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Repair starts with words: An action plan for the EU Right to Repair

Brussels is turning "repairability" into a design, marketing, and after‑sales obligation. Here is a practical guide to getting your documentation up to scratch in 90 days.

Text by Scott Abel

Inhaltsübersicht

Image: © VladTeodor/istockphoto.com

The new European Right to Repair Directive  (EU) 2024/1799 complements earlier consumer‑protection and sustainability measures. If you are a tech writer in the EU creating manuals, online help, service guides, parts catalogs, or digital product passports, those pages now sit on the regulatory front line. Noncompliant documentation can block market access, trigger fines, or extend legal guarantees – none of which your employer wants.

Below, you find a plain‑language tour of the six legal instruments that matter most, the deliverables they touch, and concrete actions you can take this quarter.
 

1. Right to Repair Directive (EU) 2024/1799

Scope

This directive applies to every “repairable” good already covered by Ecodesign rules –phones, tablets, washing machines, dishwashers, vacuum cleaners, displays, and many more. EU member states must transpose by July 31, 2026.

Key documentation duties

RequirementWhat you must produce
European Repair Information Form (ERIF)A one‑page sheet listing repair costs, lead times, spare‑part prices, and warranty on the repair itself. The ERIF must be clear, accessible, and available before purchase in the buyer’s language.
Clear repair instructionsNo more “No user‑serviceable parts inside.” If disassembly is possible with common tools, the user guide must say so.
Warranty extension noticeWhen a consumer chooses repair over replacement, the legal guarantee is extended by 12 months. Include that statement in the warranty section.

 Tip: Keep the ERIF as a structured component (XML/DITA topic). You will need it in product pages, packaging inserts, and the EU’s upcoming online repair portal.

Read Directive 2024/1799 here.

 

2. Sale of Goods Directive (EU) 2019/771

This older but still essential directive obliges sellers to supply “necessary updates” – including security patches – for connected products throughout a “reasonable” period. Manuals and release notes therefore become legal proof that you:

  • Inform users how and when updates are delivered
  • Explain the consequences of refusing an update
  • Document any guarantee extensions after a repair

 Tip: Store that wording in a reuse‑ready snippet; you will insert it into every model’s quick‑start, PDF, and web‑help topic.

Read Directive 2019/771 here.

 

3. Ecodesign for Sustainable Products Regulation (EU) 2024/1781

Think of the ESPR as Ecodesign 2.0. It keeps the familiar product‑specific durability and repairability rules (accessible screws, spare‑part availability within 15 working days, etc.) but adds a Digital Product Passport (DPP) that travels with every product.

Documentation impact

  1. Service manuals for professionals must now be posted on a “free access website” within two years of a product’s market launch.

  2. DPP data will include disassembly steps, spare‑part codes, materials, and end‑of‑life guidance. Many organizations plan to feed that data straight from their CCMS – so map your topic metadata to the DPP schema now.

  3. If your product category already has a delegated Ecodesign act (e.g., Regulation (EU) 662/2024 covering smartphones), that act lists the exact pages, diagrams, torque specs, and file formats you must provide.

Read Regulation 2024/1718 here.

 

4. Batteries Regulation (EU) 2023/1542

From February 18, 2027, almost every portable battery must be “easily removable and replaceable by the end user.” Your manuals therefore need:

  • A step‑by‑step removal procedure that avoids heat or solvents
  • Clear safety warnings and recycling instructions
  • A statement of battery chemistry and capacity (label copy may point users to the full instructions)

Lack of a compliant battery‑removal section can prevent CE marking. CE marking is mandatory for many products sold in the European Economic Area. By affixing it, the manufacturer declares the product meets all applicable EU health, safety, and environmental requirements.

 Tip:  Don’t hide it in tiny diagrams – make it a numbered procedure, and localize it for every EU language market to which the product is shipped.

Find the Explainer about battery removability here.

 

5. Waste Electrical and Electronic Equipment (WEEE) Directive 2012/19/EU

WEEE hasn’t changed much since 2012, yet many companies still forget the documentation clause: Manufacturers must supply dismantling guides that recyclers can download free of charge. Required content:

  • Tools and time per disassembly step
  • Hazardous parts and how to remove them
  • End‑processing routes for batteries, PCBs, and plastics

If you already create service manuals, you can adapt that content, but remember, recyclers are not OEM‑authorized technicians – write for non‑experts.

Read Directive 2012/19/EU here.

 

6. Green claims & labelling

Two additional efforts are moving through the EU pipeline:

  1. Directive (EU) 2024/825 on empowering consumers for the green transition. It bans vague eco‑claims unless they are backed by recognized certification. Expect stricter wording in brochures and online help.
  2. EU Digital Services Act (already in force) makes marketplaces liable for illegal product listings, including fake repair claims. Your public‑facing docs will be scrutinized by both platforms and regulators.
     

Your 90‑day action plan

WeekTaskWhy it matters
1-2Map existing content against the six directives and regulations above. Flag missing ERIFs, battery procedures, and dismantling guides.Avoid fire‑drill rewrites when legal triggers (e.g., 2026 transposition) hit.
3-4Build a “repairability” metadata model in your CCMS (product, part, procedure type, DPP field).This lets you push the same snippet to manuals, ERIF, DPP, and websites without copy‑paste chaos.
5-6Draft an ERIF template and get legal sign‑off now; populate it with placeholder numbers if Bill of Materials data isn’t ready.The template alone satisfies auditors that you have a process in place.
7-8Create a battery‑removal topic with conditional text for end‑user vs. professional removal.Reuse for multiple models that share battery design.
9-10Publish a pilot dismantling guide as open HTML under a permissive license (e.g., CC BY).Demonstrates compliance to regulators and builds goodwill with the repair community.
11-12Run a terminology sprint: Standardize the verbs “remove,” “detach,” “disconnect,” etc., across repair topics.Consistency reduces translation cost and speeds updates.

Common pitfalls (and how to dodge them)

Avoid the following common mistakes:

  1. Treating the ERIF as marketing copy. The ERIF is a legal document; do not add colorful adjectives or cross‑sell links.

  2. Locking repair guides in PDF behind a paywall. The directives require “free access.” If you must gate, gate spare‑part sales, not the instructions.

  3. Embedding disassembly videos without transcripts. Accessibility rules still apply – supply alt text and step lists.

  4. Ignoring member‑state add‑ons. France’s repairability index and Germany’s stricter warranty rules already go beyond the EU baseline. Track national variations.

  5. Overlooking localization lead time. A 30‑language ERIF can blow past your print date – budget for early translation kicks.
     

Why technical writers are central

The Right‑to‑Repair is often framed as an engineering or legal problem, but writers sit at the intersection of both. Tech writers already translate engineering intent into user action and ensure language compliance. By adopting structured content, tight version control, and open‑access publishing, we can turn legislative burden into documentation leadership.

Put simply: We don’t just write the manual – we make the product legally sellable.

 

enlightened Read also: The Right to Repair – and what it means for tech writers