The U.S. Public Interest Research Group Education Fund (“PIRG”) and iFixit, pursuant to 16 C.F.R. § 1.9 and 5 U.S.C. § 553(e), hereby petition the Federal Trade Commission (“FTC” or the “Commission”) to promulgate rules governing consumers’ right to repair products and devices.
Manufacturers are increasingly restricting the ability of consumers and independent shops to repair products. Manufacturers do so in a number of ways, including requiring the use of specialized tools, implementing software locks, and withholding repair information from the public. Using these tactics, manufacturers force consumers to use manufacturer-approved repair shops and manufacturer-approved parts. Manufacturers can also cease supporting older devices, forcing consumers to purchase new devices prematurely. These tactics harm consumers by driving up the price of repairs and shortening the lifespan of products they buy. Additionally, manufacturers are creating unnecessary e-waste, harming the environment in the pursuit of profit.
A rule protecting the right to repair might take a range of forms, from a prohibition of unfair and deceptive trade practices limiting repair activities, to a repairability labeling system that would enable consumers to make informed purchasing decisions. Petitioners submit several considerations that should inform the Commission in the drafting of such rules. But regardless of the final form they would take, such rules would provide a single nationwide standard, improve access and affordability for consumers of repair services, bolster independent repair businesses, and reduce e-waste.
Senior Director, Campaign for the Right to Repair, U.S. PIRG Education Fund
Nathan leads U.S. PIRG’s Right to Repair campaign, working to pass legislation that will prevent companies from blocking consumers’ ability to fix their own electronics. Nathan lives in Arlington, Massachusetts, with his wife and two children.