Since 31 July 2026, member states have been applying the rules of Directive (EU) 2024/1799 on promoting the repair of goods (Art. 22). In Germany, the resulting manufacturer duties sit in Sections 479a to 479f of the German Civil Code (BGB): anyone who manufactures goods from the eleven product groups in Annex II of the Directive must repair them at a consumer's request, offer spare parts at a reasonable price and publish guide prices for typical repairs on a freely accessible website. On top of that comes a change in sales law that affects every seller with its own online store: where the remedy is provided by repair, the limitation period for claims arising from a defect is extended once by twelve months (Section 475e(5) BGB). None of this is boilerplate for the legal page. It is data that originates in the ERP - bill of materials, costing, serial number, service order - and that rarely reaches the places where consumers and repairers look for it. This article describes the path from device to spare part, from costing to guide price page and from repair order to the extended deadline per unit sold, for manufacturers in ERP integration for industrial companies as well as for brands in interface work for electronics and technology.
Key takeaways
- Member states have applied the repair rules of Directive (EU) 2024/1799 since 31 July 2026; in Germany, the manufacturer duties sit in Sections 479a to 479f BGB.
- The repair duty covers goods from the eleven product groups in Annex II of the Directive that a consumer bought and for which the consumer does not have the rights under Section 437 BGB (Section 479a BGB).
- Spare parts and tools must be offered at a reasonable price that does not discourage repair (Section 479c BGB). The mapping from device to spare part therefore belongs in the ERP as a service BOM.
- Guide prices for typical repairs go on a freely accessible website (Section 479d(2) BGB). The law speaks of calculated prices - the source is the ERP costing, not a manually kept table.
- Where the remedy is provided by repair, the limitation period is extended once by twelve months (Section 475e(5) BGB). That is a field in the warranty record per unit sold, not a note in a ticket.
How the repair duty differs from a warranty case
Sales law already provides for repair - as the seller's remedy within the statutory warranty. Sections 479a et seq. BGB start at a different point. They oblige the manufacturer to repair goods at a consumer's request (Section 479b(1) BGB), specifically for goods for which the consumer does not have the rights under Section 437 BGB (Section 479a no. 3 BGB). The repair duty therefore typically begins where the warranty ends or does not exist at all. It applies as long as and to the extent that the manufacturer must ensure reparability, including the availability of spare parts, under the legal acts listed in Annex II of the Directive (Section 479b(2) BGB), and the repair is carried out free of charge or for a reasonable fee (Section 479b(3) BGB).
For the system landscape this means there are two kinds of repair process with a different legal basis, different pricing logic and different consequences for deadlines. The warranty case is directed at the seller and is a remedy within the meaning of Section 439 BGB - and only that remedy triggers the extension of the limitation period. The repair claim under Section 479b BGB is directed at the manufacturer and may cost a reasonable fee. Anyone handling both in the same returns process needs a distinguishing attribute on the case - otherwise the ERP invoices a warranty repair or extends a deadline that is not affected at all. How returns generally move through shop and ERP is described in the article on the RMA process between shop and ERP; this article covers what the repair duty adds on top.
The eleven product groups in Annex II
The BGB does not define the goods covered with a list of its own but with a reference: the rules apply to goods that belong to the product groups listed in Annex II of Directive (EU) 2024/1799 (Section 479a no. 1 BGB). In the version applicable since 31 July 2026, the annex names eleven groups, each with the legal act that sets reparability requirements for it. The version of 13 June 2024 listed ten; the eleventh, domestic local space heaters, was added by the Commission with Delegated Directive (EU) 2026/74. For the data model this link matters more than the group name, because the scope of the duty - which parts, for how long, with which delivery time - only follows from the respective legal act.
- Household washing machines and household washer-dryers: Regulation (EU) 2019/2023
- Household dishwashers: Regulation (EU) 2019/2022
- Refrigerating appliances: Regulation (EU) 2019/2019
- Electronic displays: Regulation (EU) 2019/2021
- Welding equipment: Regulation (EU) 2019/1784
- Vacuum cleaners: Regulation (EU) No 666/2013
- Servers and data storage products: Regulation (EU) 2019/424
- Mobile phones, cordless phones and slate tablets: Regulation (EU) 2023/1670
- Household tumble dryers: Regulation (EU) 2023/2533
- Goods incorporating light means of transport batteries: Regulation (EU) 2023/1542
- Domestic local space heaters: Regulation (EU) 2024/1103, since 31 July 2026 (Delegated Directive (EU) 2026/74)
Two entries deserve a second look in industry and electronics. Welding equipment as well as servers and data storage products are often bought by businesses - but the repair duty only applies to goods that a consumer bought (Section 479a no. 2 BGB). A manufacturer selling the same device to businesses and to private customers therefore cannot attach the duty to the article, only to the unit sold and its buyer. That argues for keeping the attribute "consumer purchase" on the sales document and on the serial number, not as an article attribute. The article says which duties are possible; only the unit says which ones actually apply.
The product group belongs to the model, the duty to the unit
Spare parts at a reasonable price
The core of the manufacturer duty is the spare part. Manufacturers must offer spare parts and repair-related tools at a reasonable price that does not discourage repair (Section 479c BGB; likewise Art. 5(4) of the Directive). The law gives no number but a yardstick - and it can only be met if the price of a part comes about in a traceable way. Which parts must be kept available and how quickly they must be delivered is set out in the legal acts listed in Annex II. Two examples show how different these requirements are and why they belong in the ERP as data, not as running text in a manual.
Seven years of parts availability
For mobile phones and slate tablets, manufacturers, importers or authorised representatives make the required spare parts available for at least seven years after the end of placing on the market (Regulation (EU) 2023/1670, Annex II).
Five and ten working days
During the first five years of that period, spare parts must be delivered within five working days of receiving the order, during the remaining two years within ten working days (Regulation (EU) 2023/1670).
Indicative prices before tax
For these parts, manufacturers state indicative prices before tax, at least in euro, on their freely accessible website, including fasteners and tools supplied with the part (Regulation (EU) 2023/1670).
Ten years for washing machines
For household washing machines and washer-dryers, door, door hinge, seals and detergent dispenser, among others, must remain available for at least ten years after the last unit of a model was placed on the market (Regulation (EU) 2019/2023).
15 working days delivery time
During that period, parts for washing machines must be delivered within 15 working days of receiving the order (Regulation (EU) 2019/2023, Annex II).
Who may order
The cited provisions of both regulations name professional repairers and end-users as recipients. Different groups of recipients can apply per part; the spare parts shop therefore needs customer groups and approvals per part.
Section 479e BGB adds to this: manufacturers may not use hardware or software techniques that impede repair, and may not impede the use of original, second-hand, compatible or 3D-printed spare parts by independent repairers, unless legitimate and objective factors justify it. For the spare parts shop this says above all something about its own software: a serial number check is a tool for matching the right parts, not a lock against third-party repairs. Which spare parts are available, how many are in stock and when replenishment arrives is in the inventory system anyway; the ERP inventory integration with the online store supplies stock and delivery time per part instead of maintaining them a second time in the shop.
The service BOM as the mapping from device to spare part
A spare parts catalogue that only lists parts helps nobody. The consumer knows the device, not the part number of the door seal. The question a spare parts shop has to answer is: which parts fit exactly this device? The answer sits in the ERP, but usually in the production bill of materials - and that is unsuitable for the purpose. It describes how a device is built, including semi-finished goods, assemblies that are not sold individually and positions that change with every change of supplier.
What holds up is a dedicated service BOM: a view of the device that contains only exchangeable parts, each with spare part number, validity and successor. The decisive key is not the model but the serial number. Within one model, suppliers and components change; a display module fitted from a certain serial number onwards does not necessarily fit the devices before it. Anyone who already keeps serial numbers clean between ERP and shop, as described in the article on batches and serial numbers between ERP and shop, has done a large part of the work. The service BOM is then another set of master data with its own maintenance responsibility, usually in customer service rather than in engineering.
Validity by serial number range, not by date
device
serial_number unique per unit
model_no reference to the model master
contract_date date of the sales contract, not of delivery
consumer_purchase yes | no | unknown
sales_channel own store | retail | marketplace
model
model_no
product_group number from Annex II or empty
legal_act for example Reg. (EU) 2023/1670
on_market_until end of placing on the market, once known
service_bom
model_no + spare_part_no
sn_from, sn_to validity by serial number range
mandatory_part yes | no (to be kept available per legal act)
recipient end_user | professional | both
successor_no if the part is discontinued
spare_part
spare_part_no
delivery_target working days per legal act
available_until derived from on_market_until and legal act
guide_price_net from costing, in euro
guide_price_gross with the tax rate shownThis model lets the mandatory questions be answered by machine. Which parts must the shop offer for a device? The mandatory parts of the service BOM within the valid serial number range. Until when? From the end of placing on the market and the period in the legal act. With what delivery time is planning done? From the target value on the part, compared with stock and replenishment time. Whether the ERP is an SAP system with a customer service module or a Dynamics environment with service orders changes little about this logic; it only changes which tables the interface reads from.
Guide prices from costing rather than from a table
Section 479d(2) BGB obliges manufacturers to provide consumers, on a freely accessible website, with information on the guide prices calculated for typical repairs. The word "calculated" is telling for the implementation. A guide price is not a figure the service department would like to see; it is the result of a calculation from part price, labour time, hourly rate and, where applicable, shipping. All components sit in the ERP: the part price in pricing, the labour time in the routing of the service order, the hourly rate in cost accounting. The German Price Indication Ordinance explicitly remains unaffected (Section 479d(2) BGB).
The obvious implementation is a table in the content management system: repair, device, price. It is correct on day one and a little more wrong with every price round, every wage increase and every change of part. The more robust implementation generates the page from the same data that customer service later actually invoices with. The guide price then results from a costing rule per typical repair, is versioned with date and validity and delivered through a dedicated interface for shop and service portal. How prices generally move from the ERP into shop and customer groups is described in the article on price synchronization in B2B commerce.
| Attribute | Manually kept table | From ERP costing |
|---|---|---|
| Origin of the price | entered by hand, derivation unclear | costing rule per typical repair |
| Part price changes | table goes stale unnoticed | guide price is recalculated |
| Hourly rate rises | update forgotten or late | flows in through cost accounting |
| Query about the amount | figure without derivation | version with date and components |
| Net and gross | one figure, tax unclear | both values, tax rate shown |
| Deviation from the invoice | noticed only by the customer | order shows guide price and actual price |
Two details decide the quality of the page. First, net and gross: the ecodesign requirements for mobile phones and tablets call for indicative prices before tax, while consumers expect final prices and the Price Indication Ordinance remains unaffected. A record that holds both values together with the tax rate serves both requirements without anyone converting by hand. Second, the line between typical and individual: a guide price page gives examples, not a cost estimate. The actual price only emerges at the device; if the European Repair Information Form is used, the repairer may not change the conditions stated in it for 30 calendar days (Art. 4(5) of the Directive). Generating both - guide price and quote - from the same costing keeps the difference explainable.
Twelve months more: the limitation period per unit sold
The second change does not affect the manufacturer as manufacturer, but every seller to consumers - including the manufacturer with its own online store. Where the remedy is provided by repair, the original limitation period for claims arising from a defect is extended once by twelve months (Section 475e(5) BGB). The Directive states the same for the liability period (Art. 10(2a) of Directive (EU) 2019/771 as amended by Art. 16 of Directive (EU) 2024/1799) and requires the seller to inform the consumer, before providing the remedy, about the right to choose between repair and replacement and about the possible extension (Art. 13(2a) of Directive (EU) 2019/771). Art. 16 of the Directive does not apply to sales contracts concluded before 31 July 2026 (Art. 21).
Alongside the new rule, two suspension rules have to be reflected in the record as well. If a defect has become apparent within the limitation period, limitation does not occur before four months have passed since it first became apparent (Section 475e(3) BGB). If the consumer handed the goods over for the remedy, limitation does not occur before two months have passed since the repaired or replaced goods were handed back (Section 475e(4) BGB). Three rules, three triggers, three date fields - and all of them attach to the individual unit sold, not to the article and not to the customer account.
Once means a flag, not a counter
In the ERP this means: the warranty record per serial number gets a calculated end date that results from the date of the sales contract, the base period, the extension flag and the two suspension dates. The service order sets the flag when a repair is completed, the shop shows the customer the current end date in the account, and the complaint check reads the same field before rejecting a case as time-barred. Anyone who already keeps the withdrawal as a record of its own, as described in the article on the online withdrawal function as an ERP process, knows the pattern: a consumer right becomes a state on the case that every system reads the same way.
From the portal to the repair order in the ERP
As long as manufacturers are obliged to repair, they provide information about these repair services in an easily accessible, clear and comprehensible manner and free of charge (Section 479d(1) BGB). In practice this is a service portal or an area in the shop where a consumer identifies the device, describes the fault and asks for a repair. From an integration point of view, what counts is that every such enquiry lands as an order in the ERP and that the status flows back, instead of ending up in a mailbox.
- Identify the device: enter the serial number; the ERP returns model, date of the sales contract, consumer purchase and current end of the limitation period.
- Determine the legal basis: if the device is under warranty, a remedy case is created; otherwise the rule checks whether the repair duty under Section 479b BGB applies.
- Show the guide price: for the selected typical repair, the portal shows the calculated guide price with its date; under warranty it shows the note on the remedy instead.
- Create the order: the portal hands the order to the ERP through the middleware; the required spare parts are reserved before the device arrives.
- Earlier repair is no reason to refuse: the manufacturer may not refuse the repair solely because an earlier repair was carried out by others (Section 479b(2) BGB). In the record it is an attribute, not an exclusion.
- Report completion: type of remedy, handover date and, where applicable, the extension flag go to the warranty record and the customer account.
Technically, this flow is a classic task for a middleware layer: portal, shop, ERP and, where applicable, a service partner talk to each other through defined messages. If a handover fails, for example because a serial number is unknown in the ERP, the case belongs in a dead letter queue with clear ownership - not in a log that nobody reads. A lost repair order is not a cosmetic technical flaw but a claim that remains unprocessed.
Manufacturers outside the EU: who bears the duties
Not every device from the eleven groups comes from a manufacturer established in the Union. For this case, Section 479f BGB shifts the duties: if the manufacturer is established outside the European Union, they fall on its authorised representative in the Union; if there is no authorised representative, on the importer; if there is no importer, on the distributor. For importers and private labels with their own online store, this is the real news of this subtitle of the code. They can be obliged to repair without ever having designed a device - and then need spare parts, bills of materials and costing data that sit with the manufacturer.
The data question then is: who is responsible for this model in which role, and where does the service data come from? The role model that the article on economic operator data under the GPSR in shop listings describes can be reused here. The model states who the manufacturer is, whether it is established in the Union and who steps in as authorised representative, importer or distributor. Where the service BOM and part prices sit with the supplier, their delivery by data exchange belongs in the supply contract - with format and frequency, not as a favour.
European repair platform by July 2027
How an integration project runs
The order follows from the dependencies, not from the urgency of individual pages. A guide price page without reliable part prices is an estimate, and a service portal without device data is a contact form.
- Take stock: which models fall under one of the eleven groups, which legal act applies, where do serial numbers, purchase data and consumer status sit today?
- Build the service BOM: exchangeable parts per model, validity by serial number range, mandatory parts per legal act, successors. Often the largest item in the project.
- Define costing rules: define typical repairs, assign parts, labour time and hourly rate, keep net and gross, version with a date.
- Build the interfaces: spare parts and stock into the shop, guide prices onto the freely accessible page, orders from the portal into the ERP, status and deadlines back.
- Test the deadline logic: test cases for purchase date, first notice of a defect, repair, replacement and purchase before the cut-off date - each case with an expected end date.
- Hand over to operations: assign responsibility for BOM maintenance, costing changes and the dead letter queue before the first enquiry arrives.
Anyone already working on the digital product passport under the ESPR will find fields on reparability there that need the same data basis. And anyone currently bringing energy label and EPREL data from the ERP into the shop for the same device groups is maintaining the model master anyway, to which the product group is attached. Three duties, one master record: it pays to plan them together.
A guide price that nobody can derive is a claim with a euro sign. Only the costing behind it turns it into information that consumers and customer service understand in the same way.
Sources and legal basis
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