The FTC is seeking public comments on the right to repair. Here's what the Int'l ITC said.

The United States needs more Right to Repair mandates.  Repairing products instead of buying new ones is

• good for the local economy, as repair businesses are local.
• Good for consumers, as repairing a product costs less than buying a new one.
• Good for the environment as a repaired product has a much smaller environmental impact than making a new one.

A lack of repair competition is hurting consumers and small repair businesses, especially in the printer and printer cartridge industry, which this association represents. Without national action to protect our repair rights, corporate repair monopolies will keep wasting consumer dollars, wasting our planet’s resources, and prematurely sending products to the dump.

This occurs daily in the printer cartridge industry. Between 350 and 375 million printer cartridges are thrown away every year.  That’s roughly 1 million cartridges every day! The average toner cartridge weighs 2.5 pounds.  That translates into daily waste of 1250 tons, or the weight of more than 100 school buses or 200 elephants! Imagine if we can repair and reuse those cartridges instead.

There are three types of printer cartridges available on the market currently. Remanufactured (repaired) cartridges, new Original Equipment Manufacturer (OEM) cartridges and Asian new-built “clone” cartridges.

As with many other corporate monopolies mentioned by other posters from other industries, our industry’s OEMs want to keep their lucrative cartridge sales for themselves. HP Inc. deploys all sorts of nefarious tactics to lock customers into buying new cartridges and to keep third parties from remanufacturing/repairing their spent ones. Under the guise of security, HP frequently releases firmware upgrades that disable remanufactured cartridges.  (And there has been no reported issue ever of a security threat caused by a cartridge.) The OEMs have used technology and physical barriers (like self-stripping screws) to frustrate the repair and remanufacturing of its products, but still remanufacturers in this industry exist and thrive.

Asian new-built clone cartridges have cut deeply into the remanufactured cartridge marketplace. These cartridges can not be remanufactured, and these spent cartridges are often collected into our core stream, creating havoc for remanufacturers and creating a refuse issue for this environmentally-friendly industry.

Despite extreme pressure from competitors, remanufacturers in the printing industry have devoted customers, particularly in government sectors. As the demand for environmentally-friendly products skyrockets, more rules and legislation need to be enacted to promote the repair process, and bad actors need to be punished for interfering with or frustrating reuse, repair and remanufacturing.

We support this petition and call on the FTC to take action!

Submit your comments to the FTC in support of repair before February 2nd!

A new request by the Federal Trade Commission (FTC) for public comments on a petition for the agency to adopt rules that support our right to repair. the FTC opened a comment submission period in response to a petition submitted by US PIRG and iFixit petition submitted by US PIRG and iFixit.. The comments the FTC receives from the public are critical: they help the agency assess public support for new rules ensuring a right to repair. The deadline to submit your comments is Friday, Feb 2 at midnight, so do this right now!

What to say to the FTC

There is no set format for comments and they tend to weed out duplicate submissions, so we make no specific suggestions. Your comments can be as brief or wordy as you like. You can view some of the hundreds of comments submitted so far for an idea of what others are saying.

Most of all, the FTC wants to hear from you. That could be a story about your repair operations as a cartridge remanufactured, or seller of remanufactured cartridges.

If you're at a loss for words, iFixit, one of the petitions proponents, has proposed the following language:

The United States needs more Right to Repair rules. A lack of repair competition is hurting consumers and small repair businesses. Without national action to protect our repair rights, corporate repair monopolies will keep us wasting our own money, wasting our planet’s resources, and prematurely sending products to the dump. I support this petition and call on the FTC to take action!

What does the petition ask the FTC for?

The PIRG and iFixit petition seeks to restore competition in repair markets around the country. The two organizations identified several ways that companies could make repair easier and more widely available. They include:

• 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 are easy to obtain.
• 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,” 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 by clicking the button below, and follow the instructions to submit your comments.

Submit Comments to FTC