Brighton: Ensure NH has safe and secure electronics repair

‘Right to repair’ bill threatens safety of connected products

The products in our hands and internet-connected products at our homes (appliances, home automation systems and medical products) and places of work (farm equipment, trucks and tablets) are empowering tools that can be used to run a business, make financial decisions, ease our lives and stay connected to friends and family.

Consumer electronics are critical to our daily lives. But that integration poses new security and privacy challenges. The New Hampshire House Commerce and Consumer Affairs Committee recently held a public work session focused on determining the best way for consumers to have consumer electronics repaired in a convenient, safe and secure manner.

While calling legislation “fair repair” or “right to repair” makes for a great campaign slogan, further examination reveals serious threats to the safety and security of the growing network of connected products. We are concerned with the legislation’s potential for troubling, unintended consequences, including the potential for serious consumer security, privacy and safety risks, piracy hazards, potential environmental impacts, and barriers to innovation.

Consumers, small and large businesses, public schools, hospitals, banks and industrial manufacturers all need reasonable assurance that those they trust to repair their connected products will do so safely, securely and correctly. Enabling anyone to have the digital and physical keys to these products cannot be the solution. Government should be focused on protecting consumers, not adding more risk.

Repairing today’s consumer electronics is a very complex issue. Access to parts and repair manuals without training or accountability requirements affects not just the user of that singular product, but family and friends whose contact information is on the product or even fellow passengers on a Metrobus who would be susceptible to injury if a battery has been installed improperly. These are the exact reasons manufacturers work with affiliated networks to provide requisite training for the handling of lithium batteries in small consumer electronics or gas connections to appliances.

Manufacturers have created a system of checks and balances that enables consumers to have their products fixed while also knowing technicians are being held accountable. As New Hampshire legislators examine the repair issue, we strongly caution policymakers to resist unwarranted intervention with mandates that compromise consumer privacy, safety and security.

We believe New Hampshire must ensure consumers retain safe and secure repair rights to include:

• The ability to continue to have multiple options for safe and secure product repairs
• Changes to a product do not compromise the privacy, security and physical safety of individuals and businesses
• The public disclosure of information about product alterations is weighed against the public interest of choice, consumer security, privacy and intellectual property protection
• Products that are altered in an unskilled, unsafe and insecure way, are the responsibility of the product owners and entities who made the alterations

We encourage New Hampshire to recognize the unique characteristics of 21st century electronics and refrain from legislating their repair with a 20th century “solution.”

Dusty Brighton is executive director of the Security Innovation Center.