Part 3: The Directive's Structural Shortfalls

30 Second Summary

• The Right to Repair Directive is a major step forward, but it does not solve every challenge.
• Important B2B ICT issues remain outside its scope.
• Software licensing, parts pairing and enterprise IT continue to present barriers to repair.
• Additional legislation will be needed to create a truly level playing field.

The Right to Repair Directive represents significant progress for the repair sector, but it is not a complete solution. While it introduces important rights for professional repairers, several structural gaps remain that continue to affect the business-to-business (B2B) ICT market.

The Directive is fundamentally focused on consumer goods, consumer repair and consumer rights. As a result, enterprise IT infrastructure and many of the challenges faced by professional repairers and refurbishment businesses are largely overlooked.

Network equipment is not included, as it is not covered by an active Ecodesign product group.

The Directive also places no restraints on software licensing. Manufacturers can continue to use licensing models that tie software to specific hardware or restrict software reinstallation and transfer. These practices can significantly limit the reuse and refurbishment of IT equipment.

In addition, the Directive does not prohibit software based parts pairing, where replacement components must be digitally authorised before they function correctly. Nor does it introduce requirements for certified data erasure or improved access to data for IT Asset Disposition (ITAD) providers.

The Directive also does not set maximum delivery times for spare parts. Future Ecodesign legislation is expected to address this issue.

Finally, desktop PCs and laptops are not yet included within the Directive's scope. Their inclusion depends on updates to the Ecodesign Lot 3 Regulation, which is currently under review.

The Right to Repair Directive creates an important legal foundation, but further legislation will be needed to address these remaining barriers to repair and refurbishment.

In Plain English

The Right to Repair Directive is a major step forward, but it doesn't fix every problem.

Many of the biggest challenges facing professional repair businesses remain. Software licensing restrictions, digital locks on replacement parts, network equipment and business IT systems are still largely outside the scope of the legislation.

For example, a repair company may be able to replace a component, but if the software refuses to recognise it or a licence cannot be transferred, the repair may still be impossible.

The Directive opens the door, but there is still a long way to go before repair businesses have a truly level playing field.

Why this matters

Repair is about much more than replacing a broken part.

Modern IT equipment increasingly depends on software, firmware, licensing and digital authentication. If these barriers remain, the ability to repair and refurbish equipment will continue to be limited, regardless of how many spare parts are available.

This is why Free ICT Europe continues to advocate for complementary legislation, including improvements to Ecodesign, the Cyber Resilience Act and the Data Act. Together, these policies can help create an environment where products are not only designed to be repaired but can also remain functional, secure and reusable throughout their full lifecycle.

This article is part of Free ICT Europe's six part series on the European Right to Repair Directive.

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