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D.Transparency of Repairability by OEMs/Industry

One objective of the Workshop was to learn whether consumers understand the existence and effects of repair restrictions.[1] At the Workshop, several panelists agreed that repairability should be a factor for consumers to consider when making purchasing decisions.[2] Currently, however, right to repair advocates argue that “consumers lack information at the point of purchase about repairability.”[3] Similarly, Dr. McGraw stated that among other things, repairability is one thing that consumers are “woefully misinformed about.”[4]

Panelists and commenters discussed the idea of a “repairability score” or repairability rating to better inform consumers about the repairability of products.[5] For example, Workshop panelist Minnesota Senator Osmek suggested that a “repair score” could help consumers “make the decision on what they want in a device.” He went on to say that if consumers “want to have a repairable device, they will look for a high repairable score.”[6] At least one non-OEM company is doing this to a certain extent; iFixit rates products “for ease of disassembly and repair” to provide consumers “with an educated guess of repair difficulty before they buy the product.” iFixit stated in its empirical research submission that it considers things like, “how time-consuming is [the product] to open? Can broken components be replaced individually, or will you have to swap out more expensive larger modules? Are the components that are most likely to fail easily accessible by consumers?”[7]

As Dr. Crane stated, “it would be great if we could get people to make consumer-based buying choices because of the security of the device or the repairability of the device in addition to the features of the device….”[8] Consumers can only make buying choices based on repairability if they are aware of how easily a product can be fixed.[9]

VIII.IDENTIFICATION OF ISSUES TO BE CONSIDERED IN ANY ACTION TAKEN BY INDUSTRY, POLICYMAKERS, OR LEGISLATORS

The expansion of consumers’ repair options, whether through industry initiatives or through regulations or legislation, raises numerous issues that will warrant examination. In this section, we identify some of the most significant of these issues—the types of products that should be covered by expanded repair rights, the treatment of component parts, dollar and


  1. See Call for Empirical Research, https://www.ftc.gov/nixing-the-fix-call-for-research.
  2. According to Dr. Earl Crane, “consumers should have a choice between a repairable device, a secure device, or a securely repairable device…” Transcript, at 94.
  3. Transcript, at 58.
  4. Id. at 97.
  5. Id. at 25. See also Andrew Keates comment (“I believe a repair-ability rating would be a useful addition to product labeling…. I would certainly give preference to buying a product with a high repair-ability score.”).
  6. Transcript, at 152.
  7. iFixit empirical research, at 20.
  8. Transcript, at 116.
  9. Furthermore, if a self-regulatory or legislative body were to consider creating a repairability scoring regime, it should also consider having a parallel durability scheme because repairability only tells half the story. Products that rarely break down but that are costly to repair may be more desirable to some consumers than products that break more frequently but are easier to repair. Repairability and durability, however, are not necessarily opposite sides of the same coin. A durable product could also be easy to repair.

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