You import vacuum cleaners, smartphones or washing machines manufactured outside the Union and you resell them to consumers in Belgium. A European directive is going to concern you, even if you manufactured nothing.
Directive (EU) 2024/1799 of 13 June 2024 obliges the manufacturer to repair certain appliances at the consumer's request, including after the legal guarantee. When the manufacturer is established outside the Union, this obligation moves up the chain to the importer, then to the distributor.
Who is concerned by the obligation to repair?
The obligation targets the manufacturer first. It can reach you in three situations.
You are the importer: the business established in the Union that places on the Union market a product from a third country. This is the typical case of the Belgian SME that buys in China and resells here.
You sell under your own name or your own brand a product manufactured by someone else. For the law, you are then the manufacturer: a manufacturer is anyone who manufactures a product, or has it designed or manufactured, and markets it under their name or brand. White labelling does not protect you.
You are the distributor of a product that no importer has brought into the Union.
These definitions are those of Regulation (EU) 2024/1781 on ecodesign, to which the Belgian bill refers (art. I.18/1, draft).
Which products are covered?
The list is set by Annex II of the directive. It has ten product groups for which European law already imposes repairability requirements: household washing machines and washer-dryers, household dishwashers, refrigerating appliances, electronic displays, welding equipment, vacuum cleaners, servers and data storage products, mobile phones, cordless phones and tablets, household tumble dryers, and goods incorporating batteries for light means of transport.
This list will evolve. The European Commission updates it by delegated acts as new repairability requirements are adopted (art. 5(9) of the directive).
What will you actually have to do?
At the consumer's request, repair these products, within the limits of the European requirements specific to them. The obligation covers defects that do not fall under the seller's legal guarantee: a breakdown after two years, wear and tear, a fall.
The repair is free of charge or invoiced at a reasonable price, within a reasonable time. The price may cover labour, parts, the running of the workshop and a usual margin, provided it does not deter the consumer. A replacement good may be lent during the repair. If the repair is impossible, a refurbished good may be offered.
Indicative prices for common repairs must be accessible on a freely accessible website, with clear information on the repair services.
The manufacturer may not use contractual clauses or hardware or software techniques that impede repair, except for legitimate and objective factors, including the protection of intellectual property rights. Nor may it refuse a repair on the sole ground that another repairer has already intervened. The consumer remains free to turn to the repairer of their choice.
These rules appear in article 5 of the directive and in article XIV.3, draft, of the Code of Economic Law (CDE).
Who must repair when the manufacturer is in China?
The directive organises a cascade. If the manufacturer is established outside the Union, its authorised representative in the Union fulfils the obligation. Failing an authorised representative, the importer. Failing an importer, the distributor (art. 5(3) of the directive; art. XIV.3, § 3, draft).
Each of them may entrust the repair to a subcontractor, for example a repairer close to the customer. What does not change is who is liable for the obligation.
The authorised representative is defined by a written mandate from the manufacturer. A mere commercial contact in Europe is not enough.
When do these rules apply?
Two texts must be distinguished.
The obligation to repair goes through a bill that reinstates a Book XIV "Rules promoting the repair of goods" in the Code of Economic Law. It was tabled in the Chamber on 23 September 2026 (Doc. parl., Chambre, no. 56 1750/001). It has not yet been passed and may still change. The directive was to apply from 31 July 2026 (art. 22), but the Council of State (Conseil d'État) recalled that the Belgian law cannot be retroactive and will have to give businesses time to adapt.
The guarantee, for its part, has already changed in the law. The law of 22 July 2026, published in the Belgian Official Gazette (Moniteur belge) on 23 September 2026, provides that if the buyer opts for the repair of a consumer good, the guarantee period is extended once by one year: three years instead of two. The rule is inserted into the former Civil Code by article 14 of that law, which enters into force on the tenth day following its publication (art. 50, para. 2).
The same rule is taken over in the new Book 7 of the Civil Code (art. 7.2.50), in force on 1 September 2027.
What sanctions does the bill provide?
The bill punishes any infringement of Book XIV with a level 2 criminal sanction (art. XV.124, draft). In the Code of Economic Law, that is a fine of 26 to 10,000 euros, before surcharges (décimes additionnels), or 4% of total annual turnover for the last closed financial year if that amount is higher (art. XV.70).
The bill also opens up collective action by consumers (art. XVII.37, draft). Once the law is in force, the president of the Commercial Court (tribunal de l'entreprise) will be able to order the cessation of an infringement (art. XVII.1/4 of the Code of Economic Law).
How do you prepare now?
The purchase contracts you sign today will cover the sales of the coming years. So now is the time to re-read them. Five clauses deserve your attention:
- the designation by your supplier of an authorised representative established in the Union, in writing, with a copy of the mandate;
- the supply of parts, repair documentation and software tools for the whole period required by the product's regulation, at an agreed price;
- the reimbursement of repairs due to a manufacturing defect, covered by a retention on payment or a bank guarantee;
- the absence of any clause excluding or capping the supplier's warranty;
- a governing law and a dispute resolution method that you will actually be able to enforce.
On your side, identify a repairer in Belgium, prepare the indicative price page and keep a breakdown register: date, defect, part replaced, repairer's report. This register is your evidence against the supplier.
What if the defect comes from your supplier?
With a Belgian seller subject to Belgian law, the new Book 7 of the Civil Code makes the seller liable for any lack of conformity that existed, even in germ, at delivery and that appears within ten years (art. 7.2.30 and 7.2.32). The defect must be notified to the seller within a reasonable time, on pain of forfeiture (art. 7.2.33), and the action is time-barred two years from that notification (art. 7.2.34). This regime applies to contracts concluded from 1 September 2027 (art. 49 and 50 of the law of 22 July 2026). Between businesses, it is not mandatory: a clause in the seller's general terms and conditions may limit it. Hence the value of negotiating it.
With a supplier established in China, it is in principle the Vienna Convention on the international sale of goods that applies, Belgium and China both being parties. The parties may, however, exclude it (art. 6). In both cases, obtaining redress from a distant supplier takes time: the purchase contract remains the best protection.
An order of magnitude
Here is an example built on my own assumptions, not on market data.
An SME imports 10,000 vacuum cleaners for 1 million euros. It assumes a failure rate of 3% a year for five years, that is 1,500 repair requests.
If it charges a reasonable price close to the actual cost, each repair costs it little. The real cost is the organisation: stock of parts, contract with a repairer, management and price page. I estimate it at 45,000 euros over five years, that is 4.50 euros per appliance.
If a serial defect affects 1,000 appliances and it has to repair them free of charge, for example during the legal guarantee, the bill can reach 75,000 euros. Without a clause in the purchase contract, recovering it from a Chinese supplier is uncertain.
Sources
Directive (EU) 2024/1799 of the European Parliament and of the Council of 13 June 2024 on common rules promoting the repair of goods, art. 5, 16, 21, 22 and Annex II (EUR-Lex, CELEX 32024L1799). Bill reinstating Book XIV "Rules promoting the repair of goods" in the Code of Economic Law, Doc. parl., Chambre, 2025-2026, no. 56 1750/001, tabled on 23 September 2026. Law of 22 July 2026 inserting Book 7 "Specific contracts" into the Civil Code, art. 2, 14, 49 and 50, M.B., 23 September 2026 (NUMAC 2026005775). Code of Economic Law, art. XV.70 and XVII.1/4. United Nations Convention on Contracts for the International Sale of Goods, Vienna, 11 April 1980, art. 6.
This article is general information, current as of 30 September 2026. It is not an opinion on your situation. To find out whether your products are covered, write to [email protected].
Translated from the French original published on 30 September 2026. The analysis concerns Belgian and European Union law. Read the French original.