Does the EU Directive 2024/1799 (‘Right to Repair’) also apply to laptops?

The new EU Directive 2024/1799 introduces extensive requirements for manufacturers of certain product categories to offer extended repair services during and after the warranty period. The title ‘Right to Repair’ is merely an unofficial designation.

In the following, we will explain whether laptops fall within the scope of this directive. We will then provide a general explanation of our approach to out-of-warranty repairs.

Does this regulation apply to laptops?

Various product groups are explicitly named in the directive's appendix (ANNEX II). Laptops, on the other hand, are explicitly not listed there – but the following product groups, among others, are:

• Electronic displays
• Servers and data storage products
• Mobile phones, cordless phones and slate tablets

The definitions of these product groups are linked in the corresponding footnotes.

As we understand it, laptops are not covered by the scope of the directive. It could be argued that a laptop has an ‘electronic display’ and is actually also a ‘data storage’ product and therefore falls under the categories listed there. However, the underlying EU documents each refer to very narrow definitions from which laptops are explicitly excluded.

We will demonstrate this here with the original quotations. German translations of the documents are available via the corresponding links.

1. Electronic displays

The footnote refers to Commission Regulation (EU) 2019/2021, published in the Official Journal of the European Union, L 315 (OJ L 315). The definition contained therein states that a ‘display’ within the meaning of this directive must not be a component of another complete product.

As laptops (or notebooks) are already covered by other provisions of Directive 2009/125/EC, they are excluded from the term ‘electronic display’ in this context, since a laptop display is an integrated component of such a complete product.

The definition of displays in the sense of Directive 2024/1799 (Right to Repair) therefore refers to separate products such as desktop monitors, televisions, digital picture frames and public displays (‘digital signage’).

2. Servers and Data Storage Products

The footnote refers to Commission Regulation (EU) 2019/424, which, according to Article 2, defines ‘servers’ and ‘data storage products’ as follows:

These definitions do not apply to laptops. A typical laptop (even in the business sector) is not a classic server device.

3. Mobile phones, cordless phones and slate tablets

Here, Commission Regulation (EU) 2023/1670 defines as follows:

Despite its portability, a laptop is not a smartphone or tablet in the sense of this regulation. While laptops and tablets may serve similar use cases, a laptop with an integrated keyboard, display hinge and desktop operating system is not a tablet in the sense of the EU definition.

Why are laptops excluded?

Laptops are considerably more complex than, for example, a smartphone or a single display panel. A typical laptop contains:

• a wide range of components (CPU, GPU, mainboard with various interfaces, audio subsystem, keyboard, display, battery, etc.),
• movable housing constructions (display hinge, keyboard mechanism),
• a wide range of power and cooling systems with varying designs.

There are likely several reasons why Directive 2024/1799 does not currently include laptops within its scope. Among other things, laptops are subject to relatively short innovation cycles; manufacturers often launch completely new models on the market after just 6–12 months. As a result, individual spare parts (e.g. mainboards or cooling systems) are often no longer economically available after a few years. While it is true that smartphones also have short product cycles, a smartphone is usually much less complex than a laptop (for example, it has fewer different components and interfaces).

Implementation into national law

EU Directive 2024/1799 requires transposition into national law by July 2026 at the latest. It is possible that individual EU Member States will extend their national legislation beyond the directive or that further product groups will be included in a future amendment.

Our position on out-of-warranty repairs

Although laptops do not fall under the scope of the new directive as it is currently interpreted, we remain committed to offering repairs for as long as feasible, even beyond the regular warranty period.

However, we cannot promise a fixed period such as ‘5 or 10 years’, as this is not always realistically feasible for many of our laptops’ components. Nevertheless, we endeavour to keep spare parts available for as long as possible. You are welcome to contact us with a repair request at any time.

See also:

• What kind of warranty do I get on XMG laptops?
• How can I contact XMG directly?
• RMA return for a voluntary device check-up