[Themaintainers] The FTC is taking public comment on Right to Repair

[Nathan Proctor]

Dear Maintainers,

*TL;DR* - Please consider submitting a comment
<https://www.regulations.gov/commenton/FTC-2023-0077-0001> in support of
Right to Repair at the Federal Trade Commission. Our petition for rulemaking
<https://www.regulations.gov/document/FTC-2023-0077-0001> calls for several
reforms, including supporting their creation of a "repair score" system to
incentivize fixable designs.

Here's a little more info:

On January 4, the FTC opened a comment submission period in response
to a petition
(PDF)
<https://publicinterestnetwork.org/wp-content/uploads/2023/11/2023.11.14-Petition-for-Rulemaking-SUBMISSION.pdf>submitted
by US PIRG Education Fund (my organization) and iFixit. The comments
the FTC receives from the public are critical: helping the agency grasp
public support for new rules ensuring a right to repair. The deadline to
submit your comments is *Friday, Feb 2 *(30 days after the opening of the
submission period).

*What to say to the FTC*
There is no set format for comments - and they can be as brief or wordy as
you like. You can view some of the hundreds of comments submitted so far
<https://www.regulations.gov/docket/FTC-2023-0077/comments> for an idea of
what others are saying.

Broadly: the FTC wants to hear from you. That could be a story about repair
restrictions - like a manufacturer who refused to repair a product, high
costs or limited availability of repair for you or your community. It could
be related to your field of expertise in why repair is so important to
society, and why repair ecosystems need to be protected.

*What does the petition ask the FTC for? *
We see repair as essential to the mission of the FTC in both consumer
protection and protecting competition. Our petition identified several ways
that companies could make repair easier and more widely available. They
include:

   - *Create a system of "Repair Scores *- to allow consumers to see how
   repairable a product is before they buy it, something already being used in
   France, and originally pioneered by iFixit.
   - *Increase the accessibility of consumable components *- the FTC should
   determine that parts that routinely wear out, like batteries, should be
   replaceable and readily available for the product’s entire lifespan.
   - *Increase the availability of common parts* so that components that
   are prone to wear and tear should be easily replaceable.
   - *Ensure that consumers have repair choice* and the liberty to choose
   their repair provider or opt for DIY solutions.
   - *Provide sustained product support* so that key product functions
   remain intact even if the product is discontinued, with repairs possible
   through independent shops.
   - *Ensure that identical components are interchangeable* by limiting the
   use of parts pairing -components from identical devices should be
   interchangeable without needing manufacturer intervention.
   - *Protect consumer privacy* by making sure independent repair shops are
   not mandated to disclose customers’ personal information to manufacturers.

The FTC has been instrumental in advocating for Right to Repair. Their
landmark 2021 report, “Nixing the Fix
<https://www.ftc.gov/system/files/documents/reports/nixing-fix-ftc-report-congress-repair-restrictions/nixing_the_fix_report_final_5521_630pm-508_002.pdf>,”
debunked manufacturers’ justifications for repair restrictions. They’ve
taken action against companies like Harley-Davidson, Weber, and
Westinghouse for voiding warranties for third-party repair work.

*Submit Your Comments*
To submit your comment, visit the Federal eRulemaking Portal for docket
number FTC-2023-0077
<https://www.regulations.gov/commenton/FTC-2023-0077-0001> and follow the
instructions to submit your comments.

Thanks for your support! I look forward to reading your comments!

-- 
Nathan Proctor
Senior Director, U.S. PIRG Campaign for the Right to Repair
O: (857) 413-2534
C: (203) 522-3860

*Come work with me - we're hiring*
*Right to Repair Advocate
<https://jobs.publicinterestnetwork.org/en/postings/57acc6d7-bf8a-43c1-8148-05e996b44d05>*
*Federal Legislative Director
<https://jobs.publicinterestnetwork.org/en/postings/5701f4c3-2c69-420a-9441-367c466b4925>
*
*Zero Waste Program Director
<https://jobs.publicinterestnetwork.org/en/postings/f9d20a02-b2a8-4678-9a82-e5a06ee89a38>*
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