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Repairability and CE marking: it's decided at design, not at the end of the project

June 12, 2026

Discovering during pre-certification that a product does not pass the EMC, means going back to routing. The repairability index is decided when choosing screws and connectors. Compliance is an architectural choice.

Éco-conceptionMarquage CERéparabilitéConformité
Repairability and CE marking: it's decided at design, not at the end of the project

There are two ways to approach the compliance and sustainability of an electronic product. The wrong way: making it a topic at the end of the project, when the design is already fixed. The right way: considering them as input constraints, just like function and cost. The first approach costs a re-spin. The second costs upfront thinking.

The numbers that justify the topic

Today, only 40% of failures result in a repair, with a public goal of reaching 60% in five years. And the lifespan directly affects the market: 55% of purchases follow a failure, which accounts for 72% of renewals. In other words, a product that lasts and can be repaired doesn’t just check a regulatory box, it changes the commercial dynamics of an entire category.

In France, the Anti-Waste Law for a Circular Economy (February 10, 2020) introduced the repairability index on January 1, 2021, followed by the sustainability index on January 1, 2024. Initially, five pilot products (washing machine, TV, smartphone, laptop, lawn mower) were targeted, with a progressive extension to follow. The score ranges from 0 to 10, established by the manufacturer or importer, based on five criteria and ten sub-criteria defined by decree: documentation, disassembly, availability of spare parts, price of parts, and specific criteria (software updates, support, software reset, usage counter, battery).

In addition to this, the usual stack of directives applies depending on the product: RED for radio, CEM, low voltage, RoHS for substances, DEEE for end-of-life, and the plastics directive. Mapping them out from the specification phase onwards helps avoid unpleasant surprises later on.

Repairability cannot be improvised

I’ve seen a case, anonymized: an audio storyteller for children, evaluated on the smartphone grid. Version 1: 5.4. Version 2: 5.1. The score decreases even though the product improves, because repairability depends on design choices (disassembly, access to wear parts like the battery or buttons) that come into conflict with other requirements.

There is a real technical trade-off: increasing repairability can reduce reliability. A clip-on and dismountable case is more repairable, but sometimes less robust. And it’s difficult to predict in advance which components will fail. These decisions are made during the architecture phase, not at the end of the project when everything is fixed. That’s where upfront work on calculation grids, done with the client, pays off.

Eco-designing means deciding upfront with a method

Serious eco-design is not just about “adding recycled materials.” It follows a six-step logic (rethink, refuse, reduce, reuse, repair, recycle) and relies on a life cycle analysis (LCA) conducted early on, not as a posterior justification. We define the functional unit, scope, impact categories, model, identify the families of elements with the greatest impact, and use this screening to challenge electronic, mechanical, and software architecture choices.

Concretely, this means integrating Design For Environment into design reviews, sourcing eco-compatible materials, studying packaging, planning for disassembly at end-of-life, and ensuring the availability of parts. Repairability, recyclability, and re-manufacturability are design objectives, not constraints.

The cost of neglect

Pushing these topics aside has a mechanical cost. Failing CEM pre-certification means reworking the layout, redoing tests, and delaying market release. Discovering that wear parts are not accessible means a mediocre repairability index displayed on store shelves, which is a commercial disadvantage. On the other hand, a product designed to last and be repaired becomes an argument, not a constraint.

Compliance and sustainability cannot be addressed at the end of the project; they must be built into the architecture. Mapping applicable directives from the specification phase onwards, addressing the repairability index during disassembly choices, and conducting LCA early to guide design from the start: it’s less expensive, more robust, and increasingly what the market and regulations demand. The question is no longer “how to pass certification at the end,” but “how to design compliant and repairable from the start.”