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Introduction
Forming part of the EU’s broader circular economy agenda, the Directive on common rules promoting the repair of goods (Right to Repair Directive) aims to extend product lifecycles by making repair a more attractive and accessible alternative to replacement. It complements other key sustainability measures, including the Ecodesign for Sustainable Products Regulation, which promotes product durability and repairability, and the Empowering Consumers for the Green Transition Directive, which strengthens consumer access to information on product durability and repairability.
The Directive entered into force on 30 July 2024 with member states required to transpose its provisions into national law by 31 July 2026. The Directive has now been given effect in Ireland through the European Union (Common Rules Promoting the Repair of Goods) (No. 2) Regulations 2026 (the Regulations), which came into operation on 31 July 2026. The Regulations introduce a new framework designed to make it easier for consumers to arrange for in scope goods to be repaired, thereby reducing waste and encouraging more sustainable patterns of consumption. Businesses operating in Ireland, or using it as a manufacturing or distribution hub, should now assess the potential impact of the legislation and consider whether changes to existing repair, warranty and customer service processes may be needed.
Scope
The Regulations do not create a general right to repair for all consumer goods. Instead, the repair obligation applies only to specific categories of products listed in Annex II of the Right to Repair Directive, namely those for which EU repairability requirements are already in place. These include mobile phones and tablets, washing machines, tumble dryers, fridges and freezers, vacuum cleaners, dishwashers, TVs and other electronic displays, space heaters, as well as a range of other products such as e-bikes, servers and welding equipment. The European Commission has indicated that Annex II will be reviewed and updated regularly, with the possibility of extending the repair obligation to further product categories in the future.[1]
The repair obligation applies primarily to manufacturers. To ensure that consumers can effectively exercise their repair rights where a manufacturer is not established in the EU, the Regulations introduce a cascading responsibility mechanism. A non-EU manufacturer must designate an authorised representative in the EU to fulfil the relevant obligations. Where no authorised representative has been appointed, responsibility passes to the importer and, failing that, to the distributor. Any of these parties may engage third party repair providers to discharge their obligations under the legislation.
Amendments to existing consumer legislation
The Right to Repair Directive amends existing EU legislation on the sale of goods, and the Regulations give effect to those changes in Ireland through amendments to the Consumer Rights Act 2022. While the Directive primarily imposes obligations on manufacturers, namely the persons or companies that manufacture a product and market it under their own name or trademark,[2] the amendments to existing consumer law also affect sellers, being the persons or companies that sell goods to consumers in the course of their business.[3]
Consumers will continue to have a choice between repair and replacement for defective goods, and sellers must inform consumers of that choice. Where repair is selected, it must be carried out free of charge, within a reasonable period and without significant inconvenience to the consumer.
During the repair process, sellers may offer consumers a loan replacement free of charge, including a refurbished product. Where a consumer chooses replacement rather than repair, sellers may provide a refurbished replacement instead of a new product, provided the consumer expressly agrees.
Businesses should review warranty wording, returns procedures, customer service scripts, repair pathways and systems for tracking limitation or liability periods.
Key elements of this legislation
The obligation to repair
The legislation promotes repair both during and after the legal guarantee period. However, the manufacturer's repair obligation only applies where a defect occurs or becomes apparent after the seller's liability has expired. In Ireland, consumers generally have up to six years to pursue a claim against the seller for defective goods.
Where a product falls within the scope of the legislation and can be repaired, the manufacturer must provide a repair at the consumer's request. Depending on the circumstances, the repair must be carried out either free of charge or at a reasonable cost, and within a reasonable timeframe. Manufacturers may fulfil this obligation themselves or through subcontracted repair providers.
For businesses, this means repair cannot be treated solely as an optional after-sales service. Manufacturers should ensure they have the necessary operational capacity, repair infrastructure, pricing models and customer service processes in place to manage and respond effectively to consumer repair requests. Manufacturers established outside the EU should also ensure that any authorised representative, importer or distributor that may assume responsibility for compliance is aware of these obligations.
Spare parts, tools and restrictions on repair
Manufacturers of in scope products must make spare parts and repair tools available at reasonable prices that do not discourage repair. They must not impede repair through contractual terms, hardware measures, software restrictions or other practices unless such measures are objectively justified. They may not refuse to repair a product solely because a previous repair was carried out by an independent repairer or other third party. Similarly, manufacturers may not prevent the use of compatible, second hand or certain 3D printed spare parts where those parts comply with applicable legal and safety requirements.
Businesses should therefore review spare parts availability, pricing, software locks, design features, warranty conditions and repair network rules to identify any barriers that could be viewed as creating unreasonable barriers to repair.
Standardised and clear information about repair services
The legislation introduces a voluntary European Repair Information Form, which repairers (including manufacturers, sellers and independent repair service providers that offer repair services in the course of business) may provide to consumers before a repair is agreed. The form must be provided free of charge unless a diagnostic service is required, in which case the consumer must be informed of the diagnostic fee in advance. Any such fee may subsequently be deducted from the repair price.
The form should contain key information including the repairer's identity and contact details, a description of the product and defect, the proposed repair, repair costs, the estimated repair timeframe, the availability of a replacement product during repair, and any related services such as collection, transport, removal or installation. Where the form is provided, the information it contains will be binding on the repairer for at least 30 days.
Separately, businesses subject to repair obligations will need to ensure that consumers can readily access information about their repair services. In particular, they must publish indicative repair pricing on a freely accessible website and make available clear and easily accessible information on the products covered by the repair obligation, the scope of that obligation and how repair services are provided, including through subcontracted repair providers. This is likely to require updates to websites, customer-facing materials, warranty documentation and after-sales support processes.
Businesses offering repair services may therefore wish to use the European Repair Information Form alongside clear online and customer facing repair information to improve transparency and enable consumers to compare repair options more easily.
European Online Repair Platform
The Right to Repair Directive also provides for a new European Online Repair Platform, which will be established as an extension of the EU's “Your Europe” portal. This will help consumers identify repairers, access repair information and request a European Repair Information Form where available. The platform will have sections for each EU country. While participation will be voluntary, repair businesses may benefit from registering, as the platform could increase their visibility among consumers seeking repair services.
The European Commission will be responsible for establishing and maintaining the platform, while member states will determine the registration criteria and administer the registration of repairers in their respective jurisdictions. The platform is expected to become operational in 2027. The existing RepairMyStuff.ie website will provide the basis for Ireland’s national repair platform. The Minister for Enterprise, Trade and Tourism in consultation with the Minister for Climate, Energy and the Environment, will be responsible for bringing the national platform into compliance with the Directive’s requirements by 31 July 2027.
Consequences of non-compliance
The Competition and Consumer Protection Commission may take enforcement action for breaches of the Regulations, including issuing compliance notices. Non-compliance can lead to criminal sanctions, significant fines and imprisonment. Breaches may be the subject of representative actions brought by qualified entities on behalf of consumers.
Next steps
With the Irish implementing measures now in force, businesses should consider whether this legislation applies to their operations. Companies placing consumer goods on the Irish or wider EU market should assess whether any products fall within the categories listed in Annex II and consider the impact of the new repair requirements on their operations. Developments will need to be monitored as the scope of products covered by the legislation is likely to expand over time.
These measures mark a further shift from a linear “take, make, dispose” model towards a more circular economy, in which products are designed, supported and used for longer. For businesses, repairability is becoming not only a consumer law obligation, but an increasingly important part of their circularity strategies.
For further information in relation to this topic, please contact Jill Shaw, ESG & Sustainability Lead, Erin Ward, Solicitor, or any other member of the ALG ESG & Sustainability team.
Date published: 6 August 2026
[1] Annex II has already been amended by Commission Delegated Directive (EU) 2026/74.
[2] ‘Manufacturer’ means any natural or legal person that manufactures a product or that has a product designed or manufactured, and markets that product under their name or trademark – Article 2, point (42), of Regulation (EU) 2024/1781.
[3] ‘Seller’ means any natural person or any legal person, irrespective of whether privately or publicly owned, that is acting, including through any other person acting in that natural or legal person's name or on that person's behalf, for purposes relating to that person's trade, business, craft or profession, in relation to contracts covered by this Directive – Article 2, point (3), of Directive (EU) 2019/771
