Spare parts pricing under the Right to Repair: the ‘reasonable price’ problem

The ‘reasonable price’ obligation is a legal blank check

Directive (EU) 2024/1799, the EU’s Right to Repair directive, requires manufacturers to offer spare parts at a ‘reasonable price’ for products covered by ecodesign rules. But the directive does not define ‘reasonable’. It leaves the term open to interpretation, creating a compliance grey zone that is already causing headaches for manufacturers and service providers entering the European market. For a Chinese robotics manufacturer setting up after-sales operations in Europe, the practical question is not whether to comply, but how to price parts in a way that satisfies regulators, wins customer trust, and avoids disputes that can escalate into legal or reputational damage.

The directive, adopted in 2024, mandates that spare parts be available for at least 10 years after the last unit of a model is placed on the market, and that they be supplied at a ‘reasonable price’ that does not deter repair. The European Commission’s guidance on repair pricing transparency (available on its website) emphasises that consumers should be able to obtain repair services without excessive cost. Yet neither the directive nor the guidance provides a formula or benchmark. This ambiguity is not an oversight; it is a deliberate flexibility that allows member states to interpret the term within their own legal traditions. But for a manufacturer, this means that a price considered reasonable in Germany might be challenged in Poland, and what is acceptable for a consumer drone may be unreasonable for an industrial robot.

What ‘reasonable’ means in practice: cost-plus, market parity, or something else?

In the absence of a statutory definition, manufacturers and service networks typically adopt one of three pricing strategies:

• Cost-plus pricing: Adding a fixed margin to the manufacturing cost of the part. This is transparent but can be distorted by allocation of overheads, and it may not reflect market value.
• Market-parity pricing: Setting prices in line with comparable parts from other manufacturers or independent suppliers. This requires continuous market monitoring and can be difficult for proprietary parts.
• Value-based pricing: Charging what the market will bear, often justified by the part’s criticality or the cost of downtime. This is the most opaque and the most likely to be challenged as ‘unreasonable’.

Each approach has merits, but the directive’s intent is clear: the price must not deter repair. A part that costs €500 to manufacture but is priced at €2,000 because the robot is down and the customer has no alternative is likely to be seen as unreasonable. Conversely, a part priced below cost might be seen as anti-competitive or as a loss-leader that undermines independent repairers. The ‘reasonable price’ is therefore not a single number but a range that depends on the product category, the part’s complexity, and the competitive landscape.

Opaque pricing creates compliance and trust risks

When manufacturers keep spare parts pricing opaque, they expose themselves to several risks:

• Regulatory risk: National enforcement authorities may investigate complaints about excessive prices, leading to fines or mandatory price reductions. The directive requires member states to establish penalties for non-compliance, and these can be substantial.
• Litigation risk: Consumers or business customers may sue for breach of the directive, especially if the price forces them to scrap a product. Class actions are rare in Europe but not impossible.
• Reputational risk: In an era of social media, a single viral complaint about a €1,000 spare part for a €2,000 robot can damage a brand’s image across the EU.
• Operational risk: Opaque pricing complicates the work of service networks, which need to quote prices quickly. If a technician cannot explain why a part costs what it does, customer trust erodes.

Transparent pricing, on the other hand, builds trust and reduces friction. It also aligns with the directive’s spirit and with the Commission’s push for repair-friendly business models. A manufacturer that publishes a clear price list, with justifications for high-value parts, is less likely to face complaints and more likely to be seen as a responsible market player.

Comparison: opaque vs transparent parts pricing

Practical steps for manufacturers and service networks

For a Chinese robotics manufacturer entering Europe, the ‘reasonable price’ problem is not just a legal issue; it is a business strategy issue. Here are concrete steps to mitigate risk:

1. Conduct a pricing audit: For each spare part, calculate the true cost (materials, labour, logistics, customs) and compare it with market benchmarks. Identify parts where your price exceeds a 100% margin, as these are the most vulnerable to challenge.
2. Publish a price list: Make the list available on your website and to your service network. Update it regularly. This transparency is a strong defence against claims of unfair pricing.
3. Document the rationale: For parts with high prices, prepare a brief justification (e.g., low volume, complex manufacturing, long shelf life). This documentation can be shared with regulators if needed.
4. Offer tiered pricing: For business customers, consider volume discounts or service contracts that include parts. This can make high prices more palatable.
5. Monitor national interpretations: Since the directive is transposed into national law, each member state may define ‘reasonable’ differently. Work with local legal counsel to stay compliant in each market.
6. Leverage a local service network: A certified technician network being assembled in Europe can provide on-the-ground feedback about price sensitivity and help you adjust pricing before problems escalate.

The role of a local service network

For a manufacturer without a European footprint, navigating the ‘reasonable price’ requirement is daunting. A local service network, such as the one being set up by Robanchor, can act as an intermediary. It can help you understand local market expectations, benchmark your prices against competitors, and handle customer complaints before they reach regulators. By partnering with such a network, you gain not only compliance expertise but also a reputation for being a responsive and responsible player in the EU market.

However, it is important to note that Robanchor is not yet a registered entity; it is a local service network being set up. Any claims about its capabilities should be verified. But the concept is sound: a network of certified technicians who understand both the technical and commercial aspects of spare parts can be invaluable.

Conclusion

The ‘reasonable price’ problem is not a puzzle with a single solution. It is a balancing act between profitability and fairness, between legal compliance and customer satisfaction. The directive gives manufacturers flexibility, but with that flexibility comes responsibility. Those who embrace transparency, document their pricing logic, and adapt to national interpretations will thrive. Those who rely on opacity will face regulatory scrutiny, customer backlash, and ultimately a weaker position in the European market. The time to act is now, before the first complaint lands on a regulator’s desk.

Sources

• EUR-Lex — Directive (EU) 2024/1799 — https://eur-lex.europa.eu/eli/dir/2024/1799/oj (accessed 2025-10-20)
• European Commission — Repair of goods — https://commission.europa.eu/ (accessed 2025-10-20)