Conservancy submits comments to FTC for free software labeling

[Software Freedom Conservancy]

      Conservancy submits comments to FTC for free software labeling
  If accepted, appliances would include offer for source on EnergyGuide label

URL: https://sfconservancy.org/news/2022/dec/21/ftc-comments-free-software-labeling/

Social Media:
  https://social.sfconservancy.org/notice/AQq9am4UqaEoB1uOLQ
  https://twitter.com/conservancy/status/1605636752101736450?s=20&t=2oq_eDYpatejUnsRYevb0Q

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 [0] or submit your own at the FTC
website [1].

For more details on SFC's submission, see our blog post [2] on our comment
to the FTC.


[0] https://downloads.regulations.gov/FTC-2022-0061-0018/attachment_1.pdf
[1] https://www.regulations.gov/commenton/FTC-2022-0061-0002
[2] https://sfconservancy.org/blog/2022/dec/21/energyguide-software-repair-label/