COMMISSION STAFF WORKING DOCUMENT Accompanying the document COMMISSION DELEGATED REGULATION (EU).../... amending Commission Delegated Regulation (EU) 2023/2534 on household tumble dryers regarding information on repairability and clarifying some aspects of the measurement and calculation methods, the product information sheet, the technical documentation and the verification procedure
Date: 2025-07-01
Institutions: Directorate-General for Energy, European Commission
Subjects: EU energy label, consumer information, documentation, energy consumption, household electrical appliance, labelling, maintenance, product life, technical specification

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 1.7.2025  SWD(2025) 167 final  COMMISSION STAFF WORKING DOCUMENT Accompanying the document COMMISSION DELEGATED REGULATION (EU).../... amending Commission Delegated Regulation (EU) 2023/2534 on household tumble dryers regarding information on repairability and clarifying some aspects of the measurement and calculation methods, the product information sheet, the technical documentation and the verification procedure {C(2025) 3986 final}  
 
 
1.  EXECUTIVE SUMMARY 

Tumble dryers are a popular appliance in EU households. The market penetration of tumble 
dryers is increasing and expected to grow from 26% of EU households in 2020 to 35% in 2040. 
However, the average lifetime of tumble dryers over the last decade has decreased from 
14 to 12 years, prompting an acceleration of production to compensate the shorter lifetime. 
This results in an increase of energy and materials used for production and distribution, 
as  well  as  higher  costs  related  to  replacements,  disposal  and  recycling.  Quantitatively  this 
gives, by 2040, 9,720 TJ (terajoules) additional energy consumption, 1.5 mtCO2e additional 
greenhouse gas emissions and 114 kilotons extra waste. 

Regulation (EU) 2023/25331 already includes certain circular economy measures, namely the 
mandatory  availability  of  spare  parts  and  related  information.  Already  at  the  time  of  its 
adoption  it  was  however  considered  unlikely  that  those  measures  alone  would  succeed  in 
reverting  the  negative  trend  of  tumble  dryers  durability  without  additional  action.  The 
Regulation  therefore  requires  the  Commission  to  present  a  repairability  score  for 
household tumble dryers no later than 1 January 20252. A repairability score, displayed in 
the energy label of the tumble dryer by means of an A-to-E scale, will encourage consumers to 
buy repairable products  and producers to  develop appliances that can be repaired in  a cost-
effective manner. It would also help protect the single market from fragmentation due to 
national  measures  that  might  otherwise  be  adopted  to  provide  consumers  with  such 
information, increasing costs for producers and consumers alike. 

This  document  proposes  a  repairability  score  for  household  tumble  dryers,  based  on  recent 
relevant studies on the matter, and following a similar approach as the one used for the rules 
adopted on energy labelling for smartphones and tablets3, consistent with the terminology 
used in standard EN 45554: General methods for the assessment of the ability to repair, reuse 
and upgrade energy-related products4. The repairability score is determined by scoring, against 
certain repairability criteria, a number of priority parts, chosen on the basis of their relevance. 
The final score for the whole product  is the weighted average of the  partial scores for each 
repairability criterion. The score for each criterion is, in turn, the weighted average of the partial 
scores of each priority part against that criterion. 

The repairability score will be displayed in the label as a class on an A-to-E repairability scale, 
immediately  allowing  the  consumer  to  assess  how  good  or  bad  a  product  is  in  terms  of 
repairability, compared with other models.  

1  
Commission Regulation (EU) 2023/2533 of 17 November 2023 implementing Directive 2009/125/EC 
of  the  Euroepean  Parliament and  of  the  Council  with  regard  to  ecodesign  requirements  for  household  tumble 
dryers,  amending  Commission  Regulation  (EU)  2023/826,  and  repealing  Commission  Regulation  (EU)  No 
932/2012 (OJ L, 2023/2533, 22.11.2023, ELI: http://data.europa.eu/eli/reg/2023/2533/oj). 
2  
Ibid, Art. 7(2). 
3 
https://commission.europa.eu/energy-climate-change-environment/standards-tools-and-labels/products-
labelling-rules-and-requirements/energy-label-and-ecodesign/energy-efficient-products/mobile-phones-cordless-
phones-and-tablets_en. 
4  
reuse-and-upgrade-energy-related-products/. 

https://www.en-standard.eu/csn-en-45554-general-methods-for-the-assessment-of-the-ability-to-repair-

1 

 
 
 
The repairability score has been discussed with stakeholders at the Consultation Forum of 11 
March 2024. It will be adopted as an amendment to Delegated Regulation (EU) 2023/25345.  

2. 

INTRODUCTION: POLITICAL, LEGAL AND SOCIAL CONTEXT 

2.1. 

Political context 

In  December  2019,  the  Commission  presented  the  European  Green  Deal6,  the  centre  of  its 
environmental  strategy  to  implement  the  United  Nation’s  2030  Agenda  and  the  sustainable 
development  goals7.  The  Green  Deal  aims  at  turning  Europe  into  the  first  climate-neutral 
continent by 2050, and at protecting health and well-being of citizens from environment-related 
risks and impacts.  

One of the policies included in the Green Deal is the mobilisation of industry for a clean and 
circular economy. The Circular Economy Action Plan (CEAP)8 adopted by the Commission in 
March 2020, contains a set of measures to accelerate the transformational change required by 
the Green Deal as regards circular economy. One of the actions included in the CEAP is to 
promote  the  design  of  sustainable  products,  e.g.  by  improving  product  durability  and 
repairability  and  countering  premature  obsolescence.  The  CEAP  acknowledges  that  many 
products break too quickly and cannot be easily reused, repaired or recycled, pointing out that 
EU initiatives and legislation on circular economy are scattered and that a harmonised approach 
is needed to ensure that products placed in the EU market meet common criteria on circular 
economy. To systematically address sustainability criteria in products, the CEAP identifies two 
lines of action. The first one, general, is to extend the scope of the ecodesign legal framework 
beyond energy-related products. This has resulted in the adoption and entry into force in 2024 
of  the  Ecodesign  for  Sustainable  Products  Regulation  (ESPR)  to  replace  the  Ecodesign 
Framework  Directive9.  The  second  line  of  action  is  to  modify  existing  product-specific 
legislation, on a case-by-case basis, to address product durability and repairability.  

Further,  the  Commission  published  on  30  March  2022  its  Communication  on  making 
sustainable products the norm10. The Communication refers to the ESPR as the cornerstone of 
the  Commission’s  approach  to  more  environmentally  sustainable  and  circular  products, 
indicating  that  the  ESPR  should  not  only  be  a  framework  for  setting  requirements  on  how 
products should be made, but also on what information should be provided to the consumer on 

The European Green Deal, COM(2019) 640 final. 
Transforming our world: the 2030 Agenda for Sustainable Development. 
Circular Economy Action Plan for a more competitive Europe, COM(2020) 98. 

5  
Commission  Delegated  Regulation  (EU)  2023/2534  of 13 July  2023  supplementing  Regulation  (EU) 
2017/1369 of the European Parliament and of the Council with regard to energy labelling of household tumble 
dryers and repealing Commission Delegated Regulation (EU) No 392/20012 (OJ L, 2023/2534, 22.11.2023, ELI: 
http://data.europa.eu/eli/reg_del/2023/2534/oj). 
6  
7  
8  
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52015DC0614&from=EN. 
9  
Directive 2009/125/EC of the European Parliament and of the Council of 21 October 2009 establishing 
a framework for the setting of ecodesign requirements for energy-related products (OJ L 285, 31.10.2009, p.10) 
10  
Communication from the Commission to the European Parliament, the Council, the European Economic 
and  Social  Committee  and  the  Committee  of  the  Regions  on  making  sustainable  products  the  norm 
(COM/2022/140 final).  

2 

 
 
 
the  environmental  sustainability  of  the  products.  A  repairability  score  is  identified  in  the 
Communication as one of the possible means to provide that information.  

In March 2023, the Commission adopted a proposal for a Directive on the repair of goods (the 
Right-to-repair  Directive)11,  setting  a  set  of  common  obligations  to  producers  within  and 
beyond the legal guarantee of the product.  

There  is  consensus  among  stakeholders  on  the  need  to  urgently  develop  an  EU-wide 
repairability score for tumble dryers to prevent fragmentation of the single market by national 
initiatives  with  a  similar  aim.  APPLiA,  the  association  that  represents  the  home  appliance 
industry in in Europe, has expressed support to the implementation of a repairability score in 
EU legislation in order to address concerns about similar initiatives at national level that, by 
setting diverging rules, will risk increasing compliance costs for manufacturers and suppliers, 
and subsequently prices for consumers. Member States and NGOs have likewise insisted the 
Commission present a repairability score to inform the consumer at the sales point, within the 
shortest  possible  delay.  Delegated  Regulation  (EU)  2023/2534  reflects  such  urgency,  by 
requiring  the  Commission  to  present  a  proposal  to  the  Consultation  Forum  no  later  than  1 
January 2025, this is 5 years earlier than the deadline set out in the Regulation for the overall 
legislative review.  

2.2.  Legal basis and legal context 

Article 16(1) of Regulation (EU) 2017/136912 empowers the Commission to adopt delegated 
acts by establishing detailed requirements relating to labels for specific product groups. Article 
16(3) sets out that Delegated acts shall specify, where appropriate, the display on the label of 
supplementary  information  concerning  the  product,  in  a  way  that  this  supplementary 
information does not have a negative impact on the clear intelligibility and effectiveness of the 
label as a whole towards consumers and emphasising the energy efficiency of the product. It 
also  requires  the  Commission  to  present  proposals  to  rescale  existing  energy  labels  in 
accordance with the new A-G scale in accordance with the framework regulation. 

A general review was also foreseen in Article 7 of Delegated Regulation (EU) No 392/201213 
which required the Commission to review the Regulation by June 2017. Accordingly, a new 
Regulation (EU) 2023/2534 was adopted on energy labelling for tumble dryers and repealing 
Delegated Regulation (EU) No 392/2012.  

As indicated in point 2.1, Article 7(2) of Regulation (EU) 2023/2534 sets out the obligation for 
the Commission to present the Consultation Forum a repairability score for household tumble 
dryers and, if appropriate, a draft legal proposal no later than 1 January 2025. The repairability 
score for tumble dryers should therefore be adopted as an amendment to Regulation 2023/2534.  

https://commission.europa.eu/law/law-topic/consumer-protection-law/consumer-contract-law/rules-

Regulation  (EU)  2017/1369  of  the  European  Parliament  and  of  the  Council  of  4  July  2017  setting  a 

11 
promoting-repair-goods_en  
12  
framework for energy labelling and repealing Directive 2010/30/EU (OJ L 198, 28.7.2017, p. 1). 
13  
Commission  Delegated  Regulation  (EU)  No  392/2012  of  1  March  2012  supplementing  Directive 
2010/30/EU of the European Parliament and of the Council with regard to energy labelling of household tumble 
driers (OJ L 123, 9.5.2012, p. 1). 

3 

 
 
 
2.3. 

Societal context 

Designing a product according to circular economy criteria is a matter of growing interest in 
society. A Eurobarometer published in October 2022 showed that most Europeans are in favour 
of policies encouraging industry to adopt more circular and sustainable practices. Several EU 
environmental and consumer organisations have put  circular economy  in the centre of their 
priorities, and industry supports such efforts particularly when pursued at EU level.  

The public consultation published by the European Commission on the proposal for the Right-
to-repair  Directive,  shows  that  consumers  are  in  general  aware  of  the  shorter  lifetime  of 
products. The difficulties to self-repair and the high repair costs were among the main causes 
explaining that shorter lifetime. Most of the respondents also considered that repair should be 
prioritised in public policies whenever it is cheaper or at the same cost as replacement.  

The review study on household tumble dryers14 from May 2019 investigated the likeliness for 
self-repair, finding that approximately 35% of the consumers would for sure repair their tumble 
dryers, and that an additional 40% would probably repair. 

In response to the growing interest in repairing products, several studies on repairability have 
been  conducted  or  are  undergoing.  In  2019,  the  Joint  Research  Centre  published  the  report 
Analysis and development of a scoring system for repair and upgrade of products15 (henceforth 
“the JRC repairability study”), based on three elements: the selection of critical components, 
called priority parts, a set of key parameters against which the performance of each priority 
part would be assessed, and a scoring framework setting out the scores corresponding to each 
parameter. In 2022, the German Environmental Agency published a study16 (henceforth “the 
German repairability study”) on a repairability score adapted to two products groups: printers 
and tumble dryers. In this study, relevant spare parts were selected for each product group, and 
the repairability score was calculated for a significant number of different models of printers 
and tumble dryers placed on the market.  

3.  SUBSIDIARITY. NECESSITY OF ACTING ON REPAIRABILITY AT EU LEVEL 

As  indicated  in  point  2.1,  in  parallel  to  the  growing  interest  in  repairability,  some  Member 
States  are  developing  their  own  repairability  scores  for  specific  products.  In  January  2021, 
France introduced a repairability index for five product groups. A framework for similar action 
is underway in Belgium. Germany and Spain have urged the EU to act on this matter as an 
alternative to national action that might otherwise be pursued. 

At  the  Ecodesign  and  Energy  Labelling  Consultation  Forum  on  6  October  2023,  APPLiA 
expressed  strong  concern  about  the  risk  for  internal  market  fragmentation  from  emerging 

14  
Review study on household tumble dryers – Final report (Viegand Maagoe A/S). 
15  
European  Commission,  Joint  Research  Centre,  Sanfelix,  J.,  Cordella,  M.,  Alfieri,  F.  Analysis  and 
development of a scoring system for repair and upgrade of products  – Final report, Publications Office, 2019, 
https://data.europa.eu/doi/10.2760/725068. 
16  
material efficiency under the Ecodesign Directive (Michael Ritthoff et al.). 

Methods and standards for assessing the repairability of electrical and electronic devices – Strengthening 

4 

 
 
 
national  rules  and  asked  Member  States  to  use  EU  ecodesign  and  energy  labelling  and  the 
Consultation Forum to develop common solutions. 

The  proliferation  of  national  repairability  scores  across  EU  Member  States  would  lead  to 
market fragmentation. Diverse national approaches to repairability will be an obstacle for the 
internal market because products would have to be adapted to diverging national rules, thus 
raising compliance costs for the industry and, inevitably, prices for consumers. Conversely, an 
EU approach would  extend the benefits  to  all EU consumers whilst  also  lowering costs for 
manufacturers and for consumers. 

4.  THE PRECEDENT: A REPAIRABILITY SCORE FOR SMARTPHONES AND TABLETS 

A repairability score is a straight-forward and easy-to-understand mean to inform consumers 
about how easily a product can be repaired, helping them reduce the total cost of ownership, 
since a longer lifetime will delay replacement. It also incentivises manufacturers to design their 
products according to sustainability criteria in trying to reach the highest scores for the models 
they place on the market. 

Commission  Delegated  Regulation  (EU)  2023/1669  with  regard  to  the  energy  labelling  of 
smartphones and slate tablets17, is the first product-specific Regulation on energy labelling that 
implements  comprehensive  circular  economy  rules.  It  is  also  the  first  Regulation  that  will 
require  a  label  to  display  a  repairability  score.  The  repairability  score  has  been  adopted 
together  with  other  circular  economy  measures  adopted  in  the  review  of  the  legislation  on 
smartphones and tablets and was fully supported by Member States and stakeholders. It was 
based  on  the  terminology  developed  in  the  standard  EN  45554:  General  methods  for  the 
assessment of the ability to repair, reuse and upgrade energy-related products (se also section 
5.2). More repairability scores are under study. 

5.  A REPAIRABILITY SCORE FOR TUMBLE DRYERS.  

5.1.  What is the problem? 

According to the 2019 review study on household tumble dryers, the average lifetime of tumble 
dryers over the last decade has decreased from 14 to 12 years18, prompting an acceleration of 
production  to  compensate  the  shorter  lifetime.  This  results  in  an  increase  of  energy  and 
materials used for production and distribution, as well as higher costs related to disposal and 
recycling.  

Tumble dryers are big, heavy and complex products the production of which leads to significant 
consumption of energy and materials. The analysis conducted with the EcoReport Tool of the 
Methodology for Ecodesign for Energy-related Products (MEErP)19 for the impact assessment 

17  
Commission Delegated Regulation (EU) 2023/1669 of 16 June 2023 supplementing Regulation (EU) 
2017/1369 of the European Parliament and of the Council with regard to the energy labelling of smartphones and 
slate tablets (OJ L 214, 31.8.2023, p. 9). 
18  
19  

Section 2.2.1 of the study. 
JRC Publications Repository - Ecoreport tool - Manual (europa.eu).  

5 

 
 
 
on the review of the ecodesign and energy labelling legislation on tumble dryers20 (henceforth 
“the 2022 IA”), indicates that for each unit produced, 4.6 GJ energy are consumed on average, 
generating 14 kg landfill waste at the end of its lifetime. In addition, the production of a single 
tumble dryer generates 241 kg CO2eq., 1.5 kg SO2eq, 916 g particulate matter (PM) and 6 g 
volatile organic compounds (VOC). The unitary figures extended to the whole EU market will 
result, in 2040, in 9,720 TJ (terajoules) additional energy consumption, 1.5 mtCO2e additional 
greenhouse gas emissions and 114 kilotons extra waste.  

To help increasing the lifetime of tumble dryers back to 14 years on average, Regulation (EU) 
2023/2533 includes a list of spare parts which must be available by manufacturers to consumers 
and professional repairers, including the provision of repair and maintenance information. The 
environmental and economic impacts of this measure are addressed in the 2022 IA under policy 
option 4 (PO4). The 2022 IA assumes that by applying PO4, the average lifetime of tumble 
dryers  will  be  lengthened  by  two  years.  However,  the  2022  IA  also  explains  that  this 
assumption  is  based  on  opinions  from  repair  and  service  businesses,  but  there  is  no 
further/actual  evidence  behind  it.  The  2019  review  study  on  household  tumble  dryers  also 
acknowledges that it is not possible to know with certainty for how long the lifetime of a tumble 
dryer will be extended by applying circular economy measures. 

A repairability score (which would be displayed in the energy label by means of an A-to-D 
score, as it is for smartphones and tablets) would be a complementary driver to the availability 
of spare parts for extending the lifetime of tumble dryers. This is because the repairability score 
becomes immediately visible to the consumers, who will be made aware of how repairable the 
product is at the time of choosing/purchasing a  product. The repairability score is therefore 
likely to have a larger impact than the availability of spare parts on the purchase decision of 
the  consumer  and  the  placing  on  the  market  of  more  repairable  products  by  suppliers. 
Availability of spare parts is an important but less visible factor which may not be considered 
by  the  consumer  when  buying  the  product.  In  this  respect,  availability  of  spare  parts  is  a 
complementary  measure  to  the  repairability  score  since  an  increased  interest  for  repairing 
fostered by the energy label will ultimately increase demand for available spare parts. 

5.2.  Repairability score - general method and formula 

The European standard EN 45554:2020 on general methods for the assessment of the ability to 
repair,  reuse  and  upgrade  energy-related  products,  lays  down  a  general  procedure  for  the 
assessment  of  product  repairability.  This  standard  is  the  reference  point  for  the  JRC 
repairability study, which, in turn, is the basis for the repairability score for smartphones and 
tablets set out in Commission Delegated Regulation (EU) 2023/1669. The repairability score 
laid down in this document follows this same approach, by adapting to household tumble dryers 

20  
Commission  Staff  Working  Document  Impact  Assessment  Report  Accompanying  the  documents 
Commission  Regulation  (EU)  2023/2533  of  17  November  2023  implementing  Directive  2009/125/EC  of  the 
European  Parliament  and  of  the  Council  with  regard  to  ecodesign  requirements  for  household  tumble  dryers, 
amending Commission Regulation (EU) 2023/826, and repealing Commission Regulation (EU) No 932/2012 and 
Commission Delegated Regulation (EU) 2023/2534 of 17 November 2024 of the European Parliament and of the 
Council  with  regard  to  energy  labelling  of  household  tumble  dryers  and  repealing  Commission  Delegated 
Regulation (EU) No 392/2012. 

6 

 
 
 
the general methodology laid down in the abovementioned documents, based on three main 
elements.  

The  first  element  in  the  repairability  score  is  the  priority  parts,  namely  those  parts  or 
components against which repairability will be scored. Priority parts are to be selected for each 
product. For tumble dryers selected priority parts could be, for instance, the pump, the drum 
bearings, the door, the drum belt, or the motor.  

The  second  element  is  the  scoring  parameters.  Typical  scoring  parameters  are  the 
disassembly  depth,  the  fasteners  type,  the  tools  type  and  the  availability  of  repair 
information. Some scoring parameters are addressed at priority part level and others at product 
level. The score for disassembly depth, fasteners type, or tools type consists of adding partial 
scores for each priority part. The availability of repair information, on the contrary, consists of 
a single score to the whole product.  

With  the  first  two  elements  it  is  already  possible  to  write  the  general  formula  for  the 
repairability score, which follows the format:  

𝑅 = α1 × 𝑆1 + α2 × 𝑆2 + α3 × 𝑆3 + ⋯ + α𝑛 × 𝑆𝑛 (1) 

where Sn is the score for the scoring parameter n and αn weighting factors which value depends 
on the relevance assigned to the parameter n. Weighting factors added must sum up 1. It is 
possible  to  assign  the  same  weighting  factor  to  all  parameters  since  all  may  be  considered 
equally  important.  However,  the  JRC  report  suggests  giving  lower  weights  to  parameters 
already covered by ecodesign. For example, a scoring parameter related to the availability of 
spare parts could be assigned, for tumble dryers and washing machines, a smaller weighting 
factor, because their respective Regulations on ecodesign, already contain a provision on the 
mandatory availability of spare parts.  

When the score for a parameter consists of adding partial scores for each priority part, such 
score is calculated according to the formula:   

𝑆𝑛 = 𝛼𝑃𝑃1 × 𝑆𝑛𝑃𝑃1 + 𝛼𝑃𝑃2 × 𝑆𝑛𝑃𝑃2 + ⋯ + 𝛼𝑃𝑃𝑛 × 𝑆𝑛𝑃𝑃𝑛 (2) 

where SnPPn is the score of each priority part PPn with respect to the scoring parameter n, and 
αPPn a weighting factor which would depend on factors such as the relevance of the priority 
part or the likelihood of failure. Assuming that all priority parts are equally relevant, αPPn can 
be just fixed according to the likelihood of failure.  

The third and final element of the repairability score is the scoring framework. The scoring 
framework sets out, for each scoring parameter n, the type of score to be applied (for instance 
a  1-to-5  score)  and  the  criteria  to  apply  such  score  (for  instance,  for  the  scoring  parameter 
disassembly depth, the 1-to-5 score for a specific priority part would be higher the lesser is the 
number of steps taken to disassemble that priority part). The score for each priority part would 
go into formula (2), or directly into formula (1) if the scoring parameter is addressed at product 
level and not at priority part level, as explained above.   

7 

 
 
5.3.  Repairability score for tumble dryers 

The general formulas (1) and (2) must be adapted to tumble dryers.  

The scoring parameters are the following: disassembly depth (DD), Fasteners type (F), Tools 
type (T) and Repair information (RI). These have been derived from the German repairability 
study and further adapted after discussion with stakeholders at the Consultation Forum on 11 
March 2024, taking specially into account APPLiA’s contribution. 

Subsequently, the formula for a repairability score for tumble dryers reads as follows:  

𝑅 = 0,450 × 𝑆𝐷𝐷 + 0,225 × 𝑆𝐹 + 0,225𝑆𝑇 + 0,100 × 𝑆𝑅𝐼 (3) 

Two scoring parameters have been assigned the same weighting factor (0,225), the disassembly 
depth a higher factor (0,450) and the repair information a lower factor (0,100). Disassembly 
depth has been assigned a higher factor after discussion at the Consultation Forum on 11 March 
2024, where stakeholders agreed that the disassembly depth overlapped with the detachability 
of the side panels (scoring parameter included in the initial Commission proposal), and that the 
weighting factor for the disassembly depth could be increased to account for the removal of 
the  detachability  of  the  side  panels,  which  was  deleted.  Concerning  repair  information, 
Regulation (EU) 2023/2533 already sets minimum requirements on repair information, making 
it  less  relevant  for  a  repairability  score.  This  approach  is  supported  in  the  JRC  study  on  a 
repairability  score  for  smartphones  and  tablets21,  which  points  out  that  the  inclusion  of  a 
minimum ecodesign requirement on a specific parameter can reduce its relevance as a scoring 
parameter. 

The chosen priority parts and their respective weighting factors are the following: 

Priority parts 

Water pump 
Drum bearing 
Drum belt 
Door 
Motor 
Main  printed 
board 
Fan 
Motor capacitor 

Acronym 
part 
WP 
B 
DB 
D 
M 
MB 

circuit 

priority 

Denomination 
weighting factor 
𝛼𝑊𝑃 
𝛼𝐷𝐵𝑒 
𝛼𝐷𝐵 
𝛼𝐷 
𝛼𝑀 
𝛼𝑀𝐸𝐵 

Value  weighting 
factor 
0.14 
0.09 
0.25 
0.08 
0.05 
0.28 

𝛼𝐹 
F 
𝛼𝑀𝐶 
MC 
Table 1. Priority parts and weighting factors 

0.05 
0.06 

Priority parts and their respective weighting factors are based on a list submitted by APPLiA, 
later modified after discussion with stakeholders in the Consultation Forum on 11 March 2024. 
The list is the result of an intensive consultation and data collection exercise among APPLiA 

21  
European Commission, Joint Research Centre, Spiliotopoulos, C., Alfieri, F., La Placa, M. et al., Product 
repairability scoring system  – Specific application to smartphones and slate  tablets, Publications Office  of  the 
European Union, 2022, https://data.europa.eu/doi/10.2760/340944. 

8 

 
 
 
members.  Weighting  factors  for  each  priority  part  were  set  according  to  two  criteria:  the 
likelihood of failure and the sales volume, as declared by the manufacturers participating in the 
exercise. Relevant literature, already mentioned in this document, suggests also considering 
the functional relevance  of a spare part as  a criterion to set weighting factors. However, all 
selected priority parts have similar functional relevance for the operation of a tumble dryer, for 
which  reason  this  criterion  has  been  dismissed.  The  list  is  also  consistent  with  the  list  of 
available spare parts laid down in Regulation (EU) 2023/2533 and with the relevant priority 
parts for tumble dryers identified in the study from the German Environmental Agency.  

Regarding the scores, they are calculated as follows:  

5.3.1.  Disassembly depth score 

The Disassembly depth score (SDD) of a tumble dryer is calculated by adapting formula (2) to 
the disassembly depth parameter:  

𝑆𝐷𝐷 = 𝛼𝑊𝑃 × 𝑆𝐷𝐷𝑊𝑃 + 𝛼𝐵 × 𝑆𝐷𝐷𝐵 + 𝛼𝐷𝐵 × 𝑆𝐷𝐷𝐷𝐵 + 𝛼𝐷 × 𝑆𝐷𝐷𝐷 + 𝛼𝑀 × 𝑆𝐷𝐷𝑀 + 𝛼𝑀𝐵 ×
𝑆𝐷𝐷𝑀𝐵 + 𝛼𝐹 × 𝑆𝐷𝐷𝐹 + 𝛼𝑀𝐶 × 𝑆𝐷𝐷𝑀𝐶 (4) 

Each 𝑆𝐷𝐷𝑃𝑃𝑛 in formula (4) is calculated based on the percentage of steps required to remove 
the corresponding priority part from the product with respect to the mean number of steps for 
that priority part as laid down in Table 2 and 3. The mean number of steps have been taken 
from the German repairability study. 

Priority part 
Water pump 
Drum bearing 
Drum belt 
Door 
Motor 
Main printed circuit board 
Fan 
Motor capacitor 

Mean number of disassembly steps 
16.1 
18.9 
40.9 
3 
49.4 
13.7 
7.7 
24.9 

Table 2. Mean number of steps for each priority part 

disassembly depth (as a percentage of the mean number of steps in 
Table 2) 
DD ≤ 70% 
70% < DD ≤ 90% 
90% < DD ≤ 110% 
110% < DD ≤ 130% 
DD > 130% 

Table 3. Disassembly depth score 

Score 
(SDDPPn) 
10 
7 
4 
1 
0 

5.3.2.  Fastener type score 

The fastener type score (SF) of the tumble dryer is calculated by adapting formula (2) to the 
fastener type parameter: 

9 

 
 
𝑆𝐹 = 𝛼𝑊𝑃 × 𝑆𝐹𝑊𝑃 + 𝛼𝐵 × 𝑆𝐹𝐵 + 𝛼𝐷𝐵 × 𝑆𝐹𝐷𝐵 + 𝛼𝐷 × 𝑆𝐹𝐷 + 𝛼𝑀 × 𝑆𝐹𝑀 + 𝛼𝑀𝐵 × 𝑆𝐹𝑀𝐵 + 𝛼𝐹 ×
𝑆𝐹𝐹 + 𝛼𝑀𝐶 × 𝑆𝐹𝑀𝐶 (5) 

Each 𝑆𝐹𝑃𝑃𝑛 in formula (5) is assigned according to the level of removability and reusability of 
the fasteners used in the device assembly, in accordance with Table 4. In case different types 
of  fasteners  are  encountered  in  the  disassembly  of  a  priority  part,  the  lowest  score  shall  be 
considered. 

Fastener type 

Reusable 
Resupplied at no cost 
Resupplied at additional cost 
Removable 

Table 4. Fastener type score 

Score 
(SFPPn) 
10 
7 
3 
0 

5.3.3.  Tool type score 

The tool type score (SF) of the tumble dryer is calculated by adapting formula (2) to the tool 
type parameter: 

𝑆𝑇 = 𝛼𝑊𝑃 × 𝑆𝑇𝑊𝑃 + 𝛼𝐵 × 𝑆𝑇𝐵 + 𝛼𝐷𝐵 × 𝑆𝑇𝐷𝐵 + 𝛼𝐷 × 𝑆𝑇𝐷 + 𝛼𝑀 × 𝑆𝑇𝑀 + 𝛼𝑀𝐵 × 𝑆𝑇𝑀𝐵 + 𝛼𝐹 ×
𝑆𝑇𝐹 + 𝛼𝑀𝐶 × 𝑆𝑇𝑀𝐶 (6) 

Each 𝑆𝑇𝑃𝑃𝑛 in formula (6) is assigned according to the complexity and availability of the tools 
needed  for  its  replacement,  in  accordance  with  Table  5.  Where  different  types  of  tools  are 
needed for the disassembly of a priority part, the lowest score shall be considered. 

Use of tools 

Repair possible with basic tools  
Repair possible with tools supplied with the spare part 
Repair possible with tools supplied with the household 
tumble dryer  
Repair possible with commonly available tools  

Table 5. Tool type score 

5.3.4.  Repair information score 

Score 
(STPPn) 
10 
7 
4 

0 

The repair information score (SRI)is calculated at product level in accordance with Table 6. 

Use of tools 

Availability of repair information at no cost for professional repairers 
Availability of repair information with a reasonable and proportionate fee for 
professional repairers 

Table 6. Repair information score 

Score 
(SRI) 
10 
0 

10 

 
 
6.  EXPECTED IMPACTS OF A REPAIRABILITY SCORE 

6.1. 

Introduction 

The addition of a repairability score to the new energy label does not in itself warrant a fully-
fledged impact assessment given the nature of such a limited modification to the label and the 
broad agreement among Member States, industry and stakeholders on the merits, urgency and 
modalities  of  such  an  addition.  Nevertheless,  the  Commission  services  have  updated  the 
analysis  of  the  2022  Impact  Assessment  to  provide  a  broad  estimate/idea  of  the  additional 
impacts.  

6.2. 

Policy options analysed in the 2022 IA 

The 2022 IA is the starting point for an update of the assessment of the impacts of the policy 
including  the  repairability  score.  The  following  table  displays  the  correspondence  between 
problems, measures and policy options as presented in the 2022 IA:  

Problems 

First key problem: 
missed in-use energy 
savings due to the lack 
of adaptation of the 
legislation to technical 
progress  
Second key problem: 
insufficient industry 
measures on circular 
economy 

Measures 
- Rescaling the energy label 
- Improving real-life representativeness of the 
energy efficiency formula 
- New energy efficiency limits 

- Mandatory availability of critical spare parts 
- Accessibility to repair and maintenance 
information 
- Availability of documentation for enhanced 
disassembly/recovery of WEEE-components 
and refrigerants 
- Permanent marking of the refrigerant type 
- User information on the location of the filters 

Policy options 
PO2: energy labelling measures 
(lenient option) 

PO3: ecodesign measures 
(ambitious option) 

PO4: circular economy 

Table 8. Schematic overview of drivers, problems, objectives and measures and their interlinkage 

The  2022  IA  concluded  that  the  preferred  policy  option  would  be  a  combination  of  all  the 
above,  namely  PO2+PO3+PO4.  PO2+PO3+PO4  has  been  implemented  in  Regulation  (EU) 
2023/2533 and Delegated Regulation 2023/2534, and it will apply from 1 July 2025.  

6.3. 

Policy as updated by including a repairability score 

Table 8 shows that PO4 is the policy option focussing on circular economy, which key element 
is the mandatory availability of a list of spare parts for a period of 10 years, after the placing 
on the market of the last unit of the corresponding model.  

Following  the  approach  provided  in  point  5.1,  whereby  the  repairability  score  would  be  an 
additional measure to extend the lifetime of tumble dryers from 12 to 14 years, the repairability 
score could be considered as an additional element of policy option PO4. The updated policy 
option on circular economy (PO4u), then consists of the following items: 

11 

 
 
- 

Items from the 2022 IA: mandatory availability of spare parts, mandatory access to repair 
and maintenance information, permanent marking of the refrigerant type, information on 
the  location  of  the  filters  and  the  need  to  clean  them  regularly,  and  availability  of 
information for enhanced disassembly/recovery of WEEE-components and refrigerants. 

-  New  item:  addition  of  an  A-to-E  repairability  scale  to  the  energy  label,  based  on  the 
repairability  score  explained  in  point  5.3.  The  letter  corresponding  to  the  class  of  the 
product within the scale will appear bigger than the rest of the letters. 

Further, following the 2022 IA, which preferred policy option is PO2+PO3+PO4, the policy 
option which impacts are to be calculated in this Section is PO2+PO3+PO4u.  

To  give  industry  time  to  adapt  to  the  new  policy  PO2+PO3+PO4u,  which  on  the  one  hand 
implies fixing the new label with the repairability scale on units placed on the market for the 
first time, and on the other hand the possible relabelling of units already placed on the market 
by the date of application of the new measure, the impact model assumes an obligation to fix 
the new energy label by 1 year after the date of application of Regulation 2023/2534, namely 
1 July 2026. This means that, during the first year of application of the new Regulations, the 
impacts calculated in the 2022 IA for PO2+PO3+PO4 apply, and from 2026 onwards those 
impacts need to be reassessed for PO2+PO3+PO4u. 

6.4.  Assumptions 

The inclusion of the repairability score does not change the assumptions made in the 2022 IA 
(Section 6 and Annex 6 in the 2022 IA), namely: 

-  The average lifetime of tumble dryers increases from 12 to 14 years.  

-  There is no change of the total EU stock estimated for the business-as-usual scenario (BAU) 
developed in  the 2022 IA. None of the policy options assessed in  the 2022 IA  entails  a 
change in the stock.  

-  The average repair costs per unit is around 150 €. As explained in the 2022 IA, there are 
very different views on how often a tumble dryer is repaired, varying from “it is often not 
repaired” according to APPLiA to “twice during the lifetime” according to R.U.S.Z22. The 
review study suggests that the machines on average will be repaired 0,4 times during their 
lifetime23 (5 €/year x 12 years being the cost per repair 150 €). To extend the lifetime, it is 
assumed that more repairs are required and that the repair and maintenance cost per year 
will increase to 8 €/year. With this assumption a tumble dryer will on average be repaired 
0,75 times during its lifetime of 14 years. 

-  Price increase is fully carried over to the consumer. 

22  
23  

https://rusz.at/en/ 
5 €/year in 12 years is used in the review study.   

12 

 
 
 
6.5. 

Impacts 

6.5.1.  Environmental impacts 

As explained in section 5.1, the repairability score would not change the environmental impacts 
for PO4 that were already assessed in the 2022 IA. The environmental impacts of PO4u and 
PO4  are  the  same  because  they  are  calculated  on  the  same  assumption  that  the  circularity 
measures will lengthen by two years the lifetime of appliances.  

Energy consumption during use 
[TWh/year] 

Savings 
[TWh/year] 

Cumulative 
savings 
[TWh] 

BAU 
PO4/PO4u 
PO2+PO3+PO4u/PO2+PO3+PO4 

2020 
10.50 
10.50 
10.50 

2025 
9.49 
9.49 
9.42 

2030 
8.97 
8.97 
8.30 

2040 
8.10 
8.16 
7.04 

2030 

2040 

2030 

2040 

0.00 
0.67 

-0.05 
1.06 

0.00 
2.11 

-0.17 
12.57 

Total energy consumption (in-
use+embedded) [TWh/year] 

Savings 
[TWh/year] 

Cumulative 
savings 
[TWh] 

BAU 
PO4/PO4u 
PO2+PO3+PO4u/PO2+PO3+PO4 

2025 
11.64 
11.64 
11.57 

2030 
11.21 
11.21 
10.58 

2040 
2020 
10.45 
12.45 
9.84 
12.45 
12.45 
8.72 
GHG emission, in-use + embedded 
[mtCO2e/year] 
2030 
2025 
2.52 
3.07 
2.52 
3.07 
2.53 
3.09 

2020 
3.62 
3.62 
3.62 

2040 
1.95 
1.59 
1.52 

2030 

2040 

2030 

2040 

0.00 
0.64 

0.61 
1.73 

Savings 
[mtCO2e/year] 
2040 
2030 

0.00 
1.93 

2.69 
15.01 

Cumulative 
[mtCO2e] 

2030 

2040 

BAU 
PO4/PO4u 
PO2+PO3+PO4u/PO2+PO3+PO4 
Table 9. EU environmental impacts for BAU, PO2+PO3+PO4 and PO2+PO3+PO4u 

0.00 
-0.01 

0.36 
0.43 

0.00 
-0.27 

1.54 
1.75 

Until 2031, the decrease in energy consumption is only due to PO2 and PO3, since the benefits 
from PO4 are only realised in the long term. From 2032 onwards, the effects from PO4u start 
to be noticed as described in section 6.3.1 of the 2022 IA. 

6.5.2.  Economic impacts 

The wider scope of PO4u increases compliance costs, due to the following two factors:  

-  First, the redesign of some models where manufacturers choose to do so in trying to get the 
highest repairability score. The average cost of redesigning the product is assumed here to 
be equivalent to the increase of cost calculated in the 2022 IA for PO2, this is the policy 
option including only energy labelling measures. Compliance costs in PO2 in the 2022 IA 
factored in a 1% increase of production costs due to manufacturers’ investment to attain 
better  energy  efficiency  classes.  The  introduction  of  a  repairability  scale  in  the  label  is 
assumed to trigger an equivalent effect with a similar increase of compliance costs.  

-  Second,  there  may  be  administrative  costs  due  to  relabelling,  as  suppliers  will  have  to 
provide two labels instead of one for a period of 4 months. These costs have been calculated 
in the 2022 IA and estimated at 0.3 EUR to print a label. For 1.9 million household tumble 
dryers sold in 4 months, this means a total cost of approximately 567,000 € for suppliers to 

13 

 
 
  
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
temporarily provide a second label for a transition of one label to another. They are one-off 
costs representing around 0.03% of turnover in the year that they occur, namely 2026.  

Since costs are assumed to be entirely carried over to the consumer, the  modest increase in 
costs due to PO4u will produce an equivalent increase of the sector’s turnover.  

The economic impacts of PO4u and PO2+PO3+PO4u are displayed in Table 10. These can be 
compared with the impacts of PO2+PO3+PO4 as calculated in the 2022 IA.  

BAU 
PO2+PO3+PO4 
PO2+PO3+PO4u 

BAU 
PO2+PO3+PO4 
PO2+PO3+PO4u 

Industry turnover [bln. €/year] 

2020 
1.27 
1.27 
1.27 

2020 
2.69 
2.69 
2.69 

2025 
1.37 
1.38 
1.38 

2030 
1.45 
1.57 
1.58 

Retail turnover [bln. €/year] 

2025 
2.84 
2.87 
2.87 

2030 
2.94 
3.09 
3.10 

2040 
1.54 
1.45 
1.47 

2040 
3.12 
2.30 
2.34 

Difference to BAU 
[bln. €/year] 

Cumulative difference 
[bln. €] 

2030 

2040 

2030 

2040 

0.12 
0.13 

-0.11 
-0.07 
Difference to BAU 
[bln. €/year]  

0.45 
0.54 

1.08 
1.29 

Cumulative difference 
[bln. €] 

2030 

2040 

2030 

2040 

0.13 
0.14 

-0.82 
-0.78 

-2.32 
0.80 
0.99 
-1.27 
Cumulative savings 
[bln. €] 

Total user expenditure [bln. €/year] 

Savings [bln. €/year] 

BAU 
PO2+PO3+PO4 
PO2+PO3+PO4u 

2020 
5.08 
5.08 
5.08 

2025 
5.16 
5.17 
5.17 

2030 
5.26 
5.33 
5.35 

2040 
5.26 
4.43 
4.47 

2030 

2040 

2030 

2040 

-0.07 
-0.09 

0.83 
0.79 

-0.46 
-0.70 

2.83 
2.26 

Table 10. EU Economic impacts for BAU, PO2+PO3+PO4 and PO2+PO3+PO4u 

6.5.3.  Social impacts. Employment 

The slight change in the sector’s turnover will produce an equivalent change of employment. 
As  explained  in  the  2022  IA,  the  impact  on  employment  for  manufacturers  and  retailers  is 
estimated from the turnover, with a correction for changes in labour productivity. Based on 
historical manufacturing data, an increase of 1% in turnover will lead to a 0,6% increase in 
workforce, and a 1% decrease in turnover leads to a 1,6% decrease in workforce.  

Total employment [jobs/year] 

Difference to BAU (jobs/year) 

2020 
22,023 
22,023 
22,023 

2025 
22,977 
23,118 
23,118 

2030 
23,651 
24,691 
24,742 

2040 
24,531 
18,681 
18,861 

1,602 

1,906 

2,594 

3,680 

2030 

1,040 
1,091 

439 

2040 

-5,850 
-5,670 

1,337 

BAU 
PO2+PO3+PO4 
PO2+PO3+PO4u 
Out  of  which  in 
the repair sector 

Table 3. EU Employment (manufacturers + retailers) for BAU, PO2+PO3+PO4 and PO2+PO3+PO4u 

7. 

INPUT FROM STAKEHOLDERS 

The Commission presented a working document at the Consultation Forum on 11 March 2024. 
At that meeting, the Commission gave a detailed explanation of the main assumptions for the 
assessment of the impacts and the corresponding results and discussed all the relevant aspects 
with stakeholders.  

14 

 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
Written  comments  were  submitted  by  stakeholders  and  Member  States.  Those  comments 
referred to the spare parts and parameters to be included in the calculation of the repairability 
index, as well as the scoring criteria. There also were contributions related to the relevance of 
the  information  on  repairability  for  the  definition  of  new  models  and  to  the  transitional 
measures to be applied until the date of mandatory application of the new label. 

These comments were examined and taken up to the extent possible. Minutes of the meeting 
and comments from stakeholders are publicly available in CIRCABC24.  

https://circabc.europa.eu/ui/group/418195ae-4919-45fa-a959-3b695c9aab28/library/793260a3-318a-448f-

24 
b55f-5dc27dd36118?p=1&n=10&sort=name_DESC  

15