Right to Repair and Your Warranty Strategy
Key Takeaways
- UK Ecodesign Regulations require spare parts delivery to professional repairers within 15 working days; parts must remain available 7–10 years after last sale
- OEM spare parts carry 55–70% gross margins versus 20–35% for new product — the aftermarket is more profitable than the original sale
- John Deere's proprietary repair lock-in generated an estimated $2.4 billion annually but triggered FTC antitrust action and lasting brand damage in agricultural communities
- France's repairability index (in force since 2021) is the leading indicator for UK regulation — products scoring below 6/10 face retail disadvantage in French markets now
Two pieces of legislation are reshaping what it means to manufacture a physical product in Europe and the UK. The UK Ecodesign for Energy-Related Products Regulations 2021 and the EU Right to Repair Directive 2024 both arrive at the same conclusion: if you sell it, you must be able to fix it. Spare parts must be available. Repair information must be accessible. And customers — or their chosen repairers — have a legal right to access both.
The instinctive response from many manufacturers is to treat this as a compliance cost: a legal minimum to satisfy at the lowest possible expense. The smarter response is to ask a different question — what if spare parts are not a cost at all, but a revenue channel you have been leaving untapped?
| Key Metric | Value |
|---|---|
| EU Right to Repair Directive — spare parts availability obligation | 7–10 years post-sale |
| UK Ecodesign Regs — maximum delivery time to professional repairers | 15 working days |
| Global aftermarket parts market size (2025) | $390 billion |
| Average gross margin on OEM spare parts vs. new product | 55–70% vs 20–35% |
| John Deere — estimated revenue from proprietary repair lock-in | $2.4 billion annually |
| France repairability index minimum score (from 2025) | 6/10 for large appliances |
What the Law Actually Requires
The legal baseline is more specific than most manufacturers realise.
Under the UK Ecodesign Regulations, manufacturers of energy-related products must make spare parts available to professional repairers within 15 working days of an order. The parts must remain available for a minimum of seven years after the last unit is placed on the market — in some product categories, ten years.
The EU Right to Repair Directive, which passed in 2024 and begins phased implementation in 2026, goes further: it covers a broader product range, introduces a right for consumers to request repairs over replacements in certain circumstances, and creates a European repair information database.
Neither regulation specifies how you make parts available. They do not require you to have a direct-to-consumer spare parts shop, a scan page, or any particular digital infrastructure. They simply require that the parts exist, that they are priced reasonably, and that repairers can get them within the required timeframe.
The compliance floor is low. The commercial ceiling is high.
The John Deere Cautionary Tale
No story better illustrates the risk of getting the repair strategy wrong than John Deere's encounter with the Right to Repair movement.
For over a decade, John Deere used software locks — specifically their Electronic Data Link (EDL) diagnostic system — to prevent farmers from repairing their own tractors. Replacing a sensor or an engine component would trigger an error code that could only be cleared by an authorised John Deere dealer. The US FTC and state attorneys general cited this practice directly in their 2025 antitrust action, characterising it as an unfair method of competition under the FTC Act. In practice, this meant a farmer with a broken-down tractor during harvest season was dependent on a dealership that might be days away.
The commercial logic was clear: lock in service revenue, protect dealer margins, prevent third-party parts from entering the supply chain. In the short term, it worked. John Deere estimated that proprietary repair revenue contributed billions annually to its services business.
The backlash was severe and enduring. Farmer coalitions in the US and Europe mobilised around Right to Repair legislation specifically targeting John Deere. The brand became synonymous with corporate overreach in agricultural communities. In 2023, under pressure from the US FTC and state legislatures, John Deere signed a memorandum of understanding committing to providing independent repair access — a concession extracted through years of reputational and legal pressure.
The lesson is not that repair lock-in is impossible to execute. It is that the brand damage when it unravels is disproportionate to the service revenue it protects. Customers who feel trapped by a warranty strategy become vocal critics. Customers who feel supported by one become advocates.
The Fairphone Inspiration
Fairphone took the opposite approach and turned repairability into a brand asset.
The Fairphone 5 is designed with eleven components that the user can replace themselves, without specialist tools, using a standard screwdriver. Spare parts are sold directly through Fairphone's website — batteries, screens, cameras, USB ports — at transparent prices. The product scores 9.3 out of 10 on the French repairability index (more on that below). Repair guides are publicly available and genuinely useful.
None of this is regulatory compliance. Fairphone's repair strategy goes well beyond any legal minimum. But it has delivered a disproportionate commercial return: the brand commands a price premium in a commoditised smartphone market, earns consistent press coverage without a marketing budget, and retains customers who would otherwise churn to competitors. Their Net Promoter Score significantly outperforms category averages.
The mechanism is straightforward. A customer who can repair their own Fairphone trusts the brand more, not less. They spend money on replacement parts that Fairphone sells at healthy margins. And they tell other customers about it.
Repairability, executed well, is a loyalty programme with hardware attached.
France as the Leading Indicator
The French repairability index (indice de réparabilité) is the most useful signal for where UK and EU regulation is heading.
Since 2021, France has required manufacturers of smartphones, laptops, washing machines, lawnmowers, and televisions to display a repairability score — from 0 to 10 — on product packaging and retail listings. The score is calculated from five weighted criteria: the availability of documentation, the ease of disassembly, the availability of spare parts, the price of spare parts relative to product price, and manufacturer-specific commitments to repair.
Products scoring below 6/10 on the index are effectively disadvantaged in French retail. Procurement teams in the French public sector are beginning to use the score in purchasing criteria. Consumer awareness is growing.
The UK government's own consultations on extending Ecodesign requirements have explicitly referenced the French model as a potential template. The direction of travel is clear: repairability scores, or something equivalent, are coming to UK retail. Manufacturers who have not thought about their spare parts strategy as a product design decision — not just a logistics problem — will find themselves in a difficult position when scoring criteria are published.
The BrandedMark Angle: Scan Page as Right to Repair Portal
Here is where digital product identity and Right to Repair regulation converge.
The scan page on a BrandedMark-connected product is already the natural home for everything the Right to Repair framework requires: spare parts catalogue (model-specific, orderable directly), repair manuals (version-controlled, accessible on mobile), authorised repairer locator (postcode search, verified partners), and warranty status (live, not printed on a card that gets lost).
From a compliance perspective, this means a manufacturer can point to the scan page as their Right to Repair access point — it satisfies the documentation and parts availability obligations in a single, auditable, digital location.
From a commercial perspective, the spare parts revenue opportunity becomes dramatically larger when parts are discoverable at the moment the customer needs them — which is when they are standing next to the product with a problem. A customer who scans the QR code on a broken appliance and lands on a page that shows them the exact replacement part, priced fairly, with a delivery time, converts at a rate no email campaign can match.
This is the reframing that changes the economics of Right to Repair compliance: the spare parts catalogue on the scan page is not a legal obligation grudgingly fulfilled — it is a direct-to-consumer channel reaching customers at the highest-intent moment in the entire post-sale lifecycle.
For more on how manufacturers are building this channel, see our piece on Right to Repair obligations for UK manufacturers.
Turning the Legal Minimum into a Commercial Strategy
The manufacturers who will win the next decade of Right to Repair regulation are not the ones who comply at minimum cost. They are the ones who use the regulatory moment to restructure their aftermarket model.
Compliance requires spare parts to be available. A commercial strategy makes those parts easy to find, easy to order, and clearly better than third-party alternatives. The legal obligation gets you to the starting line. The experience you deliver from the scan page determines whether spare parts are a margin centre or a cost line.
John Deere's story shows the cost of treating customers as captive. Fairphone's story shows the upside of treating repairability as a brand promise. France's repairability index shows where the regulatory baseline is heading.
The question for every product manufacturer is not whether to comply with Right to Repair. The question is whether compliance is the ceiling of their ambition or the floor.
FAQ
What does the UK Ecodesign Regulation require for spare parts availability?
UK Ecodesign for Energy-Related Products Regulations 2021 requires manufacturers to supply spare parts to professional repairers within 15 working days of an order. Parts must remain available for 7–10 years after the last unit is placed on the market, depending on the product category. The regulation covers energy-related products including white goods, lighting, and certain electronics.
Does Right to Repair apply to small manufacturers?
The EU Right to Repair Directive and UK Ecodesign regulations apply to any manufacturer placing products on those markets, regardless of company size. However, smaller manufacturers typically face lighter administrative requirements than large-volume producers. The key obligation — spare parts availability to professional repairers — applies broadly, but the documentation and scoring requirements in France-style indices are initially focused on higher-volume consumer product categories.
How does France's repairability index affect product strategy?
France's indice de réparabilité requires a 0–10 repairability score on product packaging for smartphones, laptops, washing machines, lawnmowers, and TVs. Products scoring below 6/10 face retail disadvantages. The score is based on documentation availability, disassembly ease, spare parts availability, parts pricing, and manufacturer commitments. UK regulation is expected to follow a similar model, making spare parts strategy a product design decision, not just a compliance afterthought.