EGMF-EPTA comments regarding the draft IMCO Rapporteur report on the Common rules promoting the repair of goods Directive

EGMF and EPTA welcome the initiative to promote repair and manufacture products that are long-lasting and repairable by design. We also support the harmonisation of measures on repairability to prevent further proliferation of national rules. However, we would like to underline that there are several aspects that need to be taken into account by the European Parliament, IMCO, and MEPs working on the legislative file.

• Scope: we strongly urge the final report to follow the Europe Commission’s approach to reference and build the scope on already existing or legislation such as Ecodesign, to ensure that the selected product have been subject of impact assessment and consultation with stakeholders. Unless there is specification of the product categories that are under the umbrella of the legislation, there would be massive regulatory overlaps and uncertainty. We also stress that B2C and B2B products need to be viewed differently, and the initiative should focus on the products that cannot be currently repaired, or have a very short lifetime.
• Independent repairers and consumers: we alert that repairs executed by people that are not qualified for electrical and electronic equipment, pose serious safety issues. Therefore, we believe that a horizontal one-size-fits-all approach to repair, access to repair information and spare parts of all products, and especially to consumers, should be avoided and specialists should be consulted in which cases that could be viable.
• Repair duration limit and loan: the proposed deadline of 15 calendar days and providing loans is not reasonable for many types of equipment, as it would require the manufacturer to keep a huge inventory of spare parts and whole products, which would put in jeopardy many repairers and dealer networks.
• Extended guarantee period after first repair: extending the liability period with an additional two years from the moment of repair is unfair to manufacturers, putting excessive burden to repair parts on which the original liability period has expired.

Download the paper here.