Right to Repair and Your Warranty Strategy
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 and the EU Right to Repair Directive 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?
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, and the parts must remain available for a defined period after the last unit is placed on the market. The exact availability window varies by product category. You should confirm the precise obligations that apply to your own products against the current regulations and official guidance.
The EU Right to Repair Directive (Directive (EU) 2024/1799), which was adopted in 2024 and moves into phased implementation as member states transpose it, goes further in scope. It covers a broader product range, introduces a right for consumers to request repairs over replacements in certain circumstances, and supports a European repair information platform.
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 Repair Lock-In Cautionary Tale
Few strategic mistakes illustrate the risk of getting repair strategy wrong as clearly as the agricultural-equipment repair lock-in controversy, which became one of the defining flashpoints of the Right to Repair movement. The most documented example is John Deere, whose practices the US Federal Trade Commission and several state attorneys general challenged in a January 2025 lawsuit alleging it restricted farmers' access to the diagnostic tools needed to repair their own machines.
The pattern at the centre of these disputes is software-based repair restriction: replacing a sensor or a component can trigger an error code that only an authorised dealer's diagnostic software can clear, so an owner whose machine breaks down at a critical moment is dependent on a dealership that might be days away.
The commercial logic was clear: lock in service revenue, protect dealer margins, and keep third-party parts out of the supply chain. In the short term, it worked.
The backlash was severe and enduring. Farmer and owner groups in the US and Europe mobilised around Right to Repair legislation, and lock-in became a byword for corporate overreach in affected communities. Under regulatory, legislative and legal pressure, manufacturers including John Deere have moved toward providing independent repair tooling, a shift extracted through years of reputational and legal friction.
The lesson is not that repair lock-in is impossible to execute. It is that the brand damage when it unravels can be disproportionate to the service revenue it was meant to protect. Customers who feel trapped by a warranty strategy can become vocal critics. Customers who feel supported by one can become advocates.
The Repairability-As-Brand Inspiration
A growing group of manufacturers has taken the opposite approach and turned repairability into a brand asset.
The pattern is consistent. Products are designed so that common components can be replaced by the user with ordinary tools. Spare parts are sold directly through the manufacturer's own channel at transparent prices. Repair guides are published openly and written to be genuinely useful. Much of this goes well beyond any legal minimum.
The reasoning is straightforward. A customer who can repair their own product can come to trust the brand more, not less. They may buy replacement parts that the manufacturer sells at healthy margins. And they tell other customers about it. Whether any individual brand sees a price premium or higher loyalty depends on its market, so treat these as plausible mechanisms to test rather than guaranteed outcomes.
Repairability, executed well, can act like a loyalty programme with hardware attached.
France as the Leading Indicator
The French repairability index (indice de réparabilité) is a useful signal for where UK and EU regulation may be heading.
France requires manufacturers of several consumer product categories, including smartphones, laptops, and washing machines, to display a repairability score on a published scale on product listings. The score is calculated from weighted criteria covering matters such as the availability of documentation, the ease of disassembly, the availability of spare parts, and the price of spare parts relative to the product. You can confirm the current categories, scale, and criteria in the official French scheme documentation.
Products that score poorly on the index can be disadvantaged in French retail, and awareness of the score among buyers has been growing. UK government consultations on extending Ecodesign requirements have referenced the French model as a potential template. The direction of travel looks clear: repairability scores, or something equivalent, may well come to UK retail. Manufacturers who have not thought about their spare parts strategy as a product design decision, rather than just a logistics problem, could find themselves exposed 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 a natural home for much of what the Right to Repair framework requires: a model-specific spare parts catalogue that is orderable directly, repair manuals that are version-controlled and accessible on mobile, an authorised repairer locator with postcode search and verified partners, and live warranty status rather than a card that gets lost.
From a compliance perspective, this means a manufacturer can use the scan page as a Right to Repair access point that helps satisfy documentation and parts-availability obligations in a single, auditable, digital location. It can contribute to your compliance posture, though you should still map it against the specific obligations that apply to your products.
From a commercial perspective, the spare parts revenue opportunity grows 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 the exact replacement part, priced fairly, with a delivery time, is reached at a moment of unusually high intent. Understanding this dynamic is central to building a connected product aftersales playbook that drives both compliance and revenue.
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 can be a direct-to-consumer channel reaching customers at a high-intent moment in the post-sale lifecycle.
For more on how manufacturers can build 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 do best with the next decade of Right to Repair regulation are unlikely to be the ones who comply at minimum cost. They are more likely to be 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. For product managers and service leaders looking to quantify the financial opportunity, see our analysis of right-to-repair as a competitive advantage for manufacturers.
The lock-in cautionary tale shows the cost of treating customers as captive. The repairability-as-brand approach shows the upside of treating repairability as a brand promise. France's repairability index shows where the regulatory baseline may be 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?
The UK Ecodesign for Energy-Related Products Regulations require manufacturers of in-scope energy-related products to supply spare parts to professional repairers within a defined timeframe of an order, and to keep parts available for a defined period after the last unit is placed on the market. The exact timeframe and availability window depend on the product category, so you should confirm the requirements that apply to your products against the current regulations and official guidance.
Does Right to Repair apply to small manufacturers?
The EU Right to Repair Directive and UK Ecodesign regulations apply to manufacturers placing in-scope products on those markets, regardless of company size. Some obligations may be applied differently for smaller producers, and documentation or scoring requirements such as France-style indices have initially focused on higher-volume consumer product categories. The core obligation, spare parts availability to professional repairers, applies broadly. Confirm your specific position against current official guidance.
How does France's repairability index affect product strategy?
France's indice de réparabilité requires a repairability score to be displayed on product listings for several consumer categories, including smartphones, laptops, and washing machines. The score reflects criteria such as documentation availability, ease of disassembly, spare parts availability, and parts pricing. Products that score poorly can face retail disadvantages. UK regulation may follow a similar direction, which would make spare parts strategy a product design decision rather than a compliance afterthought.
BrandedMark is the Product Operating System for manufacturers of physical goods: serialised product identity, connected experiences, warranty registration, and Digital Product Passport readiness in one platform. See how it works at brandedmark.com.