The EU Right to Repair is now law: what it actually obliges robot makers to do
After-sales is no longer a differentiator—it is a legal duty
As of 31 July 2026, Directive (EU) 2024/1799 is in force across the European Union. For robot manufacturers—whether they make industrial arms, service robots, or agricultural drones—the era of treating after-sales as a discretionary competitive edge is over. The directive transforms repair and maintenance from a marketing promise into a binding legal obligation. This article breaks down the concrete requirements, compares them with common industry practice, and highlights what remains uncertain at the national level.
What the directive actually says
The directive, formally Directive (EU) 2024/1799 on common rules promoting the repair of goods, was published in the Official Journal and entered into force on 31 July 2026. It applies to a broad range of goods, including electronics and, by extension, robots. The core obligations for manufacturers are:
- Repair obligation: Manufacturers must offer repair for products that are technically repairable under EU law. This is not optional; it is a legal requirement.
- Spare parts availability: Manufacturers must make spare parts available for a defined period after the sale. The directive specifies that parts must be available for at least 7 years from the date of purchase for certain categories, though the exact duration may vary by product type.
- Repair information: Manufacturers must provide access to repair and maintenance information, including diagrams, manuals, and diagnostic tools, to professional repairers and, in some cases, to consumers.
- Indicative repair pricing: Manufacturers must offer indicative prices for common repairs. This is not a price cap, but a transparency measure so consumers can compare repair costs with replacement costs.
- Obligations running after sale: The obligations do not end at the point of sale. They extend throughout the product’s lifecycle, meaning manufacturers must plan for long-term support.
Spare parts: the 7-year rule
One of the most concrete requirements is the spare parts obligation. Under the directive, manufacturers must ensure that spare parts are available for a minimum of 7 years after the last unit of a model is placed on the market. This is a significant extension compared to typical industry practice, where parts are often stocked for 3-5 years. For robot makers, this means maintaining inventory for components such as motors, sensors, and control boards for nearly a decade.
The directive also requires that spare parts be delivered within a reasonable time, though the exact timeframe is not specified in the directive itself—it is left to national legislation. This is a point of uncertainty: what is ‘reasonable’ in one member state may differ in another.
Repair information: opening the black box
Manufacturers must provide repair information to professional repairers and, in some cases, to consumers. This includes access to technical documentation, software updates, and diagnostic tools. For robots, which often rely on proprietary software and calibration, this is a major shift. Currently, many manufacturers restrict such information to authorized service centers. The directive forces a more open approach, though it does not require full open-source disclosure—only what is necessary for repair.
The European Commission’s guidance on the directive (available at commission.europa.eu) emphasizes that repair information should be provided at a fair and reasonable cost, but it does not mandate free access. This means manufacturers can charge for manuals or diagnostic software, but the price must be reasonable and not prohibitive.
Indicative repair pricing: transparency, not price control
Manufacturers must publish indicative prices for common repairs. This is a transparency measure designed to help consumers make informed choices. For example, a robot maker might list that replacing a gripper costs €500, while a full motor replacement costs €1,200. These prices are not binding, but they must be realistic and based on typical repair scenarios.
This requirement is likely to be challenging for manufacturers who currently operate with opaque pricing structures. It also creates a benchmark that could be used in legal disputes if a final invoice significantly exceeds the indicative price.
Obligations that run after sale
The directive makes clear that the manufacturer’s obligations do not end at the point of sale. They extend for the entire period during which the product is expected to be used. For robots, which are often capital equipment with a lifespan of 10+ years, this means that manufacturers must be prepared to support products long after the initial sale. This includes not only spare parts and repair information but also software updates that are necessary for the product to function correctly.
This long-term obligation has significant implications for business models. Manufacturers can no longer discontinue support for older models without legal consequences. They must also ensure that their supply chains are resilient enough to provide parts for years, even if the original suppliers change.
Comparison: directive requirement vs common practice
| Aspect | Directive requirement | Common practice before 2026 |
|---|---|---|
| Spare parts availability | Minimum 7 years after last sale | Typically 3-5 years, often shorter for electronics |
| Repair information access | Must be provided to professional repairers and consumers | Restricted to authorized service centers |
| Indicative repair pricing | Must be published for common repairs | Pricing often opaque, quoted on request |
| Obligation duration | Extends beyond sale, for product’s expected lifespan | Often limited to warranty period (1-2 years) |
What this means for robot makers
For robot manufacturers, the directive is a game-changer. It forces them to invest in after-sales infrastructure, including parts inventory, documentation, and repair networks. This is particularly challenging for Chinese manufacturers entering the European market, who may not have established service networks in the EU. The directive applies to any manufacturer selling in the EU, regardless of origin, so compliance is mandatory.
One practical implication is the need to appoint an authorized representative in the EU who can handle repair obligations. This is a common practice for other EU regulations, such as the CE marking, but now it extends to after-sales.
Another implication is the need to redesign products for repairability. While the directive does not explicitly require design for repairability, it is a de facto requirement because if a product is not repairable, the manufacturer cannot meet the repair obligation. This may lead to modular designs and the use of standard fasteners instead of glue.
Uncertainties and national variations
The directive sets a minimum standard, but member states can implement stricter rules. For example, some countries may extend the spare parts period beyond 7 years or require that repair information be provided free of charge. Manufacturers must monitor the transposition laws in each EU country where they sell.
There is also uncertainty about the definition of ‘technically repairable’. The directive refers to products that are ‘technically repairable under EU law’, but this is not fully defined. It is likely that a product is considered repairable if it is possible to replace key components without damaging the product. However, this will be clarified through case law and national guidance.
Finally, the directive does not specify penalties for non-compliance. Each member state will set its own sanctions, which could range from fines to bans on selling the product. This creates a patchwork of enforcement that manufacturers must navigate.
Practical steps for compliance
To comply with the directive, robot makers should take the following steps:
- Conduct a repairability assessment of all products sold in the EU.
- Establish a spare parts inventory plan that covers at least 7 years.
- Prepare repair documentation and make it available to professional repairers.
- Publish indicative prices for common repairs on the product’s webpage or in the user manual.
- Set up a network of repair partners or an in-house service team that can handle repairs across the EU.
For manufacturers without an EU presence, partnering with a local service network being set up, such as Robanchor, can help meet these obligations. Robanchor is a certified technician network being assembled to provide after-sales, maintenance, and spare parts services for Chinese robotics manufacturers. While not yet a registered entity, it aims to offer a turnkey solution for compliance.
Conclusion
The EU Right to Repair directive is now law, and robot makers must adapt. The days of treating after-sales as a differentiator are over; it is now a legal duty. By understanding the concrete requirements—spare parts, repair information, indicative pricing, and long-term obligations—manufacturers can turn compliance into a competitive advantage. The key is to act now, before national transpositions add further complexity.
Sources
- EUR-Lex — Directive (EU) 2024/1799 — https://eur-lex.europa.eu/eli/dir/2024/1799/oj (accessed 2025-09-15)
- European Commission — Repair of goods — https://commission.europa.eu/ (accessed 2025-09-15)