Repairability Score (Grades A–E) System Under ESPR-Family Ecodesign Regulations — Implementation for Smartphones and Tablets, and Prospects for Horizontal Expansion
ENFORCEMENT TIMELINE
Applies since June 20, 2025 (under Regulation (EU) 2023/1670 and Delegated Regulation (EU) 2023/1669; horizontal expansion to other product categories depends on future delegated acts)
Overview
This card focuses on the evaluation parameters, display obligations, and prospects for horizontal expansion to other product categories of the "repairability score (Grades A–E)" system that has applied to smartphones, feature phones, cordless phones, and tablets since June 20, 2025.
This repairability score is based on the Ecodesign Regulation (Regulation (EU) 2023/1670) and the Energy Label Delegated Regulation (Regulation (EU) 2023/1669), and specialises for smartphones and tablets a general repairability assessment methodology developed by the European Commission's Joint Research Centre (JRC) in 2019. The assessment combines factors such as the number of steps required for disassembly, whether proprietary tools are needed, the availability and price of spare parts, the duration of software support, and the availability of repair manuals, and is displayed on the energy label on a five-tier scale from A (easiest to repair) to E (hardest to repair). Covered products are also required to be registered in the EU's product database (EPREL). This system is an early implementation of the repairability parameter concept established under Article 5 of the ESPR, and based on the ESPR's Working Plan, it may be expanded horizontally to other home appliance and electronics categories in the future.
Enforcement Timeline
June 16, 2023: The Ecodesign Regulation (Regulation (EU) 2023/1670) and the Energy Label Delegated Regulation (Regulation (EU) 2023/1669) are adopted.
June 20, 2025: Both regulations enter into full application. Display of the A–E repairability score and EPREL registration become mandatory for smartphones, tablets, and other covered devices. Obligations also take effect simultaneously requiring batteries to retain at least 80% capacity after 800 charge/discharge cycles, spare parts to be provided for 7 years after sales end, and OS updates to be provided for at least 5 years.
February 18, 2027: Under the EU Battery Regulation, the requirement for smartphones to carry a user-replaceable battery takes effect (a related obligation that interacts with the repairability score system).
Going forward: Based on the ESPR Working Plan, the repairability score evaluation framework is expected to be expanded horizontally to other consumer electronics categories (specific scope and timing to be confirmed through future delegated acts).
Business Impact
Smartphone and tablet manufacturers face design and supply-chain decisions — reducing the number of disassembly steps, enabling disassembly with standard tools, setting reasonable spare-part pricing and building distribution capacity, and providing non-discriminatory software and firmware access to independent repairers — that translate directly into competitiveness for achieving a high A–E grade. Because a low grade display directly affects consumer purchasing decisions, manufacturers also need to build a system for accurately registering the underlying grading data in EPREL.
Because the repairability score evaluation framework is likely to expand to other electronics categories through the ESPR Working Plan going forward, electronics manufacturers currently handling products outside the smartphone and tablet categories also benefit from proactively considering design policies aligned with the same evaluation axes — ease of disassembly, spare-part availability, and software support duration — to help contain future compliance costs.