Right to repair for domestic heating: what manufacturers must do

Key data

Domestic local heating appliances are incorporated into the European right to repair framework. The Delegated Directive (EU) 2026/74, published on 20 April 2026, amends Annex II of Directive (EU) 2024/1799 to include these products, which until now were excluded from the repairability obligations established in that framework directive.

The impact is direct for manufacturers and distributors: compliance with the legal warranty is no longer sufficient. From the entry into force of this regulation, they must ensure that appliances can be repaired under reasonable and economically accessible conditions, even after the warranty expires.

What does this regulation establish?

Directive 2026/74 acts as a delegated regulation that expands the scope of application of Directive (EU) 2024/1799, the European regulation that promotes the repair of goods. Specifically, it amends its Annex II to add domestic local heating appliances regulated by Regulation (EU) 2024/1103 on ecodesign.

This means that these products are subject to the same repairability regime that already applies to other goods included in that annex. The specific obligations that arise are:

• Availability of spare parts: manufacturers must ensure that the parts necessary to repair the appliance are available for a reasonable period after it is placed on the market.
• Access to technical information: manufacturers and distributors must provide professional repairers with the technical documentation necessary to carry out repairs.
• Reasonable repair conditions: the economic and technical conditions for access to parts and information cannot be discriminatory or disproportionate.
• Consumer right to repair beyond warranty: consumers will be able to demand repair under economically accessible conditions even after the legal warranty period has ended.

Economic and operational impact

For companies in the sector, this regulation has concrete operational consequences that go beyond legal compliance. The main impacts are:

• Spare parts supply chain: companies will need to review and adapt their spare parts management to ensure prolonged availability. This may involve agreements with suppliers, minimum stock management or changes to distribution contracts.
• Technical documentation: it will be necessary to prepare, translate and keep updated the technical information of the appliances to make it available to professional repairers under reasonable conditions.
• After-sales business model: the obligation to facilitate accessible repair can open or strengthen the channel for own or authorized third-party technical service.
• Reduction of planned obsolescence: the regulation reinforces the circular economy and implicitly penalizes business models based on frequent appliance replacement due to lack of spare parts.

The measure is part of the European circular economy strategy and complements the ecodesign requirements already established by Regulation (EU) 2024/1103, which regulates the efficiency and sustainability standards for these same appliances.

Who does it affect?

• Manufacturers of domestic local heating appliances that place products on the EU market regulated by Regulation (EU) 2024/1103.
• Distributors of these appliances in the European market, who are also subject to obligations regarding access to spare parts and technical information.
• Professional repairers in the sector, who benefit from the right to access spare parts and technical information under non-discriminatory conditions.
• Importers of domestic local heating appliances from third countries that place them on the EU market.
• End consumers, who acquire the right to demand repair under economically accessible conditions beyond the legal warranty period.

Practical example

A European manufacturer of domestic electric heaters markets a model that has been on the market for three years. Until now, once the two-year warranty expired, it had no regulatory obligation to keep spare parts available or to provide technical information to external workshops.

With Directive 2026/74, that same manufacturer must:

• Keep available the spare parts necessary to repair the appliance for a reasonable period after it is placed on the market.
• Provide professional repairers with the technical documentation of the appliance (diagrams, service manuals, error codes) under economically reasonable and non-discriminatory conditions.
• Ensure that a consumer whose heater breaks down outside the warranty period can access repair under accessible conditions, without being forced to buy a new appliance due to lack of spare parts or technical information.

Operationally, this involves reviewing contracts with component suppliers, updating the after-sales policy and preparing technical documentation in the languages of the markets where the product is distributed.

What should companies do now?

1. Identify if your products are regulated by Regulation (EU) 2024/1103: check if the domestic local heating appliances you manufacture or distribute fall within the scope of that ecodesign regulation, as this is the criterion that determines whether Directive 2026/74 applies to you.
2. Audit the spare parts supply chain: review what spare parts are available, for how long and under what conditions. Identify bottlenecks and negotiate with suppliers to ensure prolonged availability.
3. Prepare and structure technical documentation: compile service manuals, technical diagrams, parts lists and any information necessary for repair. Define how it will be provided to professional repairers and under what economic conditions.
4. Review distribution and after-sales contracts: ensure that agreements with distributors and authorized repairers are consistent with the new obligations regarding access to spare parts and information.
5. Monitor the entry into force date: the regulation was published on 20 April 2026 but the effective application date has not been specified. Monitor the official source at EUR-Lex for updates.

Frequently asked questions

Q: Does this regulation apply to all heating appliances?
A: No. It applies specifically to domestic local heating appliances regulated by Regulation (EU) 2024/1103. Central heating systems and other types of heating are not included.

Q: What is considered a "reasonable period" for spare parts availability?
A: The regulation does not specify an exact number of years. It will depend on the product category and may be clarified in implementing guidelines or case law. Generally, it should be proportionate to the expected useful life of the appliance.

Q: Can manufacturers charge for providing technical information to repairers?
A: Yes, but the charges must be reasonable and non-discriminatory. They cannot be used as a barrier to prevent professional repairers from accessing necessary information.

Q: What happens if a manufacturer does not comply?
A: Member States are responsible for enforcement. Non-compliance can result in administrative fines, product withdrawal from the market, or legal action by consumers or competitors.

Official source

Commission Delegated Directive (EU) 2026/74 of 12 January 2026 amending Annex II of Directive (EU) 2024/1799 of the European Parliament and of the Council as regards the inclusion of local heating appliances. Published in the Official Journal of the European Union on 20 April 2026.

Disclaimer: This article is for informational purposes only and does not constitute legal advice. The interpretation and application of EU regulations may vary depending on national implementation and specific circumstances. Companies should consult with legal and compliance specialists to ensure proper implementation of these obligations. The information is current as of the publication date and may be subject to updates or clarifications from EU institutions.