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.

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