As per the provision laid down in Annex II.1.2.1 to the regulation, manufacturers ‘shall ensure that joining, fastening or sealing techniques do not prevent the disassembly for repair or reuse purposes of’ a number of components (data storage devices, memory, etc..).
An elaboration of the technical features related to the ability of the product to be disassembled should be part of the standardisation deliverables in the framework of the ‘Standardisation request to the European standardisation organisations in support of Commission Regulation (EU) 2019/424 of 15 March 2019 laying down Ecodesign requirements for servers and data storage products pursuant to Directive 2009/125/EC of the European Parliament and of the Council and amending Commission Regulation (EU) 617/2013’.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.