cross-posted from: https://lemmy.dbzer0.com/post/54790585

From EU regulation 2019/2023 (emphasis mine):

(1) availability of spare parts: (a) manufacturers, importers or authorised representatives of household washing machines and household washer-dryers shall make available to professional repairers at least the following spare parts, for a minimum period of 10 years after placing the last unit of the model on the market: — motor and motor brushes; — transmission between motor and drum; — pumps; — shock absorbers and springs; — washing drum, drum spider and related ball bearings (separately or bundled); — heaters and heating elements, including heat pumps (separately or bundled); — piping and related equipment including all hoses, valves, filters and aquastops (separately or bundled); — printed circuit boards; — electronic displays; — pressure switches; — thermostats and sensors; — software and firmware including reset software;

I’m first of all disgusted that only “professional repairers” get this entitlement. But as well, there is little excuse to put a 10 yr time limit on software. It’s not like they have to maintain large parts-making machinery to maintain copies of software. Also shitty: no mention of source code. Broken closed-source software is not repairable.

The next paragraph shows how much confidence the EU has in end-users’ abilities:

(b) manufacturers, importers or authorised representatives of household washing machines and household washer-dryers shall make available to professional repairers and end-users at least the following spare parts: door, door hinge and seals, other seals, door locking assembly and plastic peripherals such as detergent dispensers, for a minimum period of 10 years after placing the last unit of the model on the market;

WTF, that’s it? That’s all we get? The EU’s nannying is so fucking disturbing. They block end-users from repairing their own appliance by denying them the right to access parts.

Maybe I want to buy the parts myself and then pay a pro to do the labor. Maybe I want to buy spares before they stop making the spares at the 10 yr mark. You also cannot rely on pros to find good prices. If you enter a pro builder supply shop in Europe, they often don’t even bother putting price tags on anything because pros don’t care. They just pass the price on to the client, whatever that comes out to.

The mention of “reset software” is interesting. It suggests EU lawmakers are aware of the kill switches. But instead of banning the practice, they let the swindle continue by only giving pro repairers access to the reset software.

(2) maximum delivery time of spare parts:

during the period mentioned under (1), the manufacturer, importer or authorised representative shall ensure the delivery of the spare parts within 15 working days after having received the order;

in the case of spare parts concerned by point (1)(a), the availability of spare parts may be limited to professional repairers registered in accordance with point (3)(a) and (b);

It gets worse:

(3) access to Repair and Maintenance Information:

after a period of two years after the placing on the market of the first unit of a model and until the end of the period mentioned under (1), the manufacturer, importer or authorised representative shall provide access to the household washing machine or household washer-dryer repair and maintenance information to professional repairers in the following conditions:

(a) the manufacturer’s, importer’s or authorised representative’s website shall indicate the process for professional repairers to register for access to information; to accept such a request, the manufacturers, importers or authorised representatives may require the professional repairer to demonstrate that:

(i) the professional repairer has the technical competence to repair household washing machines and household washer-dryers and complies with the applicable regulations for repairers of electrical equipment in the Member States where it operates. Reference to an official registration system as professional repairer, where such system exists in the Member States concerned, shall be accepted as proof of compliance with this point;

(ii) the professional repairer is covered by insurance covering liabilities resulting from its activity regardless of whether this is required by the Member State;

(b) manufacturers, importers or authorised representatives shall accept or refuse the registration within 5 working days from the date of request;

© manufacturers, importers or authorised representatives may charge reasonable and proportionate fees for access to the repair and maintenance information or for receiving regular updates. A fee is reasonable if it does not discourage access by failing to take into account the extent to which the professional repairer uses the information;

(d) once registered, a professional repairer shall have access, within one working day after requesting it, to the requested repair and maintenance information. The information may be provided for an equivalent model or model of the same family, if relevant;

(e) the household washing machine or household washer-dryer repair and maintenance information referred to in (a) shall include: — the unequivocal household washing machine or household washer-dryer identification; — a disassembly map or exploded view; — technical manual of instructions for repair; — list of necessary repair and test equipment; — component and diagnosis information (such as minimum and maximum theoretical values for measurements); — wiring and connection diagrams; — diagnostic fault and error codes (including manufacturer-specific codes, where applicable); — instructions for installation of relevant software and firmware including reset software; and — information on how to access data records of reported failure incidents stored on the household washing machine or washer-dryer (where applicable);

The maintenance information apparently does not have to include how to reverse a kill switch, unless, IIUC, the reset function is carried out by running software on an external device of some kind. If reseting is a matter of pressing a secret sequence of buttons, that does not seem to be covered here.

It’s quite vague because the law does not even define what “reset software” means. Software, firmware, and reset software are listed as a required “spare part”, but no mention of how the software gets to where it needs to be.

The maker must: “ensure that the spare parts mentioned in points (a) and (b) can be replaced with the use of commonly available tools and without permanent damage to the household washing machine or household washer-dryer;”

Can I take that to mean my commonly available linux laptop can be used for the software replacement?

(3) the user instructions shall also include instructions for the user to perform maintenance operations. Such instructions shall as a minimum include instructions for:

…
(g) identification of errors, the meaning of the errors, and the action required, including identification of errors requiring professional assistance;

Useful that we at least get to see the errors in the future. But if the error is “unbalanced load” and the machine is trapped in the error state even with an empty drum (as my machine is), we’re still fucked without having a way to escape the error.

I’m glad makers are required to tell users how to disable networking, but then they write “(if applicable)”. That could either mean: 1) if there is no network feature; or 2) it’s not disablable. That’s important. I’d be damned if I buy some Internet of Shit garbage and I cannot force it offline. Not to mention there is no requirement to make all the functionality available w/out a network. A maker could put bare minimum functions on the control panel to push you to use an app.

Want to complain? A 5 yr review of this law is in ~2 months.

From Article 8:

Review
The Commission shall review this Regulation in the light of technological progress and shall present the results of this review, including, if appropriate, a draft revision proposal, to the Consultation Forum by 25 December 2025.

Plz folks, write to your EU rep. And collaborate in this thread on ways to fix this mess so we can fix our shit. Redundant complaints to the EU might start to resonate collectively.