Durability and reparability information
EmpCo amends the Consumer Rights Directive to require disclosure of durability guarantees, software-update support periods and reparability — including the new harmonised EU GARAN label.
EmpCo amends the CRD to require disclosure, before contract, of durability guarantees, software-update support periods, and reparability — including a new harmonised EU label called GARAN.
Two parallel guarantees — don't confuse them:
- Legal guarantee of conformity (already exists). Under Directive 2019/771, every product carries a minimum 2-year statutory liability for non-conformity. EmpCo just makes the right more visible via a harmonised consumer notice (new CRD Articles 5(1)(e) and 6(1)(l)).
- Commercial guarantee of durability (voluntary, new disclosure duty). A producer's voluntary commitment beyond the legal minimum. EmpCo doesn't make the guarantee mandatory; it makes information about it mandatory whenever the producer offers one covering the whole product, for more than 2 years, at no extra cost.
The GARAN harmonised label (CRD Article 22a; Implementing Regulation (EU) 2025/1960). Must show the existence of the commercial guarantee, its duration in months/years, that it covers the entire product at no extra cost, and a cross-reference to the legal guarantee. Required on packaging or shelf in retail, and next to the product image online. Where the producer makes the information available, the seller must display the label.
Energy-using goods — silence is not allowed. For fridges, washing machines, TVs, vacuums, smartphones, laptops: if the producer has not offered a commercial durability guarantee covering the whole product for more than 2 years, the trader must affirmatively inform the consumer of that fact. Either GARAN or "no commercial durability guarantee provided".
Software updates. Traders must inform consumers of the minimum period during which the producer will provide free software updates necessary to keep goods with digital elements in conformity, including security updates. Recital 30 distinguishes security updates (necessary) from feature updates (optional).
Reparability score. Where an EU-harmonised score has been established under ESPR or the Energy Labelling Regulation, the trader must display it pre-contract. Already in force for smartphones and tablets since 20 June 2025.
Other repair information. Where no score exists, the trader must pass on producer-supplied information about spare parts (availability, estimated cost, ordering procedure), repair and maintenance instructions, and any repair restrictions (e.g. software/hardware locks).
Citations: Directive (EU) 2024/825, Article 2; Recitals 22, 23, 26, 28, 30; Implementing Regulation (EU) 2025/1960; Articles 7, 17 of Directive (EU) 2019/771.
Recent developments (2024–2026). France's reparability score evolved into a broader durability index from January 2024, foreshadowing the EU-wide approach. The EU reparability score for smartphones and tabletsbecame mandatory on 20 June 2025 under the Ecodesign for Sustainable Products Regulation. The Right to Repair Directive (EU) 2024/1799 must be transposed by 31 July 2026 and reinforces EmpCo's pre-contractual duties — together they push durability and repairability information from the small print onto the product page.
Citations: Décret n° 2024-316 (France); Commission Delegated Regulation 2023/1670 (smartphones/tablets); Directive (EU) 2024/1799.