Repair documentation: the manuals, diagrams and part lists the law now requires

When the EU’s Right to Repair Directive (EU) 2024/1799 entered into force, it did more than extend consumer warranties. It created a legal obligation for manufacturers to provide repair information to professional repairers and, in some cases, to consumers. At the same time, the Machinery Regulation (EU) 2023/1230, which applies from 20 January 2027, tightens the technical documentation requirements for machinery. Together, these two legal instruments define what repair documentation must contain, who must have access to it, and how it must be delivered. For Chinese robotics manufacturers entering the European market, this is not a matter of best practice—it is a compliance requirement with concrete legal consequences.

This article explains the specific documents you must prepare, the audiences you must serve, and the practical steps to align your documentation with EU law. It is written for engineers, compliance managers, and executives who need a clear, actionable overview. The focus is on the legal obligations, not on marketing or theory.

What the Right to Repair Directive requires

The Right to Repair Directive (EU) 2024/1799, which entered into force on 30 July 2024 and must be transposed into national law by 31 July 2026, establishes a framework for repair. Its core requirement is that manufacturers must make repair information available to professional repairers and, for certain products, to consumers. The directive applies to a wide range of goods, including consumer electronics, home appliances, and—importantly for robotics—machinery that falls under its scope.

Under Article 5 of the directive, manufacturers must provide access to repair information on fair, reasonable, and non-discriminatory terms. This includes:

Repair manuals that describe the repair procedures step by step, including disassembly and reassembly instructions.
Wiring diagrams and electrical schematics that show the connections between components.
Part lists with the part numbers and, where applicable, the spare part availability.
Diagnostic information such as error codes, fault trees, and software updates necessary for repair.

The directive distinguishes between professional repairers and consumers. Professional repairers must be given access to the full repair information, often through a secure online portal. Consumers, on the other hand, are entitled to a more limited set: typically the repair manual and part list, but not necessarily the detailed wiring diagrams or proprietary diagnostic software. The exact scope for consumers is defined in the product-specific implementing acts that the European Commission is expected to adopt.

It is important to note that the directive does not require manufacturers to give consumers access to all technical documentation. The line is drawn at what is necessary for a competent consumer to perform a safe repair. For complex robotics, this may be very limited, but the obligation to provide some information to consumers is real.

Machinery Regulation: technical documentation as a legal requirement

The Machinery Regulation (EU) 2023/1230, which will apply from 20 January 2027, replaces the Machinery Directive 2006/42/EC. It applies to machinery, including robots, and sets out essential health and safety requirements. One of its key provisions is the obligation to compile technical documentation before placing a product on the market. This documentation must demonstrate that the machinery complies with the regulation and must include:

A description of the machinery and its intended use.
Drawings, diagrams, and descriptions necessary for the understanding of the machinery, including the control system.
The results of tests and examinations carried out to verify compliance.
The instructions for use, which must include information on maintenance and repair.

While the Machinery Regulation is primarily about safety and CE marking, its technical documentation requirements overlap with repair information. The instructions for use must include sufficient detail for a qualified person to carry out maintenance and repair safely. This is where the wiring diagrams and part lists become legally relevant: without them, a repairer cannot safely disassemble and reassemble the machinery.

For robotics, the technical documentation must also cover the software and control systems. This is a significant challenge, as many robots rely on proprietary software that is not easily documented. However, the regulation requires that the documentation be sufficient to understand the logic of the control system, which implies that the manufacturer must provide at least a functional description and, where relevant, the interfaces for diagnostics.

Who must have access to what: a comparison

To clarify the obligations, the table below compares the types of documentation, the legal basis, and the primary audience.

Document type	Legal obligation	Primary audience
Repair manual (step-by-step procedures)	Right to Repair Directive (Art. 5)	Professional repairers; consumers (limited)
Wiring diagrams / electrical schematics	Right to Repair Directive; Machinery Regulation (technical documentation)	Professional repairers; qualified technicians
Part list with part numbers	Right to Repair Directive (Art. 5)	Professional repairers; consumers
Diagnostic information (error codes, software)	Right to Repair Directive (Art. 5)	Professional repairers
Technical documentation for CE marking	Machinery Regulation (Art. 10, Annex I)	Notified bodies, market surveillance authorities
Instructions for use (including maintenance)	Machinery Regulation (Annex I, Section 1.7)	End users, operators, repair personnel

This table is a simplification. The exact obligations for consumers under the Right to Repair Directive will be specified in delegated acts, and the Machinery Regulation’s technical documentation is not the same as repair information. However, the table gives a practical overview of what you need to prepare.

Practical steps for manufacturers

To comply with both legal frameworks, a manufacturer should take the following steps:

Audit existing documentation. Identify what repair manuals, wiring diagrams, and part lists already exist. Many manufacturers have internal service documentation that can be adapted.
Create a repair information package. This should include a repair manual, wiring diagrams, part list, and diagnostic information. The level of detail must be sufficient for a professional repairer to perform repairs without special proprietary knowledge.
Set up an access mechanism. The Right to Repair Directive requires that repair information be accessible on fair, reasonable, and non-discriminatory terms. This often means a secure online portal with registration for professional repairers. The terms must be transparent and not impose excessive costs.
Align with the Machinery Regulation. Ensure that the technical documentation for CE marking includes the necessary diagrams and descriptions. The instructions for use must include maintenance and repair information that is consistent with the repair manual.
Plan for updates. Both laws require that repair information be kept up to date. If you make a design change that affects repairability, you must update the documentation and notify repairers.

It is wise to involve a local service network, such as a certified technician network being assembled in Europe, to validate the documentation and provide feedback on its usability. This can also help you meet the requirement to make repair information available in the official languages of the member states where the product is sold.

What varies by country and what to verify

The Right to Repair Directive is a directive, not a regulation, so it must be transposed into national law. This means that the exact implementation may vary from one EU member state to another. For example, some countries may impose penalties for non-compliance, while others may rely on market surveillance. The directive sets minimum requirements, but member states can go further, for instance by extending the scope or requiring that spare parts be available for a longer period.

It is essential to monitor the transposition in the countries where you sell. The European Commission maintains a database of national measures, but the most reliable source is the national legislation itself. As of the date of this article (August 2026), the transposition deadline is 31 July 2026, and many countries are still in the process. You should verify the specific obligations in each market.

Similarly, the Machinery Regulation applies directly in all member states from 20 January 2027, but there are transitional provisions. Machinery that complies with the old Machinery Directive and is placed on the market before that date can continue to be sold. After that date, the new regulation applies. You need to plan your documentation accordingly.

Conclusion

Repair documentation is no longer an afterthought. The Right to Repair Directive and the Machinery Regulation impose clear obligations on manufacturers to produce and share repair information. For Chinese robotics manufacturers, this is an opportunity to build trust with European customers and repair networks. By preparing comprehensive repair manuals, wiring diagrams, and part lists, and by making them accessible through a fair system, you can turn a legal requirement into a competitive advantage.

The key is to act now. The legal deadlines are approaching, and the documentation effort should not be underestimated. Start with an audit, build the package, and test it with professional repairers. The investment will pay off in compliance, customer satisfaction, and a stronger position in the European market.

Sources

EUR-Lex — Directive (EU) 2024/1799 — https://eur-lex.europa.eu/eli/dir/2024/1799/oj (accessed 2026-03-29)
EUR-Lex — Regulation (EU) 2023/1230 — https://eur-lex.europa.eu/eli/reg/2023/1230/oj (accessed 2026-03-29)