Right to Repair and the Digital Product Passport: How Responsibility, Repairability and Product Data Converge

Last Updated on 30. January 2026

For many years, repair was often the less attractive option in everyday life. Spare parts were unavailable, repairs were expensive or organisationally complex, and information about the structure or maintenance of products was difficult to access. For consumers, buying new products was often the easier choice – even when a defect could technically have been fixed with little effort.

With the new EU-wide Right to Repair, this principle is set to change fundamentally. Repair is no longer treated as a voluntary service, but as an enforceable right. At the same time, the digital product passport introduces a new obligation to provide product information in a structured way. Both regulatory frameworks are closely linked and mark a fundamental shift: responsibility for products no longer ends at the point of sale, but extends across their entire lifecycle.

The EU-wide Right to Repair was adopted in 2024 and must be implemented by the Member States. Application is currently expected from 2026 onwards, depending on national implementation.

What the Right to Repair in the EU changes

The Right to Repair significantly strengthens the position of consumers. In the future, they can request that products be repaired instead of automatically replaced. If they choose repair within the statutory warranty period, the warranty is extended accordingly. Repair is therefore legally prioritised.

At the same time, the EU reorganises responsibility – and does so in a way that makes it enforceable. Responsibility for reparability does not lie with an abstract “manufacturer”, but with the respective economic operator within the EU legal area. If the manufacturer is based outside the EU, these obligations are transferred to the importer. This party must ensure that repairs are technically possible, that spare parts remain available for defined periods, and that the necessary repair information is provided. Products must not be deliberately designed in a way that effectively prevents repair.

Retailers and sellers bear an additional responsibility. They must transparently inform consumers about repair options and must not obstruct or effectively prevent repairs through unclear responsibilities, missing information or non-transparent processes. Reparability thus becomes a shared obligation along the distribution chain.

Who is responsible: manufacturer, importer and placing on the market

The regulatory frameworks clearly distinguish roles and responsibilities. Under the Right to Repair, obligations apply to the actor that can be held accountable within the EU legal framework. Where manufacturers are based outside the EU, importers assume these responsibilities.

In this way, the European Union deliberately shifts responsibility to the market actor that can be regulated and enforced.

Why repair has so far been economically unattractive

In practice, repair has so far failed primarily due to economic factors. For manufacturers and retailers, it has long been more profitable to sell new products than to repair existing ones. Repair processes are complex, difficult to scale and often more expensive than replacing a product with a new device. This economic logic has systematically made reparability unattractive.

Missing or inaccessible product information further exacerbates this imbalance. If it is unclear which components are installed, which spare parts are compatible or which repairs are intended, time and costs increase even further. Repair therefore becomes not only technically, but above all economically unattractive – even when it would in principle be possible.

The digital product passport – briefly explained

The digital product passport is part of the new EU Ecodesign Regulation for Sustainable Products (ESPR) and a central instrument of the European circular economy strategy. It is intended to ensure that products become more transparent, more repairable and easier to reuse and recycle throughout their lifecycle.

Specifically, it is a standardised digital collection of information that is clearly assigned to a product. Depending on the product group, the product passport contains, among other things, information on materials, installed components, repair and maintenance instructions, as well as guidance on disassembly and disposal.

The digital product passport will be introduced gradually. Initial mandatory requirements are expected from 2026 onwards, with further obligations following from 2027. Electrical and electronic products, batteries and other durable goods are expected to be among the first affected.

When the digital product passport applies and to whom

There is no single uniform start date for all products. Instead, product groups will be regulated one after another through delegated acts. For companies, this means that the question is not whether the digital product passport will become relevant, but when – and for which parts of the portfolio.

At the latest, companies placing complex or long-lasting products on the market face early pressure to act, as the required product information often cannot be collected or structured at short notice.

Product data as a bottleneck for the Right to Repair and the digital product passport

For both the Right to Repair and the digital product passport, implementation often fails not only because of the distribution of product information, but because of its fundamental availability. Relevant data on variants, components or spare parts either does not exist in a structured form or is not available at the required level of detail.

Product information is often fragmented, historically grown, incompletely maintained or not versioned. As a result, exactly the data required for repair, service or for populating a digital product passport is missing. Reparability is therefore constrained not by product technology, but by the quality and availability of information.

What the Right to Repair and the digital product passport mean for companies

The Right to Repair and the digital product passport are not isolated compliance topics. They directly affect organisation, processes and IT landscapes. Product responsibility becomes a company-wide task with clear legal consequences.

Companies must clarify which product information they actually have available today, who is responsible for maintaining it internally and how this data can be used across systems. Without reliable product data, repair obligations and digital product passport requirements cannot be fulfilled in the long term.

Conclusion

With the Right to Repair and the digital product passport, responsibility becomes measurable and verifiable. Reparability and transparency are no longer voluntary services, but regulatory obligations.

For retailers, manufacturers and companies placing products on the market, this above all means one thing: product data must exist, be structured and be usable throughout the entire product lifecycle. Those who address these requirements early create operational certainty. Those who wait risk operational disruptions, additional effort and regulatory pressure.

Helga Trost
Helga is passionate about all things digital commerce – from B2B marketing trends and innovative commerce strategies to inspiring industry events. In her articles, she shares ideas and insights from practice.