After-sales stops being an afterthought and gets a shape.
For most manufacturers, the phase after a product is sold has been the least governed part of the business. A warranty was a single provision built from last year’s claims. Spare parts were stock that someone in service ordered when a repair came in. A repair price was whatever the branch quoted on the day. It worked, more or less, because nothing outside the company had an opinion about how any of it was done.
That changed on 31 July 2026. Directive (EU) 2024/1799, on common rules promoting the repair of goods, applies from that date across the European Union, transposed by each Member State into its own national law. It is written for consumers and for repairers, not for finance, which is exactly why the finance implications are easy to miss. Read it as an operations text and it does two concrete things that land in your systems.
The first is a change to the legal guarantee. Article 16 amends the sale of goods rules in Directive (EU) 2019/771 so that where a consumer chooses repair, rather than replacement, to bring a faulty good back into conformity, the liability period is extended once by 12 months, added to whatever was left. Before the seller provides the remedy, a new Article 13(2a) requires it to tell the consumer they can choose between repair and replacement, and that repair may extend the period. So the guarantee is no longer a fixed span from the date of sale. It is a per unit clock that a repair can move.
The second is an obligation to repair. Article 5 requires the manufacturer, on the consumer’s request, to repair goods for which repairability requirements already exist in Union law, listed in Annex II to the Directive. The repair has to be free of charge or for a reasonable price and within a reasonable time. Spare parts, where the manufacturer makes them available, have to be offered at a reasonable price that does not deter repair, and indicative repair prices have to be published on a free access website. Where the manufacturer sits outside the Union, the obligation passes in turn to its authorised representative, then the importer, then the distributor.
One distinction is worth getting right at the outset, because a quick summary of this Directive tends to blur it. The guarantee extension and the obligation to repair have different reach. Article 21 provides that the guarantee amendment does not apply to sales contracts concluded before 31 July 2026, so the extra year attaches only to the cohort sold from that date onward. The obligation to repair, by contrast, is tied in recital 15 to goods placed on the Union market, so it reaches products already in customers’ hands, bounded only by whether that product already carries repairability requirements. One rule is forward looking and one reaches the installed base, and a provision model that merges them will misstate both.
Read as a compliance burden, this is a list of things the service function now has to do. Read as operations, it is the moment the after-sales phase acquires a structure. A guarantee that moves per unit, a spare part with a price you can defend and a life measured in years, a repair quote that holds and then binds: these are records, and records are what let a business plan, provision and price with confidence. The rest of this article is about building them once so they serve the rule and the P and L at the same time.
What the Directive says, and when each part bites.
The text is more specific than the headlines, and the specifics are the design cues. The table below works through the provisions that reach a finance or after-sales owner, taken from the Directive itself and from the sale of goods directive it amends. The third column matters as much as the second, because one change is a transitional rule that applies to a cohort and another is live for the whole in scope base.
| Provision | What the text says | When it applies | What it means for your systems |
|---|---|---|---|
| When it applies | Article 22 requires Member States to transpose the Directive and to apply the national measures from 31 July 2026. Article 23 sets entry into force on the twentieth day after publication in the Official Journal on 10 July 2024 | Live from 31 July 2026 | Treat this as present operating reality across the EU. It arrives as 27 national laws, so the detail your team answers to is the transposing text of each market, not only the Directive. |
| The guarantee gets longer | Article 16 amends Directive (EU) 2019/771 by inserting a new Article 10(2a): where repair takes place as the remedy to bring goods into conformity, the liability period is extended once by 12 months. That period is added to the remaining liability period of the good | Live from 31 July 2026 | The warranty tail is no longer a fixed figure set at the sale. It lengthens once each time a repair is chosen to fix a fault, so the provision needs the repair history to be measured properly. |
| The choice has to be offered | The same Article 16 inserts a new Article 13(2a): before providing the remedy, the seller shall inform the consumer of the right to choose between repair and replacement and of the possible extension of the liability period provided for in Article 10(2a) | Live from 31 July 2026 | The returns and remedy flow now needs a step that records which remedy the consumer chose, because that choice is exactly what triggers the extension. |
| What the extension attaches to | Article 21 provides that Article 16 shall not apply to sales contracts concluded before 31 July 2026 | Transitional | The extension is forward looking. It attaches to the cohort sold from 31 July 2026 onward, so the provision change phases in with new sales rather than restating the whole installed base. A summary that calls the guarantee change retroactive is wrong on the text. |
| The obligation to repair | Article 5(1) requires that, upon the consumer request, the manufacturer shall repair goods for which, and to the extent that, repairability requirements are provided for by Union legal acts listed in Annex II. The manufacturer is not obliged where repair is impossible and may sub-contract | Live from 31 July 2026 | Recital 15 ties this to goods placed on the Union market, so it reaches the installed base of in scope products, not only new sales. The scope is bounded by which goods already carry repairability requirements. |
| The terms of the repair | Article 5(2) requires the repair to be carried out free of charge or for a reasonable price and within a reasonable period of time. The manufacturer may loan a replacement good for the duration of the repair, free of charge or for a reasonable fee, and may offer a refurbished good where repair is impossible | Live from 31 July 2026 | An out of guarantee repair is a priced service you may run at a margin, which makes after-sales a revenue line rather than only a cost, provided the price can be shown to be reasonable. |
| Spare parts at a reasonable price | Article 5(4) requires manufacturers that make spare parts and tools available for goods covered by Union legal acts listed in Annex II to offer them at a reasonable price that does not deter repair. Recital 16 notes such a price may reflect labour, spare parts, the cost of operating the repair facility and a customary margin | Live from 31 July 2026 | A spare part needs a price rule the system can evidence, cost plus a customary margin rather than whatever the aftermarket once bore, because the price is now constrained in effect. |
| Published repair prices | Article 5(5) requires that consumers can access, via a free access website, information on the indicative prices charged for the typical repair of covered goods | Live from 31 July 2026 | The public figure and the internal quote have to come from one source. If they diverge, the published price becomes the number a consumer holds you to. |
| No blocking of repair | Article 5(6) prohibits contractual clauses, hardware or software techniques that impede repair unless justified by legitimate and objective factors such as the protection of intellectual property rights, and forbids impeding the use of original, second hand, compatible or 3D printed spare parts by independent repairers | Live from 31 July 2026 | Part pairing and software locks that used to protect an aftermarket now need a justification on the record, so the reason each one exists is worth documenting before anyone asks. |
| The repair quote holds | Article 4 lets a repairer provide the European Repair Information Form, which must state the price or the way it is calculated and a maximum, the time to complete, and a period of validity. Article 4(5) requires that the repairer not alter those conditions, including the price, for 30 calendar days, and where the consumer accepts within validity the repairer is obliged to perform | Live from 31 July 2026 | A repair quote becomes a price locked, time bounded offer that binds on acceptance. That is a quote object with a validity window and a commitment behind it, not a rough estimate. |
| The scope grows on a clock | Article 5(9) requires the Commission to adopt delegated acts adding Union legal acts to Annex II without undue delay after a new repairability act is published, and at the latest 12 months after that publication | Ongoing | Keep an in scope flag on each product line that a feed can update. When a new ecodesign act lands, the products it covers enter the obligation, and the ERP should already know which lines those are. |
| A review is scheduled | Article 19 requires the Commission to report on the application of the Directive by 31 July 2031, assessing in particular the obligation to repair and the effectiveness of the incentives to choose repair, including the extension of the legal guarantee | 31 July 2031 | The rules will be tuned. Build the data so a change to the extension length or the scope is a configuration change rather than a project. |
Two rows deserve more than a line. The first is the transitional rule in Article 21. It is one sentence, and it decides how the warranty provision moves. Because the extension applies only to contracts concluded from 31 July 2026, the change enters the numbers gradually, cohort by cohort, as new goods are sold and some of them are repaired. A team that switches the whole provision to a longer tail on day one over provides against the past. A team that ignores the change under provides against the future. The correct treatment is to hold the cohort on the unit and let the estimate follow.
The second is the reasonable price standard that runs through Article 5. It appears for the repair itself and again for spare parts, and recital 16 gives it content: a price may reflect labour, the cost of parts, the cost of running the repair facility and a customary margin, provided it does not deter the consumer from having the good repaired. That is a describable rule, which means it can be a formula rather than a judgement made per quote. It also means the number you publish under Article 5(5) and the number you charge should be the same number, produced the same way.
The guarantee is now a clock that a repair can move.
Start with the change that touches the balance sheet most directly. A legal guarantee is an assurance type warranty: a promise that the good conforms to what was agreed, backed by a remedy if it does not. It is the textbook example the provisions standard, IAS 37, uses to explain a provision, and under US GAAP it is accrued as a cost rather than treated as a separate performance obligation. The estimate has always had two moving parts, how many units will need work and how much each will cost, applied across a known period.
Article 10(2a) adds a third. The period is no longer fixed. Each time a consumer chooses repair to fix a fault, the guarantee on that specific good is extended once by 12 months. A provision built on a single tail, the same for every unit, now sits over a population whose tails vary with how often each good has been repaired. The input the estimate needs is no longer one number but a distribution: the guarantee end dates actually in force, and the observed rate at which repairs extend them. Neither exists unless the guarantee is held per unit and the repair event writes back to it.
That is the whole design of this section. A guarantee end date stored on the sales line as a static value, computed once as the sale date plus two years, cannot represent a period that moves. It has to live on the individual good, with the cohort recorded so the transitional rule can be honoured, and with a flag for whether the once only extension has already been used, since Article 10(2a) allows it a single time. The repair event, when it records a repair chosen as the conformity remedy, moves the date forward and sets the flag. From then on the provision reads the current dates, not the original assumption.
The reporting benefit shows up immediately. A warranty provision that is measured from per unit guarantee dates and a real repair history is more defensible than one measured from a single average, and it answers questions an average cannot: how much of the liability sits in the extended cohort, how the tail is lengthening, and what a change in repair frequency would do to the number. The Directive asked for none of that. The data it makes you collect delivers it as a by-product.
A spare part becomes an item with a life and a price you can defend.
The obligation to repair only means something if the parts exist, so the Directive leans on the repairability requirements already written into product law. Article 5 covers goods listed in Annex II, and the clearest worked example is smartphones and tablets, whose ecodesign rules in Regulation (EU) 2023/1670 have applied since 20 June 2025. Those rules say what an availability window looks like in practice: spare parts must be available for seven years after the last unit of a model is placed on the market, delivered within five working days for the first five years and ten working days for the remaining two, with indicative pre-tax spare part prices published on a free access website.
For finance, a seven year availability obligation is a working capital and valuation statement in disguise. You have to be able to supply a part long after the product that uses it has stopped selling, which means either holding stock, holding the ability to produce it, or both. Stock held for that long outlives its demand curve, and a part carried at cost until it is eventually scrapped is a write down waiting to be discovered. The availability window belongs on the part as a date, so planning works from it, and the same slow moving stock is tested at the lower of cost and net realisable value under IAS 2 rather than left to accumulate quietly.
The price is the other half. Article 5(4) requires spare parts to be offered at a reasonable price that does not deter repair, and Article 5(5) puts an indicative repair price on a public website. A spare part price that was set by what the aftermarket would bear is now exposed on two sides: it is hard to defend as reasonable, and it can be contradicted by your own published figure. The way out is to make the price a build up, cost plus a customary margin as recital 16 allows, stored so it can be recalculated and evidenced, and to generate both the website figure and the internal quote from that one rule so they cannot drift apart.
None of this requires the aftermarket to become a charity. A reasonable price still carries a customary margin, and service parts and repair are frequently among the higher margin, more durable lines a manufacturer has. What the Directive removes is the option of an opaque price and a part that is quietly discontinued. What it leaves is a service business with a catalogue, a price you can stand behind and a life you can plan, which is a better business to run than the one held together by whatever the branch quoted.
| The after-sales object | What the Directive requires | The finance record it becomes | The control that keeps it honest |
|---|---|---|---|
| The guarantee clock | A once only 12 month extension of the legal guarantee where repair is chosen to bring a good back into conformity (Article 10(2a) of Directive (EU) 2019/771) | A per unit guarantee end date and a warranty provision measured by cohort under IAS 37, the standard that uses a warranty as its worked example of a provision | A repair event that updates the end date, flags the cohort, and feeds the provision model with a frequency and a tail rather than a single fixed period |
| The spare part | Availability for at least the period set in Union law, at a reasonable price that does not deter repair (Article 5(4), and for phones and tablets the seven year window in Regulation (EU) 2023/1670) | A service part item with an availability window measured in years and a valuation at the lower of cost and net realisable value under IAS 2 | A reasonable price rule the pricing engine can evidence and an obsolescence review keyed to the statutory window, not only to expected sell through |
| The repair quote | The European Repair Information Form, price and conditions held for 30 calendar days and binding on acceptance (Article 4) | A quote object with a validity window and, on acceptance, a repair order and a commitment the finance team can see | A pricing control that freezes the quote for its validity, plus a link from quote to order to parts consumed to invoice |
| The out of guarantee repair | Carried out for a reasonable price where the fault falls outside the legal guarantee (Article 5(2)) | Repair revenue recognised as the service is performed under IFRS 15 or ASC 606, distinct from a free in guarantee repair | A split made at the event level between free in guarantee work, which is provisioned, and priced work, which is recognised |
| The published price list | Indicative prices for the typical repair of covered goods on a free access website (Article 5(5)), and indicative spare part prices for phones and tablets (Regulation (EU) 2023/1670) | A public data surface generated from the internal pricing source rather than maintained by hand | One source for the website and the quote, with a change log, so the figure a consumer reads matches the figure you charge |
| The scope flag | The Annex II list of goods that already carry repairability requirements, updated by delegated act (Article 5(9)) | An in scope indicator per product line that governs whether the obligation applies today | A feed that sets the flag from the current Annex II and an alert when a new act brings a line into scope |
The repair quote is a priced offer that holds, then binds.
The Directive gives the repair quote a standard shape and a legal weight it did not have before. Article 4 introduces the European Repair Information Form, which a repairer may provide and, once provided, must fill out fully. It states the defect and the type of repair, the price or the way the price is calculated with a maximum, the time to complete, the availability and cost of a temporary replacement, and a period of validity. A diagnostic fee may be charged where a fault has to be investigated first, and it can be deducted from the repair price if the consumer proceeds.
The weight is in Article 4(5). Once given, the conditions, including the price, cannot be altered for 30 calendar days, and if the consumer accepts within that window the repairer is obliged to perform the repair on those terms. A quote is therefore no longer a rough estimate that can be revised when the parts turn out to cost more. It is a price locked, time bounded offer that becomes part of the contract on acceptance. For a finance system that is a familiar object: a quote with a validity date, a locked price, and a state that moves from offered to accepted to a repair order.
Modelling it properly closes a common gap. A quote that binds on acceptance and then flows into a repair order, the parts consumed and an invoice gives you an unbroken line from the price promised to the work done to the amount charged. An accepted quote that has not yet been fulfilled is a small commitment the finance team can actually see. And because the price on the form and the price on the website both come from the reasonable price rule, the figure a consumer was shown, the figure they accepted and the figure you booked are the same figure, which is the sort of internal consistency an auditor stops asking about once it is reliably true.
The record that makes it one job instead of four.
Put the pieces together and the shape is a small set of linked records: a finished good with a serviceable bill of materials, spare parts that each carry an availability window and a reasonable price build up, a unit that carries its own guarantee clock, a repair quote with a validity, and a repair event that references all of them. The model below is a worked illustration of that structure, followed by the exception query that turns it into a standing control. The identifiers and figures are placeholders and describe no real organisation or product.
An after-sales record keyed so one repair updates the guarantee, the parts and the provision
# The after-sales record, keyed so a repair updates the guarantee, the
# parts and the provision at once. Identifiers and figures are placeholders
# and describe no real organisation or product.
finished_good:
product_id: "FG-2210"
commercial_name: "Countertop dishwasher, model X"
in_scope: true # set from the current Annex II
in_scope_source: "ecodesign act listed in Annex II" # Article 5(9)
serviceable_bom: # orderable parts, not the production BOM
- part_id: "SP-4471" # door latch assembly
- part_id: "SP-4472" # drain pump
- part_id: "SP-4473" # control board
spare_part:
part_id: "SP-4472"
description: "Drain pump"
availability_window_end: "2033-05-31" # >= period set in Union law
availability_source: "seven years from end of placement, per product act"
# reasonable price is a build up, not a typed number (recital 16)
unit_cost: 18.40
customary_margin_pct: 35
reasonable_price: 24.84 # unit_cost * (1 + margin)
indicative_price_published: 24.84 # Article 5(5), same source as the quote
on_hand_qty: 260
nrv_reviewed_on: "2026-09-01" # IAS 2 lower of cost and NRV
unit:
serial: "FG2210-000148217"
product_id: "FG-2210"
sold_on: "2026-08-14" # contract concluded after 31 July 2026
cohort: "post-2026-07-31" # so the extension can apply
guarantee_end: "2028-08-14" # moves on a repair, do not overwrite blind
extension_used: false # Article 10(2a) allows it once
repair_event:
repair_id: "RE-88120"
serial: "FG2210-000148217"
reported_on: "2027-03-02"
defect_code: "DRAIN-NO-PUMP"
remedy_chosen: "repair" # recorded per Article 13(2a)
in_guarantee: true # decides provision vs revenue
parts_used: ["SP-4472"]
labour_hours: 0.8
quote_id: "RQ-53107"
extension_applied_months: 12 # sets guarantee_end to 2029-08-14
priced_amount: 0.00 # free while in guarantee
repair_quote: # European Repair Information Form
quote_id: "RQ-53107"
issued_on: "2027-03-02"
price: 24.84
max_price: null
completion_days: 5
valid_until: "2027-04-01" # 30 calendar days, Article 4(5)
price_locked: true # not altered within validity
accepted_on: "2027-03-03"
# The exception query. Run it on a schedule. Every row is a question you
# would rather answer before someone else asks it.
SELECT ref, reason FROM (
-- an in scope product with no serviceable bill of materials
SELECT product_id AS ref, 'in scope, no serviceable BOM' AS reason
FROM finished_good
WHERE in_scope AND serviceable_bom IS NULL
UNION ALL
-- a spare part with no availability window, so planning has no horizon
SELECT part_id, 'spare part without availability window'
FROM spare_part WHERE availability_window_end IS NULL
UNION ALL
-- a price above the reasonable price rule, hard to defend as reasonable
SELECT part_id, 'price above cost plus customary margin'
FROM spare_part
WHERE indicative_price_published > unit_cost * (1 + customary_margin_pct/100.0)
UNION ALL
-- the website figure and the quote rule have diverged
SELECT part_id, 'published price differs from reasonable price'
FROM spare_part WHERE indicative_price_published <> reasonable_price
UNION ALL
-- a repair happened but the guarantee date never moved
SELECT serial, 'repair chosen, guarantee not extended'
FROM repair_event
WHERE remedy_chosen = 'repair' AND in_guarantee
AND extension_applied_months = 0
UNION ALL
-- the extension was applied twice, which Article 10(2a) does not allow
SELECT serial, 'guarantee extended more than once'
FROM unit WHERE extension_used_count > 1
UNION ALL
-- a slow moving service part past its NRV review with stock on hand
SELECT part_id, 'service part not reviewed for NRV'
FROM spare_part
WHERE on_hand_qty > 0
AND nrv_reviewed_on < current_date - INTERVAL '365 days'
UNION ALL
-- a quote altered inside its validity window
SELECT quote_id, 'quote conditions changed within validity'
FROM repair_quote WHERE price_locked = false AND valid_until > issued_on
) exceptions
ORDER BY reason, ref;The query at the foot is the part worth adopting first. Run on a schedule rather than after a complaint, it surfaces the gaps that turn into problems under time pressure: an in scope product with no serviceable parts listed, a part with no availability window, a price that sits above the reasonable price rule, a website figure that has drifted from the quote, a repair where the guarantee date should have moved and did not, an extension applied more than the once the Directive allows, a service part overdue for a valuation review, and a quote that was altered inside its validity. Each row is a question, and finding it yourself is always cheaper than having a consumer, an auditor or a regulator find it for you.
An implementation checklist.
None of this is a programme. It is a handful of fields, one query on a schedule, and a few decisions taken deliberately rather than per quote.
- Make the guarantee end date a per unit field, not a formula. For anything sold under a consumer sales contract from 31 July 2026, store an end date on the individual good, derived at the sale but able to move. Wire the repair event to apply the once only 12 month extension from Article 10(2a) and to stamp the cohort, so the value that feeds the provision is the current one rather than the original assumption.
- Record the remedy the consumer chose. New Article 13(2a) requires the seller to offer the choice between repair and replacement and to mention the extension. Capture the choice in the returns flow, because a repair chosen as the conformity remedy is what triggers the extra year, and a replacement does not.
- Give every covered finished good a serviceable bill of materials. List the parts that can be ordered and fitted, each as its own item, so the question can this unit be repaired and with which parts has an answer by query rather than by a call to engineering.
- Put an availability window on each spare part. The Directive requires availability for at least the period set in Union law, and for phones and tablets Regulation (EU) 2023/1670 sets seven years from the date the last unit of the model was placed on the market. Hold that end date on the part so planning and obsolescence both work from it.
- Express the reasonable price as a rule, not a number typed in once. Recital 16 allows labour, parts, facility cost and a customary margin. Store the build up so the price can be recalculated and shown to be reasonable, and generate the free access website figure and the internal quote from the same rule.
- Model the repair quote as a validity bounded, price locked object. Article 4(5) freezes the conditions for 30 calendar days and binds you on acceptance. Give the quote a validity end, lock the price for that window, and handle the diagnostic fee as a charge that can be deducted from the repair price if the consumer proceeds.
- Point the warranty provision at the guarantee clock and the repair history. Once the tail lengthens with each repair, the provision needs the distribution of end dates and the observed repair frequency by product, not a single period applied to every unit. Keep the pre and post 31 July 2026 cohorts separate so the change phases in cleanly.
- Review service parts for net realisable value against the statutory window. A part you must be able to supply for years can outlive its demand. Test slow moving service stock at the lower of cost and net realisable value, and treat the availability obligation as a planning input rather than a reason to hold cost you will later write down without noticing.
- Split in guarantee from out of guarantee at the event. A free in guarantee repair is a provision being consumed. A priced out of guarantee repair is revenue for a service performed. Deciding which one a given repair is, at the moment it happens, is what keeps the provision and the revenue line honest.
- Keep the Annex II scope current from a feed. Article 5(9) widens the list by delegated act within twelve months of a new repairability act. Set the in scope flag from the current Annex II so a product entering scope does not depend on someone reading the Official Journal.
- Run the exception query on a schedule, not after a complaint. A part with no availability window, a price above the reasonable price rule, a unit whose guarantee date never moved after a repair, a quote altered inside its validity: every one of these is a question you would rather find yourself than have found for you.
Where this goes wrong, and how to see it coming.
The failure modes are mostly ordinary, which is the good news, because ordinary problems have ordinary fixes and a scheduled query catches most of them.
- Treating the guarantee end date as a value set once at the sale. The moment a repair can extend it, a static field silently understates the warranty tail, and the provision drifts below the obligation without anyone changing a number. The fix is an end date that a repair event updates.
- Reading the guarantee extension as retroactive. Article 21 is explicit that Article 16 does not apply to sales contracts concluded before 31 July 2026. Applying the extra year to the existing installed base over provisions the past, and assuming it never applies under provisions the new cohort. The transitional rule is the line that gets this right.
- Confusing the two things the Directive does. The 12 month guarantee extension attaches to new consumer sales contracts. The obligation to repair reaches goods already placed on the market that carry repairability requirements. They have different populations and different start points, and a model that merges them answers neither question.
- Keeping spare parts out of the bill of materials. If the serviceable parts are not linked to the finished good, you cannot answer whether a unit is repairable, price the repair, or plan the stock you are obliged to hold. The catalogue that meets the rule is the same catalogue that runs the after-sales line.
- Pricing spare parts by what the aftermarket will bear. Article 5(4) requires a reasonable price that does not deter repair, and Article 5(5) publishes an indicative figure. A price with no cost plus margin logic behind it is hard to defend as reasonable and easy to contradict against your own website.
- Letting the website price and the quoted price come from different places. Maintained by hand, the two drift, and the public figure becomes the one a consumer holds you to. Generate both from the same pricing rule and the mismatch cannot happen.
- Provisioning warranty with a single period for every unit. Once the tail varies with repair frequency and the extension, an average applied flat is a guess dressed as a number. The repair history and the per unit dates are the inputs the estimate actually needs.
- Holding the statutory spare parts stock and never testing it for net realisable value. An obligation to supply a part for seven years is not a reason to carry it at cost until it is scrapped. The availability window is a planning input, and the valuation still follows the lower of cost and net realisable value.
- Handling the repair quote as an informal estimate. Article 4(5) makes it a price locked offer that binds on acceptance for its validity. Left as a free text estimate with no validity and no lock, it becomes a dispute rather than a commitment you can plan around.
- Assuming the scope is fixed. Annex II grows by delegated act, so a product line outside the obligation today can be inside it within a year of a new ecodesign act. A scope flag driven by a feed keeps the answer current without a manual sweep.
Data and integration considerations.
- The unit is the record the guarantee lives on. A guarantee that can move with a repair belongs to the individual good, keyed by serial or by the sales line where a serial is not kept, with the sale date, the end date, the cohort and a flag for whether the extension has already been used, since Article 10(2a) allows it only once.
- The serviceable bill of materials is separate from the manufacturing bill of materials. The parts you fit in a repair are a curated, orderable subset with their own identifiers, and they change over a product life as components are superseded. Model them as their own items linked to the finished good rather than as a view of the production structure.
- The availability window is a date on the part, sourced and dated. For phones and tablets it is seven years from the end of placement on the market under Regulation (EU) 2023/1670, and other product groups set their own. Record the window end and the legal act it came from, so a planner and an auditor both see why the part is being held.
- The reasonable price is a stored build up, not a single figure. Hold the cost inputs and the margin so the price can be recomputed and evidenced, and so the same rule can produce the indicative website price required by Article 5(5) and the quote given to a consumer.
- The repair quote is a first class object with a validity. Store the priced conditions, the maximum price where an exact figure cannot be given, the completion time, the validity end and whether the consumer accepted, because on acceptance those conditions become the contract under Article 4(5).
- The repair event ties everything together. One record should carry the unit, the defect, the remedy chosen, whether it fell inside the legal guarantee, the parts consumed from the serviceable catalogue, the labour, the quote it was performed under, and whether it triggered the 12 month extension. That single object serves compliance, the provision, the parts valuation and revenue at once.
- In guarantee and out of guarantee is a field, not an inference. Whether a repair is free under the legal guarantee or priced as a service decides whether it consumes a provision or earns revenue. Deciding it at the event, with the guarantee date and the defect in front of you, is far cleaner than reconstructing it at period end.
- Keep history rather than only current state. The guarantee date a unit carried when a claim was assessed, the price a part carried when a quote was given, and the scope flag a product held on a given day are all questions a later review can ask. Versioned rows with effective dates answer them cheaply.
- The scope flag needs a source and a date. Record which Annex II act put a product line in scope and when, so the obligation can be explained and so a delegated act that widens the list updates the flag rather than surprising the team that owns the product.
- The published price surface is generated, and its changes are logged. Treat the free access website as an output of the pricing rule with a change history, so the figure shown on any past date can be reproduced if a consumer or a regulator asks what it said.
What the evidence file should contain.
The reason to keep this material is not the Directive alone. Warranty provisions, inventory valuation and revenue recognition are already in scope for internal and external review, and a repair touches all three. Handled as a set of records rather than as an informal service activity, the after-sales phase produces its evidence as a by-product.
- The per unit guarantee record as it stood when a claim or a provision was assessed, showing the sale date, the end date, the cohort and whether the 12 month extension had been applied.
- The record of the remedy choice offered under Article 13(2a) and the choice the consumer made, since a repair chosen as the conformity remedy is what extends the guarantee.
- The serviceable bill of materials for the product, showing the parts that could be ordered and fitted at the time of the repair, with their identifiers and availability windows.
- The reasonable price build up for each spare part and for the repair, showing the cost inputs and the margin, so the price charged and the price published can both be shown to be reasonable under Article 5(4).
- A reconciliation between the indicative prices on the free access website and the internal pricing rule on a given date, showing that the public figure and the quoted figure came from the same source.
- The repair quote as issued, with its priced conditions, maximum price where used, completion time and validity, and evidence that the conditions were not altered within the 30 day window required by Article 4(5).
- The repair event record, tying the unit, the defect, the remedy, the parts consumed, the labour, the in or out of guarantee decision and any extension applied, with timestamps.
- The warranty provision working, showing the population by cohort, the observed repair frequency and the distribution of guarantee end dates that the estimate was built from, rather than a single period applied to every unit.
- The net realisable value review of service parts held against a statutory availability window, showing which slow moving parts were written down and why.
- The scope record, showing which Annex II act placed each product line in scope, the date it took effect, and the feed or review that keeps the flag current.
Questions worth asking before the first repair under the new rules.
- For goods sold from 31 July 2026, do we hold a guarantee end date per unit that a repair can move, or a period applied uniformly that a repair leaves untouched?
- When a consumer returns a faulty good, do we record whether they chose repair or replacement, given that only repair extends the guarantee?
- Can we produce the serviceable bill of materials for a product and answer, by query, whether a specific unit is repairable and with which parts?
- Does every spare part for an in scope product carry an availability window, and do we plan and value the stock against that window rather than against expected sell through alone?
- Can we show the cost plus margin behind a spare part price and a repair price, and does the same rule generate the figure on our free access website?
- Is our repair quote a price locked offer with a validity that binds us on acceptance, or a free text estimate that invites a dispute?
- Does our warranty provision use the repair history and the per unit guarantee dates, or a single period that predates the extension?
- Have we tested the service parts we are obliged to hold for years at the lower of cost and net realisable value?
- At the moment a repair happens, do we decide and record whether it is a free in guarantee repair or a priced service?
- If a delegated act brought a new product group into Annex II next quarter, would our scope flag update from a feed, or would we find out from a customer?
An obligation you can turn into a line you can plan.
The interesting thing about the repair rules is not the obligation. It is that a part of the business which used to run on habit now has a structure, and structure is what lets finance do its job. A guarantee that moves per unit, a spare part with a defensible price and a known life, a repair quote that holds and then binds, and a repair recorded as a single event: each of these is a record, and together they let you provision the warranty from real dates, value the parts against a real window, price the repair from a real rule and recognise the revenue from a real service.
The work it asks for pays for itself in more than one place. A serviceable bill of materials keyed to the finished good is the same artefact a recall or a field campaign needs. A per unit guarantee clock is the same record a customer service team wants when a consumer asks what they are still entitled to. A reasonable price rule that feeds the website and the quote is the same control that keeps pricing consistent across channels. The Directive is the occasion, not the only beneficiary.
Start where the money is. Take the products already in scope, put a guarantee clock on the units sold from 31 July 2026, give the top few spare parts an availability window and a price build up, and record the next repair as one event that writes back to all of it. That is a short list in most businesses, and once it is done the hardest part is finished. Everything after that is a scheduled query and a habit, and an after-sales phase that used to be an afterthought becomes a line on the plan.
Sources
- Directive (EU) 2024/1799 of the European Parliament and of the Council of 13 June 2024 on common rules promoting the repair of goods and amending Regulation (EU) 2017/2394 and Directives (EU) 2019/771 and (EU) 2020/1828, on EUR-Lex. Downloaded and read directly rather than through a fetched summary. Source for every normative statement in this article: the European Repair Information Form and the 30 calendar day price lock in Article 4; the obligation to repair, the reasonable price for repair and for spare parts, the free access price website and the cascade to representative, importer and distributor in Article 5; the delegated power to widen the scope in Article 5(9); the amendments to Directive (EU) 2019/771 in Article 16, including the once only 12 month extension of the liability period; the transitional rule in Article 21; the application date of 31 July 2026 in Article 22; and the 2031 review in Article 19.
- Directive (EU) 2019/771 of the European Parliament and of the Council of 20 May 2019 on certain aspects concerning contracts for the sale of goods, on EUR-Lex. The sale of goods directive that Article 16 of the repair Directive amends. Read directly for the structure of the legal guarantee that the extension attaches to, in particular the liability and remedy provisions in Articles 10, 13 and 14.
- European Commission, Directive on repair of goods, on the consumer protection law portal. Read directly. Cited for the application date of 31 July 2026, the plain language description of the obligation to repair, the reasonable price for spare parts, the European Repair Information Form with its conditions valid for 30 days, and the extra year of legal guarantee where a consumer chooses repair over replacement.
- Commission Regulation (EU) 2023/1670 of 16 June 2023 laying down ecodesign requirements for smartphones, mobile phones other than smartphones, cordless phones and slate tablets, on EUR-Lex. Read directly for a concrete example of what a repairability requirement in Union law contains. Source for the seven year spare parts availability window running from the date the last unit of a model is placed on the market, the delivery times of 5 working days in the first five years and 10 working days in the remaining two, the indicative pre-tax spare part prices on a free access website, and the application date of 20 June 2025.
- Right to Repair Europe, Repairability labels, spare parts and longer support for smartphones and tablets as of June 2025. A campaign group explainer, used for corroboration of the smartphone and tablet spare parts and support rules that took effect in June 2025, and cited as practitioner and civil society context rather than as the basis for any requirement stated here.
- Freshfields, Repair instead of replace: Germany moves to implement the EU Right to Repair Directive. Practitioner legal analysis, used for corroboration of the 31 July 2026 transposition deadline and as background on how the Directive lands as 27 national laws rather than one text. Not used as the basis for any requirement stated here.
A note on how this was researched. Every statement about what the repair rules require comes from the text of Directive (EU) 2024/1799 itself, downloaded from EUR-Lex and read directly rather than through a fetched summary. That covers the European Repair Information Form and the 30 day price lock in Article 4, the obligation to repair and the reasonable price for repairs and spare parts and the free access price website in Article 5, the amendments to the sale of goods directive in Article 16 including the once only 12 month extension of the liability period, the transitional rule in Article 21, the application date in Article 22 and the review in Article 19. The structure of the legal guarantee that the extension attaches to was read from Directive (EU) 2019/771. The concrete availability window, delivery times and indicative price website were read directly from Regulation (EU) 2023/1670 on ecodesign for smartphones and tablets, cited as the clearest worked example of a repairability requirement that Annex II points to. The application date and the plain language of the obligation were confirmed against the European Commission’s own page, and practitioner and civil society sources are attributed as corroboration and background, never as the basis for a requirement. No public posts on X are cited in this article. Candidate posts could not be verified to the standard this site holds, because account timelines and search on X now sit behind a login that the research browser did not have, and an unverified excerpt is not worth more than a clean citation. The accounting references to IAS 37, IAS 2, IFRS 15 and US GAAP describe how the resulting records are measured and are general, not advice for a specific entity. The data model and the figures in it are worked illustrations of structure and describe no real organisation or product. Nothing here is legal advice, and the obligations that apply to any business come from the Directive and its national transpositions rather than from this article.