What Right to Repair Means for UK Manufacturers
John Deere just paid $99 million to settle a right-to-repair class action. The EU's Right to Repair Directive takes effect July 31, 2026. Six US states have passed their own repair laws. Australia mandates diagnostic data sharing for motor vehicles.
If you're a UK manufacturer, this isn't a single regulation to comply with. It's a global shift in what consumers, regulators, and courts expect from the companies that make physical products.
Here's what's actually happening, where, and what it means for your operations.
The UK: Surprisingly Behind
The UK's own right-to-repair framework is the Ecodesign for Energy-Related Products and Energy Information Regulations 2021. It sounds comprehensive. It isn't.
What it covers: Washing machines, washer-dryers, fridges, freezers, dishwashers, TVs, electronic displays, lighting, and welding equipment. Spare parts must be available for 7-10 years after the last unit is placed on market.
What it doesn't cover: Smartphones. Tablets. Laptops. Small appliances. Clothing. Industrial equipment. Anything sold B2B.
The critical limitation: Manufacturers can restrict spare parts supply to "professional repairers." Consumers have no direct right to obtain parts themselves. There is no post-warranty repair obligation. No warranty extension for choosing repair. No standardised repair information form.
As of April 2026, the UK government has not introduced any new R2R legislation beyond these 2021 rules. DEFRA's Circular Economy Taskforce is developing a strategy, but it's at the consultation stage — not legislation. The House of Commons Library has questioned whether the UK's scope is sufficient, and campaign groups like the Restart Project have documented the growing gap between UK and EU requirements.
The result: UK manufacturers selling domestically face relatively light obligations. But the moment they export — to the EU, the US, or Australia — they enter a different world.
The EU: The Strictest Rules on Earth
The EU's Right to Repair Directive (2024/1799) takes effect across all 27 member states on July 31, 2026. It goes far beyond the UK's approach:
Post-warranty repair obligation. Manufacturers must repair in-scope products even after the statutory warranty expires. The only valid refusal is if repair is genuinely impossible.
Warranty extension. When a consumer chooses repair over replacement during the warranty period, the warranty extends by 12 months — on the whole product, not just the repaired component.
Anti-obstruction rules. Manufacturers cannot use software locks, hardware restrictions, or contractual clauses to block independent repair. Parts-pairing that locks out third-party repairers is specifically targeted.
Spare parts at reasonable prices. Parts must be available for 5-10 years depending on the product, priced so that repair remains economically viable — not just technically possible.
Nine product categories initially: washing machines, dishwashers, fridges, TVs, smartphones, tablets, vacuum cleaners, servers, welding equipment, and e-bike batteries. The scope expands annually under the Ecodesign for Sustainable Products Regulation.
UK manufacturers aren't exempt. Article 5(3) creates a liability cascade: if you're established outside the EU, your EU authorised representative, importer, or distributor bears the repair obligation on your behalf. Fieldfisher, Womble Bond Dickinson, and Lewis Silkin have all published detailed guidance for UK businesses.
Germany is embedding the repair right into its Civil Code. France has been running a national repair fund since 2023. Enforcement will be real.
The US: No Federal Law, But $99 Million in Consequences
The US has no federal right-to-repair law. But that hasn't stopped enforcement.
The FTC sued Deere & Company in January 2025, joined by the attorneys general of Illinois, Minnesota, Michigan, Wisconsin, and Arizona. The complaint alleged Deere maintained a repair monopoly by restricting its diagnostic software to authorised dealers, preventing farmers from accessing the tools needed for repairs.
Separately, Deere settled a class action for $99 million in April 2026. The settlement requires Deere to provide digital diagnostic tools for 10 years and enable offline repair by December 2026. The recovery rate — 26-53% of overcharge damages — is well above the typical 5-15% for class actions, signalling judicial sympathy for repair rights.
At the state level, California, Colorado, Minnesota, Massachusetts, New York, and Oregon have passed right-to-repair laws. All 50 states have proposed legislation. The requirements vary — California and Minnesota cover consumer electronics broadly, while Colorado's law targets agricultural equipment — but the direction is unmistakable.
For UK manufacturers selling into the US: there is no single standard to comply with. But the FTC has shown it will enforce, courts will award large settlements, and state laws are accumulating. The John Deere case is a warning, not an outlier.
Australia: Automotive Now, Everything Else Soon
Australia's Motor Vehicle Service and Repair Information Sharing Scheme has been in force since July 2022. It requires car manufacturers to share diagnostic and repair data with independent mechanics on fair terms.
Consumer electronics aren't covered yet. The Productivity Commission recommended expansion in 2021, but legislation hasn't followed. Agricultural equipment is the likely next target, with NSW Farmers calling for legislation and the government signalling support.
For UK manufacturers: if you export vehicles or automotive components to Australia, you're already subject to data-sharing requirements. For other categories, prepare for expansion in 2026-2027.
The Common Thread: You Can't Repair What You Can't Track
Every R2R regime — EU, US, UK, Australia — assumes the same thing: that a manufacturer knows who owns their products, what condition those products are in, and how to facilitate repair.
The manufacturers who lose R2R battles are those without digital product identity infrastructure. They can't prove who owns the product. They can't demonstrate what repairs were authorised. They can't verify whether parts are genuine. They don't know how many units are in the field, so they can't forecast spare parts demand for the 5-10 year availability windows these laws require.
John Deere didn't lose because their tractors were unrepairable. They lost because they restricted access to diagnostic software — the information layer. The EU directive doesn't ban selling products without repair infrastructure. But it makes operating without it commercially unviable.
What R2R Means Across Markets
| Requirement | UK (2021) | EU (Jul 2026) | US (State) | Australia |
|---|---|---|---|---|
| Post-warranty repair obligation | No | Yes | Varies | No |
| Warranty extension for repair | No | +12 months | No | No |
| Spare parts availability | 7-10 years | 5-10 years | Varies | N/A (data only) |
| Consumer access to parts | Professional only | Open | Open (most states) | Professional only |
| Anti-obstruction (software locks) | No | Yes | Yes (most states) | No |
| Diagnostic data sharing | No | Yes | Yes (FTC + states) | Yes (automotive) |
| Scope | 9 appliance types | 9+ expanding | Varies by state | Automotive only |
What UK Manufacturers Should Do Now
1. Map your export exposure
Which products do you sell into the EU? Into US states with R2R laws? Into Australia? Each market has different requirements. Build a compliance matrix by product and jurisdiction.
2. Build the information layer
Every R2R regime rewards manufacturers who know their installed base. Product registration, ownership tracking, and service history aren't just customer engagement tools — they're compliance infrastructure. A product operating system that tracks individual units from manufacture through ownership to end-of-life covers the information requirements of every jurisdiction simultaneously.
3. Systematise spare parts
The EU requires 5-10 years of parts availability at reasonable prices. The US settlement requires 10 years of diagnostic tool access. You need structured parts catalogues, demand forecasting based on installed base data, and pricing transparency. If your spare parts operation runs on spreadsheets and tribal knowledge, it won't survive a regulatory audit.
4. Prepare for diagnostic data sharing
Australia already mandates it for vehicles. The EU's anti-obstruction rules effectively require it. The FTC is prosecuting companies that restrict it. The trend is clear: manufacturers who hoard diagnostic information will face legal and commercial consequences. Build data sharing into your product architecture now, while you can design it rather than being forced to retrofit it.
5. Design to the highest standard
UK domestic law is the weakest of the four regimes. If you manufacture to UK-only standards, you'll be non-compliant everywhere else. Build to the EU standard — it's the most demanding, and if you meet it, you automatically comply with UK, most US state laws, and Australian requirements.
This Is Infrastructure, Not Compliance
The manufacturers who treat right to repair as a compliance checkbox will spend every year reacting to new legislation, new settlements, new enforcement actions. The manufacturers who treat it as an infrastructure investment — knowing who owns every product, tracking every repair, managing every spare part — will find that compliance follows naturally.
The regulations are converging. The EU is explicit. The US is aggressive. The UK will eventually catch up. Australia is expanding. Every one of these regimes asks the same question: do you know what happens to your products after you sell them?
The answer to that question determines everything else.