For many years, when a phone, washing machine, vacuum cleaner, or other equipment was damaged, the choice between repair and purchasing a new product depended primarily on price, service availability, and spare parts. From the consumer's perspective, repair often lost out not because it was technically impossible, but because it was difficult to access, costly, or hindered by product design and manufacturer policies.

The EU's Right to Repair is intended to change this model.

Directive (EU) 2024/1799 of the European Parliament and of the Council of 13 June 2024 establishes common rules promoting the repair of goods. Its goal is to extend the lifespan of products and make repair a real alternative for consumers to replacing a product with a new one. This regulation is part of the broader EU circular economy trend and waste reduction efforts.

However, for businesses, this is not just an environmental regulation. The Right to Repair means specific changes in sellers' liability, manufacturers' obligations, spare parts availability, consumer communication, and the organization of after-sales processes.

For e-commerce, the change will be particularly noticeable, as the information provided to the customer on the store's website, the handling of complaints, and the organization of service must correspond to what actually happens after a fault is reported.

What is the Right to Repair?

The basis of the new rules is Directive 2024/1799 on common rules promoting the repair of goods.

The Directive was adopted on June 13, 2024, and entered into force on July 30, 2024. Member States were obliged to transpose its provisions into national law by July 31, 2026, and to apply the implementing provisions from that date.

Unlike an EU regulation, a directive is addressed to Member States and requires transposition into national law. This distinction currently has very practical significance for Polish entrepreneurs.

The deadline for implementing the directive has already passed, but Polish legislative work has not yet been completed.

The government's list includes draft UC154 – a draft act amending the Consumer Rights Act and certain other acts, prepared by the President of UOKiK (Office of Competition and Consumer Protection). Its purpose is precisely to implement the Right to Repair directive. As of August 18, 2026, the draft remains at the stage of government work, and the list indicates the third quarter of 2026 as the planned date for its adoption by the Council of Ministers.

This means that the expiry of the EU transposition deadline should not be automatically equated with the entry into force of a complete set of new obligations for Polish entrepreneurs. The ultimate method of their enforcement in Poland, national sanctions, and changes to the Consumer Rights Act will result from the implementing act.

However, this does not change the fact that businesses covered by the new regulations should be preparing their processes now. The design of the basic obligations flows directly from the directive, and the Polish draft UC154 essentially reproduces the solutions adopted at the EU level.

Right to repair vs. complaint – these are not the same mechanisms

One of the most important elements of the new regulations is the distinction between two situations.

The first concerns the classic liability of the seller for non-conformity of goods with the contract. The consumer buys a product, the product turns out to be faulty, and the customer uses the legal remedies available to them against the seller.

The second situation concerns the possibility of obtaining product repair also within the broader Right to Repair system, particularly with regard to the manufacturer of certain categories of goods.

This distinction is important because the right to repair is not limited to changing the rules for handling complaints. The European Commission explicitly states that the directive is intended to promote repair both during and outside the seller's liability period.

In practice, this means creating two complementary mechanisms. On the one hand, the consumer is to be additionally encouraged to choose repair instead of replacing a faulty product. On the other hand, for certain goods, the manufacturer will have to ensure the possibility of repair also under the obligation resulting directly from the new rules.

Repair instead of replacement – an additional 12 months of seller's liability

One of the most significant changes for online stores will be the change in the rules regarding the seller's liability for the conformity of goods with the contract.

If the consumer is entitled to choose between repair and replacement and decides on repair, the seller's liability period will be extended by an additional 12 months once. Before carrying out the appropriate remedy, the seller must also inform the customer about the right of choice and that choosing repair may result in an extension of the liability period.

This solution has a very specific economic purpose.

If the consumer is faced with a choice between replacing a product with a new one and repairing it, repair should not only be an ecological solution but also a beneficial one from the perspective of their rights. An additional year of seller's liability is intended to encourage keeping the existing product in use.

The Polish draft UC154 foresees appropriate changes to the Consumer Rights Act. The seller would be obliged to provide information about the choice between repair and replacement and about the consequences of choosing repair.

For e-commerce, this means that the complaint procedure cannot be analyzed solely from the perspective of the terms and conditions.

It is also necessary to check complaint forms, automated messages, instructions given to the customer by the customer service department, and the systems in which employees choose how to handle a complaint. If the informational obligation is to be effectively fulfilled, it must be embedded in the process, not just added to the documentation.

Who will be obliged to repair the product?

The second group of obligations concerns manufacturers.

The Directive stipulates that the manufacturer of a good covered by relevant EU repairability requirements will be obliged – at the consumer's request – to carry out the repair, if the repair of the given product is possible. The repair should be carried out free of charge or for a reasonable price and within a reasonable timeframe.

However, the manufacturer will not always have a registered office in the European Union.

In such a situation, the obligation passes successively to the manufacturer's authorized representative in the EU, and if there is no such representative, to the importer. If there is also no importer, the obligation may fall on the distributor. These entities may commission the repair itself to an external service, but this does not automatically relieve them of responsibility for ensuring the fulfillment of the obligation.

This is particularly important for e-commerce companies importing products from manufacturers outside the EU.

An importer or distributor, who until now focused primarily on sales and logistics of goods, may find themselves in a completely new operational situation. The company will have to answer questions such as who physically performs the repair, where the consumer sends the product, how the price is calculated, what parts are available, and who is responsible for communication with the customer.

What products are covered by the Right to Repair?

The Right to Repair does not mean that every consumer product will immediately be subject to an identical manufacturer's obligation.

The obligation under Article 5 of the Directive is linked to products for which EU law has established repairability requirements. Their list is in Annex II to the Directive.

Currently, it includes household washing machines and washer-dryers, dishwashers, refrigerating appliances, electronic displays, vacuum cleaners, tumble dryers, mobile and cordless phones, slate tablets, servers and data storage devices, welding equipment, and certain goods using batteries for light means of transport.

This list does not have to remain constant.

The European Commission may update it as further EU requirements for product reparability are adopted. In practice, this means that a business selling a category today that is not yet covered by the repair obligation should not assume that the situation will remain unchanged in the coming years.

The manufacturer will not be able to artificially hinder repair

The obligation to offer repair alone would not be sufficient if, at the same time, the manufacturer could design the product in a way that practically prevents the use of independent service.

Therefore, the directive goes further.

The manufacturer may not, without justified and objective reason, apply contractual provisions or hardware or software solutions that hinder the repair of goods covered by the regulation. In particular, they should not block independent repairers from using original, used, or compatible spare parts and certain 3D-printed parts, provided they meet the relevant requirements, including product safety and intellectual property.

The manufacturer also cannot refuse repair solely because the product was previously repaired by another service center or another person.

This is a significant change in regulatory philosophy.

The Right to Repair is not only intended to create an obligation to perform a specific service but also to limit practices that economically or technologically trap consumers within a single authorized service system.

Spare parts should also have a "reasonable" price

Repair will not be a realistic choice if replacing a small component costs almost as much as buying a new product.

Therefore, with regard to manufacturers making spare parts and tools available for goods covered by the relevant regulations, the directive requires them to be offered at a reasonable price that does not discourage repair.

The regulation does not set a single maximum margin or a single mathematical method for calculating part prices. Market practice and the circumstances of each specific case will therefore be important.

From the manufacturer's perspective, this means that a business model based on very high prices for spare parts may need re-evaluation.

Repair price information should be available online

The Right to Repair is also intended to limit a problem that consumers encounter even before submitting equipment for service – the inability to determine how much a repair might cost at all.

The manufacturer, and where appropriate, the representative, importer, or distributor covered by the repair obligation, must provide the consumer with free online access to information on the indicative prices of typical repairs for specific goods. Information about the repair services themselves should be clear, understandable, and easily accessible.

For a company, this means another task that is not only legal but also technological.

It is necessary to determine where the information will be published, who is responsible for its updating, and how to connect the product or service page with the repair process. It is not enough to prepare an internal document if the consumer is to obtain information directly online.

European Repair Information Form

The Directive also introduces a European Repair Information Form.

However, this does not mean that every service center will be absolutely obliged to use this form. Its use is to be voluntary. If a business decides to use it and provides the form to the consumer, the document has specific legal consequences.

The form includes information on, among other things, the entity performing the repair, the product, the type of fault, the proposed repair method, the price or method of its calculation, the estimated repair completion time, and the possible availability of a replacement product.

The conditions provided in the form are to remain binding for at least 30 days. If the consumer accepts them during this period, the entity performing the repair must carry out the service in accordance with the presented conditions. The form itself is free of charge for the consumer, although if diagnostics are necessary to determine the nature of the fault or the cost of repair, a reasonable fee for this service may be charged.

From a business perspective, the voluntary form can therefore be both an additional organizational obligation and a way to streamline the repair quotation process.

European Repair Platform – easier to find a service center

Another element of the system will be the European online repair platform.

Its purpose is to make it easier for consumers to find entities offering repair, sellers of refurbished goods, entities purchasing damaged products for refurbishment, and repair initiatives. The European Commission is to prepare a common interface by July 31, 2027, and the platform is to become fully operational from January 1, 2028.

The Polish draft assumes the creation of a national section within this European system. Repair companies will be able to use a self-registration mechanism and present their offers to consumers.

In the long run, this may increase competition in the service market. Consumers will find it easier to compare available service providers instead of being limited to the service center indicated at the time of product purchase.

What does the Right to Repair mean for an online store?

For an online store, the biggest mistake would be to assume that Right to Repair is solely a problem for equipment manufacturers.

The seller will participate in the system already at the complaint stage. It will be the seller who must appropriately inform the consumer about the choice between repair and replacement and about the additional period of liability associated with choosing repair. The change may therefore require updating the terms and conditions, the complaint process, the customer panel, email communication, and instructions for customer service employees.

The regulation may have even greater significance for e-commerce that is simultaneously a manufacturer, importer, or distributor of goods covered by the Right to Repair.

In such a case, the analysis should not end with consumer documentation. It is necessary to check the possibility of carrying out repairs, cooperation with service centers, parts availability, information on indicative prices, the product acceptance process, and contractual relations with the manufacturer outside the EU.

The Right to Repair will therefore be another example of a regulation where the legal compliance of a store depends not only on its terms and conditions but on its entire operational process.

What should a company do now?

Since the Polish implementing provisions for the directive are still in progress, there is no need to introduce changes randomly. However, it is a good time to prepare the organization.

First, it is worth determining the company's role in the sales chain. The scope of changes will be different for a store that is solely a seller, different for a manufacturer, and yet another for an importer of products from a non-EU manufacturer.

Next, it is necessary to check whether the offered goods are included in the catalog of products covered by repairability obligations and what specific requirements arise from the relevant product regulations.

The final stage should involve an audit of the complaint and service process: from information on the website and in the terms and conditions, through communication with the consumer, to the physical execution of the repair, parts availability, and the flow of information between the seller, manufacturer, and service center.

Thanks to this, the entry of new regulations into the Polish legal system will not require a last-minute process overhaul.

What penalties might Polish Right to Repair law provide for?

The directive itself obliges Member States to establish effective, proportionate, and deterrent sanctions for violations of specific obligations concerning, among other things, repair and consumer information.

Since the Polish act has not yet been passed, at this stage, we must speak of projected penalties, not currently applicable ones.

Draft UC154 foresees that the primary supervisory body in this area will be the Trade Inspection. For violations of the obligations regarding the Right to Repair, the draft provides for administrative monetary penalties of up to PLN 20,000, and in the case of repeated violations, up to PLN 40,000. Depending on the nature of the practice, a violation may also be assessed as a breach of collective consumer interests, which opens up a separate liability regime before the President of UOKiK.

The draft also provides for a minor offense penalty for specific violations concerning the European Repair Information Form.

These values may still change during the legislative process, so before implementing procedures, the finally adopted text of the law should be re-verified.

Right to repair and e-commerce – it's not worth waiting for the first complaint

The Right to Repair shows the direction in which European consumer law is moving.

Not only the moment of product sale but its entire life cycle is becoming increasingly important: the possibility of updates, repair, access to parts, the way consumers are informed, and whether the product's design does not cause its premature obsolescence.

From an entrepreneur's perspective, this means the need for increasingly close cooperation between legal, e-commerce, customer service, logistics, product management, and service departments.

If the complaint procedure exists only in the terms and conditions, and the customer service employee operates according to a different practice, new obligations will quickly reveal this inconsistency. Similarly, a manufacturer will not implement the right to repair with just an announcement on the website if it does not provide access to parts, service, and cost information.

Therefore, preparing for the Right to Repair should be treated as a process project, not just another technical update of documents.

Legal support in preparing your company for the Right to Repair

The scope of changes will depend on whether the entrepreneur is a seller, manufacturer, importer, distributor, or a repair service provider. The type of products sold, the distribution model, and the organization of complaints and service also matter.

At ecommerce.legal, we begin the analysis of such changes with the actual operating model of the enterprise.

In the case of the right to repair, this includes, among other things, determining the company's role, assessing the categories of products sold, analyzing contracts with manufacturers and service providers, and verifying complaint procedures and communication with consumers.

Only on this basis can it be determined which documents need to be changed and what operational actions need to be implemented.

This is particularly important in e-commerce, where the terms and conditions, complaint form, ticket handling system, and the actual practice of employees should describe the same process.

Right to repair – summary

The Right to Repair directive changes the approach to a product after its sale. Consumers are to be encouraged to repair instead of replace, manufacturers of certain categories of goods are to ensure a real possibility of repair, and technological and economic barriers hindering servicing are to be gradually reduced.

For sellers, an important change will be an additional 12 months of liability in case of choosing repair and the related information obligation. Manufacturers, importers, and distributors of specific products, on the other hand, will have to take a broader look at access to parts, repair costs, service, and information provided to customers.

At the same time, as of August 18, 2026, Poland has not yet completed the implementation of Directive 2024/1799. Draft UC154 remains in the legislative process. Therefore, entrepreneurs should prepare processes based on the already known direction of regulations, but before final implementation, it will be necessary to compare them with the finally adopted text of the Polish law.

The right to repair is therefore not just another information obligation. For many companies, it will mean a change in the way the entire after-sales process is designed – from complaints and customer communication, through spare parts and service, to the relationships between the seller, manufacturer, importer, and distributor.