Response to Consultation on a Right to Repair
Position Paper
23 May 2023
Consumer affairs

The below consultation response assesses the European Commission's proposal to promote the repair of goods as practical, proportionate and ambitious. It can help achieve sustainable consumption by increasing the repair and reuse of viable defective goods while securing high skilled jobs.The proposal contains positive initiatives that would further enhance a true circular economy, such as the decision to apply a market-driven and product-specific approach to repairs outside the legal guarantee, the focus on consumer purchases (B2C) rather than business-to-business (B2B) and the choice to maintain the two-year minimum legal guarantee.
Nevertheless, the proposal could be improved in several ways:
- Increase harmonisation and secure consistency with other EU regulations;
- Recognise the role for replacement with refurbished products;
- Ensure B2B transactions are out of scope; and
- Avoid proliferation of multiple online repair information platforms per country.

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