The EU's Repair Agenda Has a Disproportionate Impact on US Technology Firms

The EU's repair policy framework, spanning product design, repairability, and broader circular economy rules, aims to extend product lifespans and expand consumer repair options. Alongside similar measures across other jurisdictions, however, these policies are creating a fragmented and increasingly complex compliance landscape—one that shapes core decisions about product design, repair, and distribution across global markets, with a disproportionate burden on U.S. firms.

The EU framework centers on three main elements: the Ecodesign for Sustainable Products Regulation (ESPR), which sets requirements for product durability and repairability; the Right to Repair Directive, which establishes obligations for manufacturers to facilitate repairs; and EU repairability scores, which provide consumers with information about how easy products are to fix.

The ESPR is the most expansive of these measures, replacing the 2009 Ecodesign Directive, and extending EU sustainability requirements beyond energy efficiency to cover durability, repairability, and recyclability. A central requirement is the Digital Product Passport (DPP), which requires manufacturers to maintain detailed information on a product's materials, repair characteristics, and supply chain.

The regulation also establishes a two-stage compliance structure. Horizontal obligations, such as the DPP, apply across all product categories, while more detailed, product-specific rules will follow. In practice, this structure is likely to weigh most heavily on software-integrated electronics—including tablets, smartphones, and laptops—where U.S. firms hold significant market share.

Unlike many Chinese and Japanese competitors, which run on Google's publicly available Android platform and source largely standardized components, U.S. companies such as Apple and Microsoft operate highly integrated ecosystems in which key software layers, components, and supply chain relationships are closely coordinated—though the degree of openness varies, particularly in Google’s case, where its Android devices include both open-source and proprietary elements.

The DPP's requirement for full supply chain documentation across every supplier tier is uniquely burdensome for U.S. firms. Their proprietary ecosystems contain architecturally sensitive information whose disclosure could dismantle the competitive advantage U.S. companies have spent decades building.

Furthermore, these firms manage massive volumes of product variants, each with distinct components, software versions, and vertically integrated supply chains, and each requiring its own DPP. Complying with ESPR mandates means mapping a supplier base spanning thousands of direct suppliers across 30 to 50 countries.

Rapid product cycles further compound the challenge. Unlike manufacturers in slower-moving categories such as household appliances, American tech firms cannot phase in new requirements incrementally. The tight integration of hardware, software, and supply chains means that even narrow, product-specific mandates can trigger immediate firmware updates, supply chain reengineering, and costly redesign. These changes are difficult to defer or isolate, creating a continuous, unpredictable, and open-ended compliance burden.

Another tool in the EU's repair ecosystem is the Right to Repair Directive, which requires manufacturers to repair their products beyond the standard warranty period, in some cases for up to 10 years, and to make spare parts, tools, and repair information available to independent third-party repairers.

The directive introduces a ban on “parts pairing,” a practice in which manufacturers use software to lock devices so they fully function only when the manufacturer's system authenticates replacement components. For U.S. firms such as Apple and Google, parts pairing is foundational to their software-integrated electronics ecosystems, serving as a quality control and safety measure.

It creates a cryptographic bond between replacement components and the device's security chip, ensuring that unverified parts cannot handle sensitive functions like Face ID and Touch ID. Without it, a device cannot distinguish between a genuine component and a counterfeit one, and even a genuine part installed without authentication may carry an incompatible firmware version, posing security risks.

Once enforced, the directive will compel firms to dismantle this authentication process, leaving manufacturers legally responsible for security breaches and device failures caused by components they did not verify. Competitors whose open-source ecosystems are not built around parts pairing face no equivalent burden.

U.S. firms release new product generations every 12 to 18 months. A decade-long spare-parts obligation means maintaining inventory across six to eight product generations simultaneously, requiring manufacturers either to stockpile components upfront or pay suppliers to sustain production lines for commercially obsolete parts—both at enormous cost. For software-integrated electronics, where chip architectures become obsolete within two to five years of launch, this is an impractical mandate.

As an incoming regulation, the directive compounds existing ESPR obligations that the EU is still phasing in, adding uncertainty and further expanding the compliance burden for American firms.

The EU Repair Score, displayed on the packaging of smartphones and tablets, ranges from A (most repairable) to E (least repairable) and draws on six parameters. The scoring parameters penalize proprietary design, and low scores carry real commercial consequences. Since its implementation in June 2025, U.S. companies have received some of the weakest scores: Apple scored D- and Google C- for smartphones, while Apple scored C- and Microsoft B- for laptops. Motorola, which uses more standardized components, scored B+.

For U.S. firms, improving their scores often requires redesigning products toward greater modularity and component standardization, potentially diluting the performance, security, and integration benefits of proprietary architectures. The practical effect is to shift competition away from differentiated system design toward conformity with the scoring framework, raising compliance costs while narrowing the scope for innovation.

Beyond Europe, India launched a Right to Repair portal covering mobile and electronic products, Taiwan piloted a repairability index modeled on the European system, and Australia's Productivity Commission has proposed mandating access to repair information, spare parts, and product repairability labeling. New Zealand, Brazil, and Colombia are also advancing frameworks targeting planned obsolescence and parts access.

U.S. policymakers should respond to protect U.S. economic interests. The United States should proactively engage in international standards development, including through the International Electrotechnical Commission (IEC), to ensure emerging guidance reflects software-enabled repair and diverse business models rather than defaulting to the EU’s hardware-centric approach. At the same time, the Office of the United States Trade Representative should press for alignment around a practical, IEC-based standard in bilateral trade negotiations, encouraging convergence rather than fragmentation.

The United States has both the leverage and credibility to shape these rules. Failing to do so risks ceding the field to a framework that constrains U.S. firms’ market access and competitive position.