EU repair laws start June 20 - How compliant is Apple?

The European Union is about to enforce new regulations concerning the repairability of iPhones and iPads. Here's where Apple stands, and where it needs to improve, before the new rules kick in.

The European Union has been aggressive when it comes to hardware regulations. Decisions made by the European Commission have forced tech companies, like Apple, to rethink some of their designs, in a bid to improve the technology landscape for all European citizens.

When the EU gave its final approval on the Common Charger Directive, which made it mandatory for many new devices to recharge using USB-C connectors, Apple joined in. It moved away from Lightning in favor of USB-C, a move that has been a considerable improvement for end users.

When it comes to another regulation about user-replaceable batteries, Apple has also managed to meet the provisions. Not only is it possible for a user to replace the battery of an iPhone, but Apple also made it easier to unglue the battery, by using electricity.

Evidently, Apple does what it can to keep up with hardware-related regulations where possible. However, there's more on the way, and Apple may have some work left to do to stay within the rules.

Ecodesign

On June 16, 2023, regulations relating to what is described as the "ecodesign requirements" of hardware were issued. The rules apply to cordless phones, smartphones, and slate tablets, with the latter two applying to the iPhone and iPad, respectively.

The regulations generally deal with the ecological and energy demands of mobile devices, including their use of electricity and the manufacturing of them. The bulk of it revolves around the support and repair of devices, so that they can have as long a lifetime as possible, preventing them from prematurely becoming e-waste.

There are exceptions to the rules, with one being smartphones designed for "high security communication." Despite Apple's security-minded approach, this chiefly means devices designed for government use.

The other is for "mobile phones and tablets with a flexible main display which the user can unroll and roll up partly or fully." This could include items like the long-rumored iPhone Fold, if only because the technologies associated with flexible displays is too new and therefore hard to really manage with regulations at this time.

While the regulations were adopted in June 2023, they actually come into force on June 20, 2025. That gives Apple only a short period of time to get its books in order for compliance.

What follows are a list of the main beats of the regulation, and where Apple currently stands regarding repairs and support.

Parts and Repair

The first key section is the "Design for repair and reuse." This covers a number of areas relating to repairing devices, including accessing spare parts and manuals.

Under the rules, Apple will have to make available spare parts and repair instructions for its mobile devices to professional repairers, for seven years after they have been removed from the market.

The list of parts includes:

• Batteries
• Camera assemblies
• Audio connectors
• Charging ports
• Buttons
• Microphones
• Speakers
• Hinge assemblies
• Mechanical display folding mechanisms

These components also cannot be assemblies of multiple items combined together, with the exception of a few fairly logical combinations. For example, the external audio connector could be combined with an external charging port, or a microphone could be part of a loudspeaker.

These parts must be available on a free-access website until the end of the seven-year period.

Apple must continue to offer spare parts for seven years after sales cease - Image Credit: Apple

Professional repairers must also be granted access to repair and maintenance information for the parts, again until the end of the seven-year period. "Reasonable" fees could be charged for access to the material.

There are also rules concerning the price of spare parts and even the speed of delivery.

The actual process of the repair has rules, including how the devices should be disassembled. It encourages the use of basic tool or commercially-available tool usage, reusable or resupplied fasteners, and to be performable within a workshop environment.

A "generalist" should be able to perform the fix of some parts, such as a display assembly, while less complicated tasks should be "able to be carried out by a layman."

So far, it appears that Apple is either at the point of meeting the regulations, or close to meeting it. While the regulations deal with servicing via third-party repair shops for the most part, Apple goes quite a bit beyond that already.

For professionals, there is the Independent Repair Provider Program, which provides access to parts and repairs, if they meet the requirements for registration.

Then there's the Self Service Repair Store, which allows consumers to perform their own repairs on Apple products with the supply of parts and even tools. This is already a pretty extensive thing for Apple to offer, and goes beyond the regulation in theory.

If that fails, Apple even points users in the direction of genuine parts distributors.

For Apple to fully meet the regulations, it simply would need to provide parts and access to manuals for the seven-year period.

There is also some discussion about the replacement of serialized parts, which Apple has struggled with for quite some time. However, with the expansion of its self-repair program procedures, this has been relaxed to a point.

The regulations still mandate that Apple provide access to software or firmware to make use of serialized parts, as well as for other repairs if necessary. This too is not difficult for Apple to deal with either, as it's simply a case of making the downloads available to professional repairers.

Durability and batteries

While the EU wants everything to be fixable, it would also help if those same parts are able to withstand some knocking around beforehand.

Under "Design for Reliability," devices must be able to withstand a variety of tests, covering everything from drops and scratches to dust and water, and even battery endurance.

The drop test involves the survival of 45 falls without cases or other protective materials, at a height of 1 meter (3.2 feet). However, there is no mention onto what surface the devices have to be dropped.

The test is slightly different for foldable devices, with 35 of the drops expected in an "unextended state" and 15 more in a "fully extended state."

A very smashed iPhone XR

We don't know how durable Apple's iPhones are under these tests, and Apple doesn't publish this information. The company is well known for its durability testing, though, and has documented that.

For scratch resistance, there is a need for the screen to achieve a hardness level 4 on the Mohs hardness scale. Foldable smartphones are exempt if they are designed to be used with a protective foil on the display.

Again, Apple doesn't offer a measurement on this scale, but it does work to include high-strength materials where possible. Gorilla Glass made by supplier Corning is known to have a hardness of six or seven on the ten-point scale.

To pass dust resistance, devices need to be protected from the ingress of particles bigger than 1 millimeter in size. They also need to survive a "splashing of water."

The equivalent ratings for each on the Ingress Protection ratings are IP4X for the dust test and IPX4 for the water.

Given the iPhone 16e is rated to IP68, with other recent models having similar ratings, Apple should be fine here.

For the battery, the EU requires smartphones achieve at least 800 cycles with a remaining capacity of at least 80%. Furthermore, testing for this must be under charging conditions where the charging rate is limited by the battery management system, rather than an unmanaged power supply.

Manufacturers must also include an optional charging feature that the user can enable, which stops the charging process automatically at 80% of the battery's full capacity. Also, the power management must have a feature that, once fully charged, there is no further charging power supplied to the battery until the charge level drops below 95% of its maximum charge.

An iPhone battery charging chart in iOS

For the iPhone 14 and earlier, Apple says its batteries are designed to retain 80% of the original charge capacity by 500 complete charge cycles. More importantly, for the iPhone 15 and later, the models are designed to do the same at 1,000 charge cycles.

Apple also has various battery management plans in place that meet these criteria. Since it's also software, it's something that it could further develop, such as the rumored AI battery management expected in a future iOS release.

Operating system updates

Under the rules, device producers will have to continue to supply operating system updates for security, corrections, or functionality changes, for at least five years after the "date of the end of placement. That is, five years after the model has ceased sales.

This is something that is certainly within Apple's wheelhouse. It typically provides operating system updates for five to seven years after the initial release.

Furthermore, in cases where hardware no longer gets the full operating system updates anymore due to age, Apple still releases security-specific updates for its older operating systems.

Where Apple has to be careful is in a section that concerns when an update "shows a negative impact on device performance." In such cases, the regulations state that another update that ensures at least the same level of performance as before the update is released should be issued "within a reasonable period of time," except of users give explicit consent for the negative issue to continue.

Apple has previous experience in this area, as "batterygate" saw Apple apply an update that throttled performance, in order to maintain stability in some iPhone models. Once this was discovered, lawsuits were issued, costing Apple dearly.

At least with the EU's regulations, it formalizes the need for Apple to avoid such issues in future.

Mostly ready

With the EU readying the implementation of the regulations within weeks, it's safe to say that Apple is in a pretty good position.

From a hardware perspective, iPhones are durable, and Apple has taken big strides to make its hardware more repairable. Not only by professionals, but by end users too.

That also applies to the software side as well, with its habitually lengthy period of iOS updates long after sales have ceased putting Apple in good stead to meet the EU rules.

There is seemingly no reason why Apple cannot meet all of the criteria in the regulations, especially considering it has had almost two years to prepare for it. The only real things it needs to worry about are any small remaining policy changes or country-specific availability voids that it needs to correct.

Apple may resist regulatory change. In this case, it seems to be well prepared.