How is the repairability score of a device determined?

What you must concretely do

What is expected of you

Repairability becomes a measured product characteristic, not a qualification

The ESPR identifies repairability as one of the product aspects on which environmental design requirements can be set, alongside, among others, durability, reusability and recyclability (articles 5 to 7, Regulation (EU) 2024/1781). This means that repairability is not assessed on the basis of an impression or marketing claim, but on the basis of established criteria that are developed per product group. For a company with 10 to 100 employees, this means above all that the repairability score does not allow for individual interpretation: which components count, how disassembly is assessed and which threshold values apply are laid down in the delegated act for the company's own product category. As long as that act for electronics and ICT has not been published, there is no score to calculate — but it is clear that the method cannot be freely chosen.

The score must be determined according to a prescribed method

Article 39 of the ESPR (Regulation (EU) 2024/1781) stipulates that test, measurement and calculation methods are laid down to obtain comparable and verifiable results. For repairability, this concerns, among other things, the availability and delivery time of spare parts, the extent to which an appliance can be disassembled with common tools, and the availability of repair instructions. In practice, this means that a company wishing to substantiate a score cannot rely on an internal estimate: the underlying measurement must have been carried out according to the prescribed method, with a defined test setup. This aligns with the question according to which method should I measure the values for the passport? — repairability is in that sense no exception to the other product characteristics that the passport contains.

The score ends up in the product passport

Once the repairability score has been established, it becomes one of the data accessible via the digital product passport. This raises two follow-up questions for a company that are not separate from each other: which underlying data (for example disassembly sequence or parts suppliers) belong to that score, and who may see that underlying data. For the first question, the breakdown per product group is relevant, described at which data will appear in the product passport for electronics?. For the second question, not every piece of data on which the score is based is automatically made public; that distinction is described at who may view which data from the product passport?.

The score must remain current when the product is changed

A repairability score is linked to a specific version of a product. If a manufacturer changes a component, the attachment of a housing, or the availability of a spare part, the previously established score is not automatically still valid. For a company with a limited number of product variants, this is usually manageable, but with frequent product changes — often particularly with ICT peripheral equipment — there is a risk that a passport shows a score that no longer matches the current version. This touches on the broader question of how often data must be updated, developed at how often must I update the data in the product passport?.

Where things go wrong in practice

A few situations keep coming up with companies that are already preparing for repairability requirements, even though the delegated act for electronics and ICT is not yet in place:

• The score is internally "estimated" on the basis of a comparable product. Without a measurement carried out according to the prescribed method, a score is not substantiated, even if the product is technically very similar to another model.
• Repair instructions are written, but not linked to the score. The repairability score relies on specific, measurable criteria; an instruction manual in itself is not proof that those criteria have been met.
• Spare parts delivery time is not recorded. A score that partly depends on the availability of spare parts becomes outdated as soon as a supplier stops supplying a part or changes the delivery time, without this being recorded anywhere.
• The score is viewed separately from software support. For ICT equipment, useful repair often depends on how long software is supported; anyone who does not record this alongside the repairability data misses part of the picture that the question at must I record how long a device receives software updates? describes.
• Errors in a previously published score are not corrected. Once a product change affects the score, failure to correct it is a different problem than the absence of the score; how an identified error is handled is described at I have discovered an error in the product passport, what now.

What you can document

• The test setup and measurement method used to determine the repairability score, including date and responsible party.
• An overview of the parts included in the assessment, with the location of spare parts and estimated delivery time.
• The link between product version and score, so that when a product is changed it is clear which score is still valid.
• Repair instructions and the date these were published or updated.
• A log of corrections to previously published scores, with reason and date of change.
• Agreements with suppliers on communicating changes that may affect the repairability score.