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Right to Repair Comments to the FTC

Office of Technology Research and Investigation
Bureau of Consumer Protection
Federal Trade Commission
Washington, DC 20580

To whom it may concern:

Consumer Reports writes in response to the Commission’s request for empirical research in preparation for its upcoming “Nixing the Fix” workshop on product repair restrictions.

Consumer Reports has been active in promoting consumers’ ability and right to choose where to obtain repair of their products, which increasingly depend on electronics, computer software, and internet connection to function. Our goal has been to preserve the fundamental rights of ownership that have belonged to consumers for centuries.

We have developed a model state law, and are working to help enact effective right-to-repair laws in a number of states, including co-sponsoring a bill currently under consideration in California. In addition, we have advocated for implementation and reform of the Digital Millennium Copyright Act to promote the right to repair, and we included right to repair in the issues we highlighted for the Commission’s attention in its recent Hearings on Competition and Consumer Protection in the 21st Century. These issues are also part of the Digital Standard that Consumer Reports has developed to establish criteria to evaluate safety, security, and legal protections for software, digital platforms and services, and internet-connected products offered in the marketplace.

A key part of our work on behalf of consumers is product research, including testing, surveys, and reporting. The product ratings we publish often include reliability problems as a basis for a lower product rating. We would be pleased to delve more deeply into these ratings if it would be helpful to you. Taken together, these adverse reliability reports demonstrate the common consumer experience of having products break and need repair, and the importance of having convenient and affordable options to obtain repair.

Further, in a January 2014 article, “Should You Repair or Replace That Product? How to save money on appliances, electronics, and lawn and yard gear,” we published the results of a survey of 29,281 subscribers. The article noted that consumers who used independent repair shops were more satisfied with the repairs than those who used factory service.

We look forward to assisting the Commission as you prepare for and hold your workshop, and use the information you gain to ensure that consumers’ right to repair is effectively protected.

Respectfully,

George P. Slover
Senior Policy Counsel
Consumer Reports