someone else has repaired the item before, and it publishes indicative prices for typical repairs on a freely accessible website (Articles 5 and 6). The duty reaches as far as the listed act sets repairability requirements; the directive sets no fixed number of years.

Which spare parts must be available, and for how long: spare parts periods by product group.

When a seller takes the manufacturer’s place

If the manufacturer is established outside the EU, its authorised representative performs the duty to repair; failing that, the importer; failing that, the distributor (Article 5(3)). A store that sources Annex II goods directly from outside the EU can therefore carry the manufacturer’s duties, indicative prices included. Whether your store counts as the importer depends on the facts. More for non-EU sellers: selling into the EU from outside.

Repair platform and European form

By 31 July 2027, the Commission’s common interface and the national platforms of the European online platform for repair must be in place; it is free for consumers and voluntary for repairers (Article 7). Anyone who repairs may use the voluntary European Repair Information Form; the repairer may not change the conditions stated in it for 30 calendar days (Article 4).

What belongs on the product page?

Only the information required by Directive (EU) 2024/825, for every sale to consumers, including goods outside Annex II.

The estimated cost in point (v) refers to spare parts; indicative repair prices are not required by points (u) and (v). Germany implements both in Article 246a § 1(1) Nos 20 and 21 EGBGB. Wording and examples: what applies since 27 September 2026.

What to do now

In complaints

Add two sentences to your reply templates for defect reports, for example:

“You can choose whether we repair the item or replace it. If it is repaired, the period during which we are liable for defects is extended once by 12 months.”

Example for contracts concluded from 31 July 2026; adapt it to the national law that governs the contract

Note each repair on the order so your team can see the longer period later.

On the product page

1. Use the free obligation check to see whether your product needs the class (point (u)) or spare parts information (point (v)).
2. Get the information: the class with the EPREL lookup, spare parts information from the manufacturer with the manufacturer request.
3. For the whole store, the Shopify app RepairInfoEU shows the information as a block below the buy button, in 24 EU languages. Essential ($6.99 a month) loads class and index by EPREL registration number, refreshes them weekly and matches barcodes with the French repairability index. Pro ($14.99) adds the catalogue scan, the manufacturer directory and manufacturer requests with a record.