Under the conditions set in the new Eco Design Requirements, repair and maintenance information should be made available to professional repairers, so long as conditions are met (Annex II).
One of the conditions is:
the manufacturer’s, importer’s or authorised representative’s website shall indicate the process for professional repairers to register for access to information; to accept such a request, manufacturers, importers or authorised representative may require the professional repairer to demonstrate that: (i) the professional repairer has the technical competence to repair…
As there is no legal obligation to possess a formal qualification to be a repairer, and competency can be gained through experience, how are other retailers dealing with the point about technical competency?
How are they assessing technical competency of repairers to provide access to this information?
1. There is a little more substance in the individual Regulations i.e. Regulation (EU) 2019/2023 Washing Machines
Annex II B Resource Efficiency Requirements
The question that has to be answered is, does the information that is held on file demonstrate that the individual is technically competent and has professional liability insurance?
We had a lot of discussion about this, so the question becomes: What evidence you have to demonstrate that they are technically competent?
All revert back to some form of third party assessment. Formal qualification is clearly one route. NVQ; C&G; etc;
Registration on NIC EIC; Trust a trader, etc means they have been reviewed but we would require the certificate and insurance.
2. We’re leaning towards a set of questions to gauge competency and asking for a copy of the 3rd parties liability insurance. As you can expect we are getting pushback internally and the ‘may require’ wording is what people are trying to hang their hat on. As we’ve pointed out, we can ask our Primary Authority for advice, but when they tell us what we suggested doesn’t go far enough don’t come back to say we didn’t warn them!
3. In the absence of any set requirements, it would form part of each manufacturer's/retailer's due diligence and approach to risk management to satisfy themselves as to the competency, processes and consistency of any repairer. As it stands, repair-er for each brand would be a small pool of authorised repairers.
We are of the understanding that authorities will in due course share qualification/certification requirements, as the intention is for the pool of "repairers" to be wide, maximising chances of repairability and supporting circularity.
At the above stage, the brands/retailers will not be able to have significant (if any) control over "competency" and at that stage it is probably most important to ensure that the repair and repairer is dated, recorded and logged, the repairer therefore taking accountability of any adverse impact to safety-compliance-quality of the product and indemnifying the manufacturer. This would also require liability insurance provision.
The Government will shortly publish its response to the recent consultation on updated ecodesign requirements for certain white goods, industrial goods and electronic displays (see consultation document).
- The requirements relating to repair and maintenance information in the proposed regulations were designed to encourage and facilitate the repair of electrical goods, in order to help them stay in use for longer and move the UK towards a more circular economy.
- If the regulations are adopted in GB, the requirement to make this information available would fall on the manufacturer, their authorised representative or the importer, and not on the retailer (unless a retailer had been specifically appointed by a manufacturer as their authorised representative).
- The manufacturer, authorised representative or importer would have the option to assess the repairer’s technical competence before releasing the information, but this would not be a requirement (i.e. it would be the manufacturer, authorised representative, or importer’s choice).
- The level of technical competence required would vary from product to product and would depend on the type of repair to be carried out; it would be up to the manufacturer, authorised representative, or importer to determine the appropriate level of technical competency and whether to confirm this before issuing information.