Right to Repair: What It Means for UK Manufacturers
For years, some agricultural equipment makers built software locks that prevented farmers from fixing their own machines. The result was a familiar set of complaints: hefty dealer repair bills for problems an owner could have solved quickly, long drives to the nearest authorised dealer in the middle of harvest, and crops left waiting while a machine sat idle.
That model has now drawn regulatory and legal scrutiny in the United States, and the EU's Right to Repair Directive sets out to ban the kind of software lock that blocks independent repair.
This is where the right-to-repair movement is heading. From a fringe campaign fought by tinkerers and repair enthusiasts, it has become binding legislation that will force manufacturers across the EU, and soon the UK, to fundamentally rethink how they handle repair, parts, and service after the sale.
If you manufacture physical products for the UK or EU market, the clock is already running.
| Key Legislation | Scope | Status |
|---|---|---|
| UK Ecodesign Regs 2021 | White goods, TVs, lighting | In force |
| NI Ecodesign Amendment (NI Regs 2025) | Smartphones, tablets (NI only) | In force (20 June 2025) |
| UK Product Regulation and Metrology Act 2025 | Enabling framework for extending UK rules | In force (Royal Assent July 2025); secondary regs to follow |
| EU Right to Repair Directive 2024/1799 | Smartphones, laptops, appliances, bicycles, agricultural equipment | Transposition due 2026 |
| EU Mandatory Repairability Label | Repairability scale on product packaging | Aligned with smartphone ecodesign rules |
| France Repairability Index | Score on packaging | In force |
What the UK Currently Requires
The UK's Ecodesign for Energy-Related Products Regulations 2021 set the baseline. They cover washing machines, dishwashers, refrigerators, televisions, electronic displays, and lighting. For these products, manufacturers must:
- Make spare parts available to professional repairers for a defined period after the last unit is manufactured
- Deliver ordered parts within a set delivery window
- Provide repair and maintenance information to the service network
- Ensure products can be opened and repaired without destroying them in the process
Note what the regulations do not require: making parts available directly to consumers. UK law still treats repair as a professional activity. That distinction matters for how you structure your spare parts channel.
The Smartphone Gap
The most glaring omission in the UK's 2021 regulations is smartphones and laptops, the two product categories consumers are most likely to want to repair and most likely to encounter software locks when they try.
This gap is closing. The Ecodesign for Energy-Related Products and Energy Information (Amendment) (Northern Ireland) Regulations 2025 brought Northern Ireland into line with EU rules for smartphones and tablets from 20 June 2025 (under the Windsor Framework), covering spare parts availability, non-discriminatory software access for professional repairers, durability testing, and battery longevity standards. The UK Product Regulation and Metrology Act 2025, which received Royal Assent in July 2025, creates the enabling framework to extend similar rules to Great Britain, with the substantive requirements to come through secondary regulations.
If you manufacture smartphones or smart consumer electronics for the UK market, the direction of travel is unambiguous. The question is whether you prepare now or scramble later.
What the EU Adds, and Why UK Manufacturers Must Care
EU Directive 2024/1799 entered force in 2024, and every EU member state must transpose it into national law within the Directive's transposition window. The scope is significantly broader than the UK's current rules, and the obligations are meaningfully stronger.
Products covered: Smartphones, tablets, laptops, washing machines and dryers, dishwashers, vacuum cleaners, bicycles and e-bikes, and agricultural equipment.
Key obligations that go beyond UK rules:
Post-warranty repair mandate: Manufacturers must offer repair services even after the legal warranty has expired, unless repair is technically impossible. Consumers have a right to repair, not just a right to a replacement.
Spare parts for independent repairers and consumers: Independent repairers and consumers must be able to buy spare parts, tools, and repair manuals at reasonable prices for a defined period after a product is discontinued. Not just professional repairers, but any repairer.
Parts pairing is restricted: Manufacturers cannot use software authentication to prevent a replacement part from functioning. No "this genuine part won't activate until an authorised technician validates it" systems. The Directive sets out to prohibit hardware barriers, software locks, and contractual clauses designed to block independent repair.
Warranty extension on repair: If an EU consumer chooses repair over replacement for a fault covered by warranty, the product's statutory warranty is extended. Repair becomes actively advantageous for the consumer.
European Repair Information Form: On the consumer's request, repairers must be able to provide a standardised form showing estimated repair cost, conditions, and timing, so consumers can compare repair offers before committing.
The UK implication: UK businesses are not subject to EU law domestically. But any UK manufacturer selling in-scope products into EU markets must comply in full, or lose that market. The practical result is that most UK manufacturers doing any export volume will need EU-standard processes. Many will simply roll those standards out across their whole operation.
If you sell washing machines in Germany, spare parts obligations apply. If your UK-based distributor sells your power tools in France, repair information requirements apply. You cannot easily maintain separate processes for UK and EU customers when you share a production line, a parts catalogue, and a customer service team.
What Retailers Must Do
Right-to-repair obligations do not fall on manufacturers alone. Retailers selling covered products have obligations too, particularly under EU rules.
Retailers must:
- Inform consumers of their right to repair and the availability of repair services
- Provide access to the European Repair Information Form on request
- Clearly communicate spare parts availability and warranty terms at point of sale
- Not promote replacement over repair when repair is feasible under warranty
For large electrical and appliance retailers, this means updating product listing pages, checkout flows, and post-purchase communications to surface repair options, not just replacement offers. The warranty extension on repair creates a real incentive for consumers to choose repair, and retailers need to make that option findable.
This is a significant content and information architecture problem. For a retailer carrying thousands of SKUs, surfacing accurate, up-to-date repair information at the product level is close to impossible without manufacturer-provided data.
Which brings us to why the manufacturer's scan page matters.
Repairability as a Differentiator
While many manufacturers treat repairability as a compliance burden, a number have built it into their product identity and turned it into a commercial and reputational advantage.
A handful of device makers now lead with repairability as a core marketing message rather than a compliance footnote. Fairphone builds modular, user-repairable smartphones with long spare-parts commitments; Framework does the same for laptops with user-replaceable modules; and Apple has introduced a Self Service Repair programme offering parts, tools, and manuals directly to consumers. For brands like these, repairability is a differentiator in a crowded market and a direct response to consumer sentiment around e-waste, not a line buried in a sustainability report.
At the other end of the spectrum, parts pairing, the same kind of software lock at the centre of the agricultural-equipment disputes, means a replacement screen or battery may require manufacturer authentication before the device will recognise it. You can physically fit a genuine part, but it will not work without a software authorisation. This is precisely the model the EU Directive sets out to ban.
The trajectory is clear. Repairability scores are becoming visible to consumers at point of sale, with France already requiring a score on packaging and the EU's repairability label coming to smartphones. The brands that score well will use that score as a differentiator. The brands that score poorly will face both regulatory pressure and consumer scrutiny.
Manufacturers who treat repair as a strategic opportunity rather than a compliance burden put themselves in a position to capture aftermarket revenue. This ties into broader product registration software strategies and direct consumer engagement through spare parts discovery.
The BrandedMark Scan Page as a Right to Repair Portal
Every product with a BrandedMark QR or NFC tag carries a unique scan page, accessed by the consumer at unboxing, during use, and at the end of life. That scan page is a natural delivery mechanism for right-to-repair compliance.
Here is what a right-to-repair compliant scan page can look like in practice:
| Right to Repair Requirement | Scan Page Delivery |
|---|---|
| Repair manual access | Direct link to PDF or video guide, version-matched to that product's manufacture date |
| Authorised repairers | Geo-located list of approved repair centres, surfaced from the product itself |
| Spare parts availability | Link to parts catalogue, pre-filtered by model and serial number |
| Independent repairer documentation | Same page, same information, no discrimination |
| Warranty status | Live warranty status: is this product in warranty, what's covered, when does it expire? |
| Post-warranty repair offer | Link to manufacturer's own out-of-warranty repair booking flow |
BrandedMark's scan pages are built in a no-code designer, meaning manufacturers can add, update, and restructure that repair portal content without developer involvement. As EU transposition happens across member states, the scan page can be updated once and the change flows to every product in the market.
This is the inverse of the software-lock problem. Where some manufacturers used software as a lock, a scan page uses software as the service layer, the mechanism that puts the right information in front of the right person at the right moment in the repair journey.
For retailers, this matters too. A product with a digital scan page that surfaces repair information proactively can reduce the retailer's information burden. The manufacturer has already done the work. The QR code is on the product. The consumer can scan it.
This repair portal can become a direct sales channel as well, with manufacturers capturing aftermarket revenue through spare parts discovery and warranty claim automation. The same digital product identity that supports compliance also supports revenue.
Building a Compliance Programme
Manufacturers building right-to-repair compliance programmes often evaluate several post-purchase platforms, some focused on returns and reverse logistics, some on post-purchase communications, some on product registration and warranty management. Many provide isolated pieces, such as product registration software, spare parts discovery, or warranty tracking, as standalone modules.
A comprehensive approach integrates these elements into a single digital product identity and connected product stack. The differentiation is in the product-level delivery mechanism: a scan page embedded in the product itself, serialised per unit, accessible offline-first via QR or NFC. This routes consumers to a page specific to the exact product in their hand, which is what right-to-repair regulations call for: documentation matched to the product, not the product category.
Frequently Asked Questions
Which of my products are covered by UK right-to-repair rules right now, and which will be covered by 2026?
Under the UK Ecodesign Regs 2021, these are in force now: washing machines, dishwashers, fridges, TVs, and lighting, with manufacturers required to supply spare parts to professional repairers for a defined period. Smartphones and laptops are not yet covered in Great Britain, but Northern Ireland rules apply under the NI amendment, and the UK Product Regulation and Metrology Act 2025 creates the enabling framework to extend rules GB-wide through secondary regulations. Any product sold into the EU triggers EU Directive obligations as member states transpose it, covering smartphones, tablets, laptops, appliances, bicycles, and agricultural equipment. If you manufacture for both markets from shared tooling, adopting the more restrictive standard across the board is the practical approach.
Does the EU's restriction on parts pairing mean we have to change software for UK units too, or only for EU sales?
The EU Directive applies to products placed on the EU market. UK domestic sales are not covered by EU law. However, if you operate shared production tooling, software platforms, and supply chains, maintaining two different software authentication systems, one that pairs parts for UK units and one that does not for EU units, is commercially and operationally awkward. Many manufacturers adopt the more open approach across all markets. The UK Product Regulation and Metrology Act 2025 also signals movement toward similar UK rules, which makes a restrictive, UK-only approach a short-term solution at best.
If we sell in France, what repairability scoring and labelling must we do?
France's repairability index applies to product categories including smartphones, laptops, TVs, washing machines, and lawnmowers. If you sell any of these through French retail or cross-border e-commerce to French consumers, you must display the score using the government's standardised methodology, and failure to do so is a regulatory violation. The EU's repairability label is coming next with smartphone ecodesign rules. Repairability scores are becoming a visible, point-of-sale signal. Strong scores can help with shelf access, while weak scores can create friction with retailers.
What to Do Now
Right-to-repair compliance is not a 2026 problem. The products you are manufacturing and shipping today are the products that will need to carry repair information, spare parts availability, and, for EU sales, post-warranty repair access in the near future. Supply chain preparation for long-term parts availability needs to happen at product design stage, not at the regulatory deadline. Understanding the DPP compliance timeline 2026-2030 is essential for strategic planning.
The manufacturers who move first can also capture the repairability story as a brand asset. When repairability labels appear on packaging, a strong score is a marketing differentiator. When consumers scan a product at the point of repair need, the brand that delivers a clear, fast, frictionless repair experience is the brand best placed to retain the customer relationship, and the spare parts revenue. This is the broader vision of connected product ROI: using digital infrastructure to turn compliance obligations into competitive advantages.
The agricultural-equipment disputes should serve as a warning for every manufacturer with a connected product. Software can lock repair, or software can enable it. The EU Directive has set a clear direction. The question now is whether you build the enabling infrastructure strategically, or scramble to it under compliance deadline pressure.
BrandedMark is the Product Operating System for manufacturers of physical goods, with serialised product identity, connected experiences, warranty registration, and Digital Product Passport readiness in one platform. See how it works at brandedmark.com.