Selling into the EU from outside: label, EPREL and repair information

Which law applies

Under Article 6(1)(b) of the Rome I Regulation, a contract with a consumer is governed by the law of the consumer’s country of habitual residence if you direct your activities to that country. A different law chosen in your terms cannot deprive the consumer of the protection of that country’s mandatory rules (Article 6(2)); German law, for example, forbids deviations from its consumer contract rules to the consumer’s detriment (§ 312m(1) BGB). In our reading, a store in London, New York, Zurich or Shenzhen that targets German, French or Dutch consumers must therefore give the same repairability information as a store inside the EU.

What the product page must show

Points (u) and (v) of Article 6(1) of Directive 2011/83/EU, added by Directive (EU) 2024/825, require the following before the consumer is bound by the contract. The spare parts items apply only where there is no repairability class.

The wording and the open questions are in The requirement since 27 September 2026.

Energy label and EPREL for phones and tablets

Delegated Regulation (EU) 2023/1669 splits the work between two roles. The supplier ships each unit with a printed label, enters the product information sheet into the public part of EPREL, the EU product database, before placing a new model on the market, and gives dealers the electronic label and sheet (Article 3(1); Article 4 of Regulation (EU) 2017/1369). The dealer shows the label near the price online, directly or nested behind an arrow in the colour of the energy efficiency class, and the sheet near the price or as a link to EPREL (Article 4 and Annex VIII).

The arrow shows the energy efficiency class; the repairability class appears only on the label itself. It is open whether a label behind the arrow is enough for point (u), so showing the class in its own line is the cautious choice. Ask your supplier for each model’s EPREL registration number. The EPREL lookup turns it into class and index, and Find the EPREL registration number explains where it is printed.

Are you the importer?

Four importer duties matter here.

• Producer condition. For point (v), “producer” includes the importer into the EU (Article 2(4) of Directive (EU) 2019/771). If you are the importer, it is open if you can still rely on the condition that the producer makes the information available; both readings are in When the manufacturer provides nothing.
• Ecodesign. Spare parts and repair information duties under the ecodesign regulations fall on manufacturers, importers or authorised representatives. For smartphones and tablets, for example, listed spare parts must be available for at least seven years after the model is last placed on the market (Regulation (EU) 2023/1670).
• EPREL. If you are the supplier of goods with an energy label, you register the model in EPREL before placing it on the market.
• Repair obligation. For goods in Annex II of Directive (EU) 2024/1799, the repair obligation of a manufacturer outside the EU passes to its authorised representative, otherwise to the importer, otherwise to the distributor (Article 5).

Who counts as importer follows from the definitions of EU product law, which this guide does not settle. A store that ships parcels from outside the EU directly to consumers should clarify its role.

Marketplaces

On Amazon, eBay or any other marketplace, the duty stays with you as the consumer’s contracting party, on the wording of the directive. The platform must let you give pre-contractual and, where required, labelling information (Article 31 of the Digital Services Act, Regulation (EU) 2022/2065; for the energy label, Recital 9 of Delegated Regulation (EU) 2023/1669).

What to do

1. Check each product group with the obligation check, which answers with citation.
2. Collect the data. EPREL registration numbers for phones and tablets; for other goods the producer’s spare parts information, requested with the manufacturer request template if needed. Keep the request.
3. Show the information on each product page, with source and date.

The RepairInfoEU app works for Shopify stores wherever they are based. Essential ($6.99 a month) shows the block in the language your customer chose in your store, across the 24 official EU languages, and loads class and index by EPREL registration number, refreshed every week. Pro ($14.99 a month) adds a barcode scan of the whole catalogue, the repair portals of 49 brands, and manufacturer requests marked as due after 14 days, with a printable record. Free 14-day trial, billed through Shopify.