Right for repair regulation? - Page 1
Forum section: electronics / general

author: ndarjo21
author_rank: Regular Contributor
timestamp: October 31, 2023, 09:56:21 am
content: hello all, after looking around after watching some of removable battery and USB type c regulation videos in EU. i read this regulation "Commission Regulation (EU) 2023/1670 of 16 June 2023". Is this what Louis Rossman fight for?https://eur-lex.europa.eu/eli/reg/2023/1670/oj

author: tom66
author_rank: Super Contributor
timestamp: October 31, 2023, 10:44:17 am
content: Half-hearted attempt though.No guaranteed access to repair tools or parts for regular consumers, only independent repair professionals and the company that makes the product must make their repair services available. Well in the latter case that's already common so I'm not sure why it needs to be law. Apple will repair your broken iPhone if you want, they'll just charge you an absurd amount to do so.There's also nothing to stop companies gouging the prices they charge for replacement parts or services. They just have to be made 'available on the market'.True right to repair would include:* Access to parts and service guides by ALL. Service guides should be made freely available for a 10 year period from the time a product is introduced into the market. No bull about how consumers don't have the skills needed. I can get a service manual for my car, I definitely don't feel comfortable changing brakes but VW won't stop me. So why should Bosch stop me getting access to the service guide for my tumble dryer?I had this fun with my Bosch tumble dryer recently.* Tools and parts needed should be available at nominal cost within some time after a product is put on the market; companies should have an obligation to make the parts available for this period. Where parts are not available, companies should have an obligation to make pattern parts available through third parties by providing design information. The market then determines if there is a need for these parts to be produced.* Service guides should, at a minimum, describe overall system design and block layouts. Companies that disclose schematic layouts of major components could be awarded some additional grade as part of Ecodesign regulations. Every product with a sale value >€200, sold over say 10,000 units, should come with such a guide if placed on the EU market.

author: Psi
author_rank: Super Contributor
timestamp: October 31, 2023, 11:05:03 am
content: Also, for chips that need programming, the chip can be sold pre-programmed. There's no need to release binary files if the manufacturer wants to keep that proprietary to avoid people decompiling it.There's also no need to force product manufacturers to deal with the overhead of selling/shipping many small quantities of spare parts. It's totally acceptable to have a large min order qty so a 3rd party distributor can stock up on the part for resale over many years.Only requirement is that these orders can still be made long enough after the product release that any parts prone to failures are known.The profit of selling spare parts is actually pretty high in terms of the cost to the manufacture to buy/make the part,Verses what they'd get selling it as a spare part compared to the price they would get turning that part into a product and selling that product.The margin on repair labour is high enough that it can tolerate 5x 10x 20x, even 30x the cost of the part (even when that cost is not even BOM cost but a fraction of retail product cost). A $1 IC might still be profitable sold for $30 repair part if the total repair cost charged by the repair person is like $400.Obviously it's better if the part cost is lower, I'm just saying there is money to be made in selling spare parts.Selling bulk orders of every spare part in a product for use in repair would, in a lot of cases, be more profitable than turning those parts into products and selling the products.

author: ndarjo21
author_rank: Regular Contributor
timestamp: October 31, 2023, 11:38:47 am
content: actually, the conclusion is "From 20 June 2025, manufacturers, importers or authorized representatives shall ensure that the process for replacement of parts referred to in point 1(c), meets the following criteria: the process for replacement shall be able to be carried out by a layman."and the 1(c) is"From 20 June 2025 or from one month after the date of placement on the market, whichever is later:(i) manufacturers, importers or authorised representatives shall make available to professional repairers and end-users at least the following spare parts, including required fasteners, if not reusable, until at least 7 years after the date of end of placement on the market:(a) battery or batteries;(b) back cover or back cover assembly, if to be fully removed for replacement of the battery;(c) protective foil for foldable displays;(d) display assembly;(e) charger, unless the device complies with Article 3(4) of Directive 2014/53/EU;(f) SIM tray and memory card tray, if there is an external slot for a SIM tray or memory card tray."i think, that scope of repair is enough for end user. cause the mainboard repair requires more tools like hot air and soldering station.maintenance information also at least include electronic board diagrams. and i think it good enough to help diagnose and repair process. even though it need registration which i think will be hard and manufacturers may charge reasonable and proportionate fees.but i think at least manufacturer forced to make diagram exist. it better than nothing.also it stated in the regulations thatIn order to ensure that devices are able to be effectively repaired, the price of spare parts should be reasonable and should not discourage repair.

author: tom66
author_rank: Super Contributor
timestamp: October 31, 2023, 01:28:44 pm
content: That sounds like it only applies to phones, tablets and maybe laptops... What about the thousands of tonnes of televisions, fridges/freezers, dryers, washers etc thrown away every year. Smartphones are definitely an e-waste issue but any proposal needs to encompass all items that would be economical to repair if parts and service documentation were available.

author: ndarjo21
author_rank: Regular Contributor
timestamp: October 31, 2023, 01:31:05 pm
content: yeah, it only applies for phone, and something like that. laptop haven't regulation yet. i hope this is just first step of real right for repair regulation. and it seems EU have more concern than the rest of the world. so maybe if any of us have connection with the commission of EU, we can give them advice about this thing.

author: soldar
author_rank: Super Contributor
timestamp: October 31, 2023, 02:55:47 pm
content: This is more complicated than it might appear at first glance.Ensuring repair parts are available later costs money upfront which means many consumers would rather buy a cheap grey import than a more expensive maintenance guaranteed local product.Also, the control board of many appliances costs almost as much to replace as the entire appliance.A split A/C, a clothes washer, etc, have extremely complicated and expensive control board and if that board dies it takes the rest of the machine with it even though the rest is all fine and could last for years. I just find the present situation unacceptable. Older appliances with only electro-mechanical controls lasted longer and were more reliable.I have often thought that it must be possible to design a replacement "basic board" with very few basic functions but which would keep the machine usable even if in very basic mode.That or the manufacturer should guarantee the electronic boards for at least ten years totally free of charge.

author: tom66
author_rank: Super Contributor
timestamp: October 31, 2023, 03:15:11 pm
content: Is it really believable that a £500 mini split would actually have a £300 controller board in it? I would be surprised if BoM is more than £50 or so. The costly parts are the refrigerant, compressor, condenser/evaporator and building the whole thing. The control board is just a low power VFD with some extra sensors to control the AC function. The problem is you can only buy the expensive board if something breaks down. There should be some kind of long-term supply agreement on these parts and prices kept reasonable.As for grey-market: if the product is put on the market it should have the regulations applied. It is up to the market authority to prohibit imports that don't comply, this could be difficult for smaller things, but larger items like "white goods", air conditioners, etc. will not be too difficult.

author: ndarjo21
author_rank: Regular Contributor
timestamp: October 31, 2023, 03:31:05 pm
content: Maybe we can ask Dave to help us to promote this thing. Or any people which have influence to get awareness in this society.Yeah, the hard sparepart to get from a consumer device is the main controller unit. Maybe if we can raise awareness, and give the policy maker advice, that it is possible to make the MCU to be cheap or easier to repair. Idk if the MCU can use separate eeprom or bios which i think ch341a can program that.

author: Psi
author_rank: Super Contributor
timestamp: October 31, 2023, 10:57:21 pm
content: The administration of dealing with additional and much smaller production runs of spare parts push the price of those parts up vs what those parts costs originally at volume.Which is why I'm a fan of (for some parts) restricting it to only large volume orders and have 3rd party distributors take up the administration of selling individual parts to individual people and repair companies.

author: ndarjo21
author_rank: Regular Contributor
timestamp: October 31, 2023, 11:03:49 pm
content: Yeah. I agree with you. It better available in mouser etc. Than not available at all. So, good luck for your voice. Just kidding. Actually, are we have power to tell the policy maker. Maybe we can discuss what should present in a ewaste regulation related with ecodesign or repairability

author: tom66
author_rank: Super Contributor
timestamp: November 01, 2023, 12:02:18 am
content: Another option would just be to insist products are sold with longer warranties.For things that are easily damaged (water, physical impact, etc.) two years is fine as the majority of failures in that time will be due to external events. For products which are installed and expected to last some time in one location, like televisions, appliances, home entertainment (games consoles) and so on, perhaps the mandatory warranty should be five years?That means the manufacturer has to keep enough parts to maintain their "fleet", or suffer with having to refund customers or supply customers with a replacement product.