Chapter XI, delegated acts, implementing powers and final provisions
Article 32: Transitional measures
Services may keep using products lawfully used before 28 June 2025 until 28 June 2030, old contracts run to their end but no longer than five years, and terminals may run for their useful life up to twenty years.
- Citation
- Article 32, CELEX 32019L0882 (Directive)
- Binds
- Service providers using products bought before 28 June 2025, and operators with service contracts signed before that date.
- In the instrument
- Chapter XI, delegated acts, implementing powers and final provisions
- Applies from
- 28 June 2025 for products placed and services provided from that date (Article 31(2)). The Article 4(8) 112 duty may be deferred to 28 June 2027 where a member state uses Article 31(3).
- Source
- EUR-Lex, CELEX 32019L0882
What it requires
Paragraph 1 gives service providers a transition ending on 28 June 2030. During it they may keep serving customers with equipment they lawfully used for like services before that date. The second subparagraph gives service contracts signed before 28 June 2025 a longer life: they may run unchanged to their end date, subject to a ceiling of five years counted from that date.
Paragraph 2 lets member states allow terminals that service providers lawfully used before 28 June 2025 to stay in use for similar services for as long as they remain economically worth keeping, capped at twenty years from the date they entered use.
The transition protects the installed base, not new purchases. A service that replaces a terminal or buys a new product after the cut-off cannot use the transition for the replacement, and a contract extended after the cut-off is a new agreement for this purpose.
In practice
The transition file needs three registers, not one: the installed products and their first-use dates, the service contracts and their expiry dates, and the terminal estate with commissioning dates. Each register should show the date the item leaves the transition and the replacement decision. A register that only lists what is old cannot show when it stops being protected.
What to do
- Build an asset register of products and terminals in use before 28 June 2025 with their entry-into-use dates.
- Record the contract end dates and the five-year limit for pre-2025 service contracts.
- Plan replacement before 28 June 2030, or before the twenty-year terminal limit.
- Check whether the member state took the paragraph 2 option for terminals.
Evidence to keep
- The installed-base register with purchase or first-use evidence.
- The contract register with signature and expiry dates.
- The replacement plan and its budget line.
- The member state's terminal transition provision.
Dates
- 2025-06-28Cut-off for products lawfully used and contracts agreed before the transition. (Article 32(1), (2))
- 2030-06-28End of the service transition and the outer limit for pre-2025 contracts. (Article 32(1))
- 2045-06-28Outer limit of twenty years after entry into use for a terminal first used on the cut-off date. (Article 32(2))
Cross-references
Where teams get this wrong
The transition is often read as a general five-year delay. It covers only continued use of products already lawfully used and contracts already signed. A new product bought in 2026 is not covered.
Read from the Official Journal text of Directive (EU) 2019/882, OJ L 151/70, 7 June 2019, Article 32. Check it yourself: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019L0882. This page states the provision in our own words and is not legal advice; it does not certify any product or service.