Who must show repairability information

Who has which duty

What exactly must be shown is set out in The requirement since 27 September 2026.

Consumers only

The information is owed to consumers under Directive 2011/83/EU on consumer rights; in Germany, for example, the duty attaches to consumer contracts in which a consumer agrees to pay a price (§ 312(1) BGB). Sales to businesses are not covered. If you sell to both, you owe the information to consumers, and since the product page looks the same for everyone, the simplest course is to show it to all.

Marketplaces

If you sell through a marketplace, you conclude the contract with the consumer and, on the wording, the duty is yours. The operator must design its interface so that you can meet your pre-contractual information duties and, where required, labelling duties (Article 31(1) and (2) of the Digital Services Act). Recital 9 of Delegated Regulation (EU) 2023/1669 applies this expressly to energy label information. If there is no suitable field, ask the operator for one.

Sellers outside the EU

A consumer contract is governed by the law of the country where the consumer lives if the trader directs its activities to that country (Article 6(1)(b) Rome I Regulation). A choice-of-law clause in your terms cannot remove that law’s mandatory protection (Article 6(2)). In our reading, a store in the UK, Switzerland or the US that targets EU consumers must therefore give this information as well. Labels, EPREL and importer roles for such stores are covered in Selling into the EU from outside.

Manufacturers, own brands and importers

If you make the goods, sell them under your own brand or bring them into the EU, you are bound as a seller in the same way. It is not settled whether the producer condition in point (v) still applies to you.

• Reading A: the information is available because you hold it yourself. Recital 36 of Directive (EU) 2024/825, which ties the condition to a producer “if different from the trader”, and the definition of producer, which includes importers and own brands (Article 2(4) of Directive (EU) 2019/771), support this.
• Reading B: the wording describes a transfer between two parties. Without it, the duty is not triggered, and recitals are not binding.

Separately, you may have duties of your own as manufacturer, importer or authorised representative: spare parts and repair information under the ecodesign regulations (see Spare parts periods), registration in EPREL as supplier of goods with an energy label, and the repair obligation for goods in Annex II of Directive (EU) 2024/1799. Where the manufacturer is outside the EU, that obligation passes to its authorised representative, otherwise the importer, otherwise the distributor (Article 5 of that directive). This page does not settle who counts as importer in a given case.

Refurbished, used and B-grade goods

Points (u) and (v) speak of “goods” and do not distinguish between new and used. The wording contains no exception for refurbished, used or B-grade goods, so we treat them like new goods; this has not been decided.

For smartphones and tablets, what matters is whether the model has a repairability class, which the EPREL lookup shows. If it has none, point (u) does not apply and point (v) does. For point (v), the test is the same as for new goods: what the producer has given you or shows on the product and packaging.

Check your own case

The obligation check asks who you sell to, what the goods are and what your role is, and returns the result with citation. If you sell on Shopify, the RepairInfoEU app shows the information on every product page in the language your customer chose in your store, across all 24 official EU languages. On the Pro plan it marks manufacturer requests as due after 14 days and produces a printable record. From $6.99 a month, with a 14-day free trial. The app works in your Shopify online store, not on marketplaces or in physical stores.