Conservancy submits comments to FTC for free software labeling

If accepted, appliances would include offer for source on EnergyGuide label

December 21, 2022

As one of his first official acts as Director of Compliance, Denver Gingerich submitted a comment to the FTC on behalf of SFC proposing adding software Right to Repair instructions for copyleft software on appliances. In conversations with various Right to Repair organizations, we brainstormed how to submit to the new FTC request for comment for the EnergyGuide labeling system. Based on these discussions, we found that there is no organization or governing body requiring repair instruction labeling for software. Given how many modern electronics and appliances rely on copylefted free software, SFC recommended adding software repair instructions that include labeling that there is copyleft software on the device and including specific links to the source code and repair instructions on the manufacturer's website. These are already required by the license, but are often buried deep in a manual somewhere. Adding these instructions would extend the rights afforded by copyleft software to all users of hardware that rely on it.

The FTC's EnergyGuide labeling system started out as a way to provide transparency in energy usage (and cost) to give consumers a better picture of what was entailed in the lifetime of the product. Over the years it has become a more holistic guide on the complete lifecycle of production, use and disposal of our appliances. SFC believes that the right to repair must be part of this holistic view. Free and open source software provides longevity for products that are either deemed too old for manufacturers to support, or want to force you into buying new ones so they can perpetuate their 'planned obsolescence'. SFC believes that FOSS is a critical component to achieving all the goals of the Right to Repair movement.

Joining together with the Right to Repair groups has opened up SFC to myriad new ways to provide advocacy for software freedom. SFC is grateful to the Right to Repair movement for the inclusion of software related concerns, and expects these budding relationships to grow into further fruitful cooperation to support users of all kinds of devices.

You can read our comment directly here or submit your own at the FTC website.

For more details on SFC's submission, see our blog post on our comment to the FTC.