Euralarm Position Paper on EC proposal for a Directive on Right to Repair
Professional alarms are usually viewed as business-to-business equipment, however it is also the case that domestic/consumer installations can provide consumer financial benefits, such as reduced insurance costs, as well as significant personal safety and security improvements. Professional alarm installations are usually accompanied by maintenance agreements which would include annual test/certification as well as either on-site repair or exchange and repair at a repair centre.
To maintain the quality and performance of such installations it is normal for the technicians conducting those activities be both competent and trained on the specific types and manufacturers of the equipment concerned. Technicians may be from third party organisations but, because of this, there is usually a training/certification process before a manufacturer can authorise them to perform any maintenance or repair functions. We would anticipate that other industries providing key specialist equipment into domestic/consumer premises would have similar requirements.
Service and maintenance operations as mentioned above, could also be impacted by other Directives and legislation, like the Services Directive, the Directive 2012/19/EU on waste electrical and electronic equipment (WEEE) and legislation in the field of Cyber Security.
Euralarm therefore asks that due consideration be given to the coherence between the proposed Repair Directive and the Services Directive, the WEEE Directive (and the enacted national implementations), as well as to other various legislations, proposed or enacted, which require longer term updates of equipment from original manufacturers/producers.
