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The Restart Project

The Restart Project is a charity based in London, UK.

Lobbying Activity

Response to Circular Economy Act

6 Nov 2025

Please find our feedback hereby attached.
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Response to Consumer Agenda 2025-2030 and Action Plan on Consumers in the Single Market

30 Aug 2025

See Right to Repair Europe's document attached.
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Response to Sustainable products - disclosure of information on unsold consumer products

10 Jul 2025

The Right to Repair Europe coalition welcomes this opportunity to share feedback on the draft Commission Implementing Regulation laying down rules for the application of Regulation (EU) 2024/1781 as regards the details and format for the disclosure of information on discarded unsold consumer products. The coalition supports the improvements suggested by our member organisation ECOS to the draft Implementing Regulation: Clarify that the ESPR reporting requirements will apply regardless of the date of application of the Implementing Regulation. Require companies that include unsold goods reporting in their sustainability reporting to clearly mention it on their website and indicate where to find that information in their report. Require limited assurance for all companies covered by the unsold goods reporting requirements. Companies should always partner with waste treatment operators and know the destination of their discarded products. Unknown destination should not be accepted in the reporting. Planned preventive measures should be specific to ensure that they are implementable and implemented, to avoid empty promises. Please see ECOSs supporting document for more detailed information on these elements. In addition, we would like to provide more detailed feedback on the product categories that companies should be required to report on, and specifically on the unsold goods that should be reported using a 4-digit CN code. The ESPR has the power to impact countless everyday products and drive meaningful change. The disclosure on the destruction of unsold consumer goods could provide vital data on a wide range of products. The growing flow of e-waste is widely composed by a great diversity of small devices and gadgets. To maximize the effectiveness of reporting on unsold goods, the European Commission must ensure broad product coverage, capturing as many categories as possible. At the same time, maintaining a certain level of granularity is crucial for an accurate and comprehensive assessment. We therefore wish to congratulate the European Commission for adding some product categories to the list for which a 4-digit CN code is mandatory. However, to ensure comprehensive coverage, the CN-code list should align with established frameworks such as Annex IV of the WEEE Directive and the JRC study JRC139725 on product relevance for a Reparability Scoring System. We also propose to take into account the product categories of the Open Repair Data Standard, and featured in the recent Open Repair Alliance (ORA) report. Tables 1 and 2 (attached) highlight the remaining gaps and further research is needed to identify the corresponding CN-Codes.
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Response to Correcting act of Commission Regulation (EU) 2023/1670 laying down ecodesign requirements for smartphones and tablets

8 May 2025

The Right to Repair Europe coalition represents over 180 organisations from 30 European countries, including environmental NGOs and repair actors such as community repair groups, social economy actors, spare parts distributors, self-repairers, repair and refurbishing businesses. The coalition regrets both the timing of the proposed change mere weeks before the entry into force of the Regulation, and the way in which it reduces the ambition of the regulatory text. Specifically, we object to the proposed corrections to the respective sections 1.1 (5) b) in all parts of the regulation (adding the display as an exception to the requirement), since in fact, these significantly reduce the Regulations level of ambition when it comes to disassembly requirements. Batteries and displays are the two parts that most frequently need replacement in smartphones and similar devices. It would therefore seem logical to ensure that these parts could be replaced by end-users. The regulations wording as it was negotiated, voted and officially published, provides requirements to that effect by means of two sets of requirements (sections 1.1 (5) a) and b)), which can be considered to be complementary. Given that broken displays are one of the most frequent causes of smartphones being discarded, this requirement had the potential to unlock a huge potential for the extension of smartphone lifetimes. However, the proposed corrections to the respective sections 1.1 in parts A, B, C and D of Annex II to the Regulation would mean that the display, even though it would still need to be made available to end-users, would not need to be user-replaceable (i.e. replaceable by a layman in a use environment with basic tools) for any of the covered product categories (mobile phones other than smartphones, smartphones, cordless phones and tablets). It would instead be subject to the same requirements for ease of disassembly as are much less frequently replaced parts such as camera assemblies, microphones, speakers and charging ports. The display would therefore become the only part that needs to be supplied to users, but not replaceable by them. The resulting requirements seem incoherent and lacking in ambition given the current climate and material supply crises, and the technical feasibility of user-replaceable displays as proven by several manufacturers. The Right to Repair Europe coalition proposes an alternative means of removing the duplicate content while preserving the level of ambition of the regulatory text as it was voted and published: - In parts A, B and D of Annex II to the Regulation (mobile phones, smartphones and tablets), in the perspective sections 1.1 (5) a), we propose to delete the mention of display assembly and of; - In part C of Annex II to the Regulation (cordless phones), section 1.1 (5) a), we propose to add with the exception of the display assembly to parts referred to in point 1(a), and in section 1.1 (5) b),to add and display to battery. Additionally, in line with the corrective acts aim to remove duplicate content from the Regulation, we propose to address another duplication which has gone unaddressed in the proposed corrective act: the availability of the battery or batteries, which are mandated for each product (A-B-C-D), under both 1.1 1) a) and c), to different target groups. As section 1.1 1) c) refers to professional repairers and end-users, the mention of the battery or batteries in section 1.1 1) a) referring only to professional repairers is superfluous. We therefore propose to delete section 1.1 1) a) i) battery or batteries and keep only the reference in section 1.1 1) c) i) a). We attach our detailed position.
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Response to Repairability score for tumble dryers

3 Dec 2024

The Right to Repair Europe coalition represents over 170 organisations from 27 European countries. It represents repair actors such as repair and refurbishing businesses, spare parts distributors, community repair groups, social economy actors, self-repairers, environmental NGOs and any citizen who would like to advocate for their right to repair. This is a rapidly growing movement with the objective to make repair affordable, accessible and mainstream. Browse member organisations by country here: https://repair.eu/our-network/ This note builds upon the one we published in April 2024, following the Ecodesign and Energy Labelling Consultation Forum meeting held on March 11, 2024. We acknowledge the publication of the draft act on November 5, 2024, and appreciate the Commission's consideration of certain elements from our earlier note. However, we note that some important aspects remain unaddressed, which we have highlighted in this updated note (pdf attached).
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Meeting with Lucie Rousselle (Cabinet of Commissioner Didier Reynders)

26 Jan 2024 · Discussion on the proposal on promoting the repair of goods, to explain the position of the Right to Repair Europe Coalition, representing more than 130 organisations.

Meeting with Sunčana Glavak (Member of the European Parliament, Rapporteur for opinion) and DIGITALEUROPE

5 Jul 2023 · Right to repair ENVI Opinion

Response to Promoting sustainability in consumer after-sales

25 May 2023

Right to Repair Europe welcomes the Commissions proposal for a directive on Common Rules Promoting the Repair of Goods, and this opportunity to provide feedback on the proposal. Although this proposals intent to grant Europeans a right to repair their products is a step in the right direction, the policy options outlined in the proposal do not grant a universal right to repair. In order to truly incentivise the uptake of repair and shift towards a circular economy, the following considerations must be taken into account by the co-legislature. Amendments to consumer legislation in order to promote repair only make sense if devices are repairable in the first place: consumer legislation can only complement ambitious ecodesign requirements. We are advocating for a universal right to repair, which means allowing consumers to seek repair from the provider of their choice, or to carry out the repair themselves. Availability of parts and instructions for independent repairers and consumers is essential to ensure wider and easier access to repair solutions. Access should be granted within a reasonable time and at a reasonable and non-discriminatory cost, for a period corresponding to at least the expected lifespan of the product. Anti-repair practices preventing or limiting repair beyond manufacturer authorised networks must be banned. This notably includes designs where original manufacturers have to remotely authorise a part replacement before full functionality is restored, or where serial numbers of the part and product have to be synchronised via proprietary software (part pairing/serialisation). Repair will only become a more attractive, or in fact viable, option for consumers if it is affordable. In the current climate of soaring living costs, tackling the affordability of repair should be high on the political agenda. To drive the costs of repair down, access to spare parts must be guaranteed at a reasonable cost, for a period corresponding to at least the expected lifespan of the product. To achieve this, recognition of second hand and third party spare parts is essential. The proposal should further promote the affordability of repair via limitations on the price of spare parts through a mention that it should be reasonable and non discriminatory. Finally, the proposal should make price a criterion of the EU repair index and provide an EU framework for financial incentives. Some stakeholders claim that subsidising repair costs would encourage poor practices in use and maintenance of products. We strongly disagree, as the high cost of repairs is still a key barrier between a product being theoretically repairable and actually repaired. The current system implicitly incentivises product replacement over repair, by not factoring all externalities associated with the throwaway economy. Please see the file attached for more detailed feedback Contact: Cristina Ganapini, Coordinator of the EU Right to Repair campaign: info@repair.eu
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Response to Ecodesign for Sustainable Products - Product priorities

11 May 2023

Feedback from Right to Repair Europe on the exclusion of electronic products from the list of priority products The Right to Repair Europe coalition represents over 100 organisations from 21 European countries. It represents environmental NGOs and repair actors such as community repair groups, social economy actors, spare parts distributors, self-repairers, repair and refurbishing businesses, and any citizen who would like to advocate for their right to repair. This is a rapidly growing movement, and its objective to make repair affordable, accessible and mainstream is aligned with the objectives of the European Green Deal and the Circular Economy Action plan. Browse member organisations by country here. E-waste is one of the EUs fastest growing waste streams due to the proliferation of short-lived, unrepairable consumer electronic products flooding the EU market today. The electronics industry is currently among the top eight sectors accounting for more than 50% of the global carbon footprint. Yet no electric and electronic products are included in the questionnaire of the present consultation. Many important electronic product categories were not taken forward in the Ecodesign Working Plan and were also not incorporated into the current consultation on ESPR product priorities. There is a risk that these products will fall through the gaps between these two separate investigation streams and be left unregulated, resulting in sizeable missed environmental savings. - Electronic products represent significant volumes of sales and trade - Electronics have significant environmental impacts in terms of resource use, CO2 emissions, biosphere degradation and waste production - There is significant potential for improvement in terms of their environmental impact Prioritizing this problematic product group would send a clear message to industry that the EU will crack down on such low-quality products being placed on the EU market, and so will begin the shift away from the proliferation of such products. It is imperative that this highly impactful product group does not slip through the legislative cracks, which could occur if not prioritised in neither this list of product priorities, nor the Ecodesign working plan for energy related products. We therefore call on the Commission to urgently address the environmental impact of electronic products by prioritising this product group for Ecodesign measures.
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Response to Measures addressing the environmental impact of imaging equipment including consumables

20 Feb 2023

The Right to Repair Europe coalition includes environmental NGOs and repair actors such as community repair groups, social economy actors, self-repairers, repair and refurbishing businesses, and any citizen who would like to advocate for their right to repair. This is a rapidly growing movement, and its objective to make repair affordable, accessible and mainstream is aligned with the objectives of the European Green Deal and the Circular Economy Action plan. The Right to Repair Europe coalition and the Coolproducts campaign welcome the publication of the call for evidence for an impact assessment on imaging equipment including the Commission's understanding of the problem and possible solutions. We call for the implementation of Option 4 a combination of ecodesign requirements and energy labelling. There is a need for an ambitious Ecodesign and Energy Labelling regulation to address the energy and material efficiency of imaging equipment and their associated consumables. Such a regulation would send a strong signal to manufacturers of other wasteful products: EU institutions can legislate if no concrete action is taken by manufacturers to end these practices. The attached document explains where we observe that there is potential for improvement in the Commission's understanding of the problem and possible solutions. In particular, we have: - highlighted data that was not considered by the call for evidence in the identification of problems that the initiative aims to tackle. - suggested additional objectives and policy options that must be considered by the Commission in order to avoid loopholes and build futureproof ecodesign requirements
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Response to Review of the Designs Directive

31 Jan 2023

The Right to Repair campaign supports the proposed revision of EU rules on industrial design regarding the introduction of a repair clause. The repair clause would harmonise EU rules on aftermarket spare parts, as such rules are currently fragmented across member states. An open competitive market for spare parts is necessary to ensure that repairing products becomes economical relative to the price of buying a new product. This clause would therefore be a step towards such an open repair market, and it would also provide legal certainty for repairers and providers of spare parts. However, the current proposal for the repair clause could be strengthened. 1. The impact of the repair clause should be accelerated. First of all, the proposed transition period of 10 years is too long and will lead to further barriers to repair. Spare parts will continue to be unaffordable until the repair clause is in place, thus leading consumers to replace their faulty products with new ones. This in turn will entail the continued growth of waste as unrepairable products are discarded. With this in mind, we suggest that the transition period be shortened to 2 years. Furthermore, in line with Option 1.1 of this proposals impact assessment, we recommend that the repair clause be extended to apply to both existing and new designs, in order to be applicable to designs granted before and after its entry into force. This will accelerate the benefits of the inclusion of the repair clause in this legislation. 2. Guidance is needed for repairers and providers of replacement spare parts. In order to ensure that the rules are correctly understood amongst repairers and providers of spare parts, clarity regarding the scope of parts concerned by the repair clause is needed. Potential confusion could arise regarding how to distinguish replacement parts exclusively used for repair, from other activities that resemble repair. This has been the case in instances such as the Acadia case in the EU Court of Justice (C-397/16 (Acacia) (CJEU). To avoid confusion, we suggest that if a part can be used for repair, it should be covered by the repair clause (thereby exempted from design protection), regardless of the actual use case. This will facilitate the applicability of the repair clause. Similarly, confusion has arisen on the labelling requirements for third-party spare parts in countries where a repair clause is already in place. This issue arose in a case brought to the German Federal Court of Justice, where a dealer of third party spare parts did not meet the labelling requirements necessary for a spare part that was not from the original manufacturer. To make the new rules accessible for repairers, the EU should provide clarity on what information requirements the part must have, whether this information should be on the website, and in which languages it must be in. 3. Note on the interaction between design law and copyright. A shortcoming in the proposed amendments to the Design Directive is that they do not address the exclusive rights in software that may be necessarily implicated in the process of manufacturing or installing a computerised replacement part of a computer system. Parts pairing or authentication processes are one such example of software dependency. In these cases, the functionality of replacement parts will depend on authorisation and interoperability with a computer system or systems. To achieve this functionality at the point of manufacture or installation, this may require circumvention of technological protection measures or the reproduction, use, or access of proprietary software. In order to give effect to the harmonisation goals of this renewed Directive, the EU legislator must address the relationship between replacement parts, software copyright, and related protection measures used by manufacturers. Our full feedback can be consulted in the attached document.
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Response to Environmental impact of mobile phones and tablets - Energy Labelling

28 Sept 2022

Right to Repair Europe is a coalition of European organisations pushing for system change around repair. For more information on the composition of the campaign visit: https://repair.eu/ Please find attached our feedback on "Energy labelling of mobile phones and tablets – informing consumers about environmental impact"
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Response to Environmental impact of mobile phones and tablets - Ecodesign

28 Sept 2022

Right to Repair Europe is a coalition of European organisations pushing for system change around repair. For more information on the composition of the campaign visit: https://repair.eu/ Please find attached our feedback on "Designing mobile phones and tablets to be sustainable – ecodesign"
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Response to Sustainable Products Initiative

22 Jun 2022

Right to Repair Europe’s reaction to ESPR Right to Repair Europe is enthusiastic about the publication of the Ecodesign for Sustainable Products Regulation (ESPR) which has the potential to improve the way products on the EU market are designed and serviced. This regulation could mean a leap towards achieving a European right to repair. It could also inspire non-EU countries to draft policies for more reliable, repairable and reusable products. To perfect the ESPR, we recommend the following: - Horizontal requirements should be set where possible To gain efficiency and reduce risks of having too many unconstructive exceptions, it is essential for the Commission to tackle several product types at once: - Horizontal repairability requirements for problematic product groups like small kitchen appliances, home audio/visual and connected devices should be prioritised in the draft work plan due later in 2022. - Ban any practice preventing repair outside of manufacturers' networks: Repairers and refurbishers are often hampered in their activities because of certain manufacturer’s practices. Such practices should be horizontally banned for all products and people should have a right to install any operating system on any device. - Clear responsibilities for online marketplaces: To tackle the widespread import of non-compliant products, online marketplaces facilitating the sale of products should assume clear responsibilities. To avoid obscure sellers and lack of accountability, market places must implement strict vetting processes that enable the traceability of their sellers. - Guarantee access to information on repair: The development of a Digital Product Passport is welcomed and should facilitate access to repair information. The Commission must remain aware of the importance of transparent access to repair information (so the repairer/refurbisher can test or repair the product correctly) and give it priority when opposed to manufacturer’s confidentiality and Intellectual Property rights. - Allow consumers to take legal action against non-compliant products: Market surveillance authorities, unless their budget and capacity are significantly enhanced, won’t be able to comprehensively prevent breaches to ecodesign requirements. Allowing consumers to take legal action against non-compliant products will greatly increase the enforceability of the ESPR. Ecodesign related procedures should be more inclusive - Remove voluntary agreements (VAs) from the suggested options: VAs developed by industry have yielded meagre results and become infamous due to their poor market coverage, weak requirements, and delays in adapting to technological developments. Also, VAs for printers and games consoles haven’t resulted in the expected reduced human resources burden for the Commission. - Significantly increase resources allocated to ecodesign: The Commission is already behind schedule in the development and implementation of essential ecodesign and energy labelling policies. With no resource increase, the ESPR proposals will never materialise or will be solely driven by industry’s interests. - Support inclusiveness in development of ecodesign requirements: The Commission must ensure that civil society NGOs, repairers/refurbishers, consumers, social enterprises and environmental concerns are well represented in these processes, notably through allocating resources to help these organisations contribute. Definitions should be improved - Define and protect second-hand operators and independent repairers: The status of independent repairers and second-hand operators (including repair cafes, non-profit community repair initiatives, professional repairers and refurbishers) is poorly defined and risks being compared to the status of operators placing new products on the EU market. Fine tuning the “Refurbishment” definition, adding definitions for “second-hand products” and “second-hand operators” should bring clarity.
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Response to Empowering the consumer for the green transition

28 May 2022

Right to Repair Europe welcomes the proposed amendments to the Unfair Commercial Practices Directive and the Consumer Rights Directive as a first step to reduce obsolescence and provide information on repairability. However, far stricter rules are needed to prevent business practices which unnecessarily and deliberately shorten the lifetime of devices. Our response to the proposals is as follows: 1. Information on the existence and length of a producer’s commercial guarantee of durability Efforts to provide greater clarity on the provision of commercial and legal guarantees are welcome. However, the proposal could be improved as follows: • It should be made clear to the consumer whether there is a fee for the commercial guarantee or not (with respect to recital 62, 2019/771/EC) • When information is not provided by the producer, the information requirement should apply to all sectors, not just energy using products. Many products not using energy can reasonably have an expected duration of use longer than 2 years (e.g. furniture). • When product groups are assessed under the new Ecodesign framework, an appropriate lifetime from a sustainability perspective should be established per group, and this should be the basis for the length of the legal guarantee. 2. Providing information on the availability of free software updates for all goods with digital elements, digital content and digital services. Information at the point of sale on the duration of software updates is welcome. However, according to 2019/771/EC, the seller may be anyway obliged to provide software updates for a time beyond the conformity period. We suggest the following: • The minimum period for providing updates for a device should be communicated alongside the number of years offered by the vendor to encourage competition. If no information is provided, the consumer should be informed. • In general, the availability of software updates should be aligned with other factors of product longevity, like the duration for which spare parts are available. 3. Providing information on repairability While we welcome the provision of information on product reparability, there is currently no EU repair score, so the information provision will be limited to vague information on the availability of spare parts and manuals. We suggest the following: • “spare parts” is currently undefined, so this could be circumvented by only providing limited or unimportant parts. We suggest referring to “spare parts indispensable to the repair of a good” to ensure all necessary spare parts are provided. • The period for which spare parts are available should be indicated. Consumers should be informed if parts, tools and manuals have not been provided by the producer. 4. Misleading consumers about the durability and repairability of products and a ban on certain practices related to the early obsolescence of goods While we welcome efforts to prevent certain practices relating to the obsolescence of goods, we wonder whether these provisions are practicable. We are concerned that the approach taken to focus on enforcing providing information on obsolescence, rather than banning practising premature obsolescence, may be difficult to enforce. • We think a general prohibition on practices which “foreseeably reduce the lifetime of a product” would be much more powerful in curbing obsolescence, and should be added. • Inducing consumers to replace consumables earlier than is necessary, limiting product durability, or using software locks or part-pairing to limit functionality if non-OEM spares or consumables are used should be banned altogether • We propose to add two new Unfair Commercial Practices to Annex 1: 1) Omitting to inform that the seller will refuse to perform a repair on a product that has previously been repaired in another professional network, beyond the legal guarantee. 2) Omitting to inform whether or not a software update is necessary to keep the product in conformity.
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