negative_zero

"I can't imagine having to have each hardware iteration certified by the FCC."

Depending on your device and the magnitude of the changes, this might simply be the reality for you. This is why I always try to tell people that you need compliance at the table from the start or you really risk making life very difficult for yourself. Find yourself a compliance specialist or at least a hardware engineer who is familiar with the regulations.

EDIT: You CAN'T just iterate ad-infinitum for free without consequence like you do for software. This thinking and approach, only works in software land. No where else.

It would be ridiculous to build a house and having the builder iterate on your house over 2-3 years to finish it, no?

The other part of the rules are for human safety. Devices can directly hurt people (like a microwave) or indirectly (like a crappy device that prevented ambulance phone calls going through).

It's as simple as that (and not perfectionism or being mean to the poor software people).

""we're going to teach you how to cheaply get your product to market in a way that respects the spectrum" I'm available to do exactly that for you at my hourly rate :D

"Now that I'm in position to ask ;)"

Ask away :) This is boring for 99.99999% of the population so I don't get to talk about it often :)

"I've wondered about the glass/plastic window PC cases.. Surely a PC case itself would not be required to have any emission tests done on it, or would it?"

You're right, a PC case itself does not need EMC compliance, but a PC case that's sold with a power supply does. So does one with built in fans and lights or anything electronic. IMO and very much off the cuff, certing the case + lights and fans without a whole computer inside is probably reasonable. But I would personally try cert with a whole PC (defence in depth).

"On the other hand, might the PC motherboard emissions be certified with the assumption that it will be placed inside a case?"

Yes it can be certed that way. Generally if it is, the details have to be in the manual.

But also, legally, you don't really need to cert a motherboard because it will always be integrated into another thing. However the reality of the PC architecture is that it is extremely modular and reach module is extremely complex. It's simply not at all practical for any systems integrator to try to modify those modules to try and make a whole PC compliant so that they can sell it. Even sticking the whole thing in a metal case might not be enough because the case has cables attached to and unwanted emissions and get out via those.

So for practical purposes manufacturers of motherboards, graphics cards, PSUs, hard drives etc vigorously test and cert their products with decent margins so that no matter what cards are used or how a PC is put together, the sum will be compliant. And this rule holds pretty well in general at all scales, from the individual parts and submodules that come together to make a product up to several products wired together in your house with power and network cables.

And system integrators can demand these requirements because it's necessary for the industry to function. I found a few years ago on Dell's website their manual for part suppliers. It listed every standard they required, made stricter and even had additions of their own so that they could sell with your module everywhere in the world, because they sell everywhere. It basically a thick manual on making a computer "world compatible".

"And then finally comes a consumer (or even a small integrator) and sticks in a PC motherboard inside a windowed case—but in this case the case might not be doing much on the RF side. Or maybe the cases provide better RF protection than they look like or the MBs don't need a case for that reason in the first place :)."

And the consumer benefits from everything I explained earlier. They can buy parts and assemble a computer that will be compliant. It's also why computer shops can build you a PC and sell without a cert and it'll be fine. Just the sheer effort of all these manufacturers so that they have a market to sell into means that the problem is solved for small players in the traditional PC world. The traditional PC industry is quite unique in that way actually.

It sounds like you are actually doing some things right :) FCC, for example, have scope for "modular approval". Order a radio module (with modular approval), do exactly as the datasheet tells you and you can "piggy back" off the radio modules radio certs. But you will still need to test and cert for things like your own "unintentional emissions", maybe ESD and other things (NOT actual compliance advice btw, this is just to give a rough picture).

"That said, while I actually enjoyed the snark in your reply, there are those of us who actually do want to get this right and do the right thing, despite lacking years of experience and an infinite budget."

Oh I absolutely know you people are out there :) (I've consulted for them. I've also consulted for the ones who are learning the hard way...)

I don't intend to be mean with posts like this on HN, but some reality on these posts is just needed IMO. Especially given how much software dominates product development these days and people just don't know.

I think it's difficult for new comers, but I don't know how you fix that other than asking a consultant. The earlier the better. You can certainly make early feature and design choices to make your certs simpler (and cheaper) down the road.

That said, I think a good place to start for anyone is the following:

1) Find a product that is broadly similar to yours. Is it like a small computer? Is it a wired network device like a router? Maybe it's like a bluetooth dongle or smartwatch? Find one from a large reputable company and search said company's website for their "EU Declaration of Conformity". On these docs (even though it is not required) many companies list the standards that the device is compliant with. They have names like: EN 55022, EN 60950, IEC 61000-3-3.

NOTE - This is for EU only, but they have massive regulatory reach. Also many FCC and EU standards are very similar or even the same. Over time they have been converging more and more.

2) Do this for a few different devices of the same or similar category and you will notice many which are always there and some that are sometimes there. Now you have a starting template of standards that you might need.

3) With this starting template, you can now look up the standards names and often download the first few pages free to get an idea for what they are for.

4) Get a quote from a lab. They often do a lot of testing for product importers (as onus is also on said importers), so they can have "non-engineer friendly" forms that you can fill in. This will give you a price but also some information on what they think you need (they have to be careful though because they have to maintain their independence). Tell them you want CE (Europe) and FCC (North America). This covers much of the world for you. Many countries, even those with their own standards, also simply accept CE and FCC (again this is all in very very broad strokes). Many standards are also just copy and pasted between different regulatory domains but they change the name. So the original standards body will have their name for it. When the EU recognises it, it'll get an "EN" number for it's name (for example).

4b) Consider a hiring consultant for a short chat to "downsize" the standards you need and maybe they can point out any you might be missing. Good ones can also advise you on things you can do to avoid standards (and this is not in an illegal way). If you understand the rules well, you can sometimes make small changes and avoid whole sets of rules and testing (classic one IMO is a radio device. In VERY GENERAL TERMS, if it's going to be used more than 40cm from a human, then you don't need to test for human absorption of RF energy. My Chromecast, for example, has a disclaimer on it so that they can claim exactly this (IMO of course) ). How to find a good consultant? Well that's hard and I don't have a sure fire way sorry. Some labs have business cards of small local consultants.

5) Source copies of the standards and read them (Yes it'll likely be heavy reading). Most standards sellers (including the national ones) are crooks. Don't use them. Instead go to the Estonian Centre for Standardisation and Accreditation: https://www.evs.ee/en . They are the cheapest source I know of for standards in English (and only English matters). Further details in an old comment of mine here: https://news.ycombinator.com/item?id=36452660

These above steps are the same steps that I myself use.

Sources to read ... sadly I've not found many good ones. I think the best one that I would recommend is https://incompliancemag.com/ It's dry and does what it says on the tin. But their archives have some great articles by experts. They cover new standards, certing particular devices, testing technology etc. Even the ads can be kind of informative I think. It's good for learning the general layout of the field. Not a shallow learning curve but not steep either IMO (It's also free in digital form).

1) test and exercise your product to extremes so that you can say with high certainty that: no matter what the customer loads, it won't breach the rules.

2) As pjc50 mentioned: Lock down the parts which the user could potentially cause the most damage with. i.e lock down that radio firmware (why is why none of it is open source).

If you do (1) and (2) and a few other things, you buy down your risk sufficiently that you can confidently demonstrate that re-certs are not needed.

The Author of the parent article IMO is doing the exact opposite.

There are also half-way houses: Just doing "pre-compliance testing". So not a formal cert, your just doing a quick test in an anaechoic chamber or even on a table top scanner. Of course this only applies to things you can self-certify. Some things, like radios (WiFi, Bluetooth etc.), you cannot self-certify. That's why almost everyone buys the radio as a module (To buy down their risk). By consequence: That's why those radio module manufacturers have the firmware locked down hard and engineer and cert the radios to have big margins.

There are a lot of rules yes, but there is actually a lot of flexibility and common sense in the system too (but it is still imperfect, absolutely). But that flexibility does not allow for horsing around. If you can demonstrate to Friendly Spectrum Agency all this due diligence, you are going to have a MUCH better time.

"Is this not exactly equivalent how I might buy a Raspberry Pi and install a non-Raspberry-authorized OS on it? Or equivalent on how I might buy a PC and install Linux on it? Or Android and LineageOS? Are those devices certified not only as SOLD but also as modified by the end-user with software, making them somehow different?"

Yes and no :) Very very succinctly: When you test and cert, it is best practice to create the worst case scenario for your product and pass like with healthy margins. Especially for something like a smartphone or PC, when it's in the test chamber (for something like radiated emissions), you run it at "full noise" (even if it's not a realistic use case). So all your clocks: maximum (don't use all of the clocks? Turn them all on anyway); Power draw: Maximum or more; Play seizure inducing video to exercise that screen; Connect peripherals that are likely to be used to make sure those don't screw you etc. PCs and phones, especially, are tested at these extremes so that the manufacturer can be confident that despite what software the end-user loads, the device will remain compliant (this is also why the radio firmware is kept locked down hard).

Now in the case of this article, sure, the dev boards have CE, but what does that mean? How did they test it? Where all the peripherals running? What did the physical test setup look like? Under CE they are required to keep a compliance folder and to provide the information on request.

My experience with, dev boards that are "compliant". They just powered it up and maybe ran a simple program. Low effort, low noise, easy pass, because the reality is that they don't need it and time is money.

So now you a third party integrator takes that dev board, and runs something that wasn't exercised or puts it into a state that is non compliant. That's on you. Just like it's on the Author of this article.

I might be wrong in this case. Maybe the dev boards have excellent test setups. I might look at the test docs and think: "oh we should be fine". And just do a pre-compliance test and self-certify. You have to evaluate the risk each time and make a call.

If Microsoft released a patch tomorrow that somehow caused a sizable percentage of PCs to start stepping on the cell phone bands they would VERY quickly be told (I emphasise told NOT asked) to fix it. Just like any software this Author could load. They have not sidestepped any responsibility.

Disclaimer: Nothing below is meant as legally relevant compliance advice. This is just my opinion on the matter.

Going to snark:

"The testing and certification industry is odd"

Except, outside the software world, the real world, where there are real consequences, it's not really.

"The line about CES, in particular, made my hair stand up."

Why? Absolutely the unauthorised device at CES is should NOT be allowed. What if said device caused too much interference on cell phone frequencies and suddenly nobody at CES can dial the local emergency number?

If that made "your hair stand up", here's one from personal experience that will freeze your blood:

I worked as a teen for a certain electronics chain. Said chain was selling a wireless weather station imported from China. A government department that monitored the country for Earthquakes noticed that this device impinged on their frequencies. After the spectrum regulator confirmed the finding, a nice gentleman from them visited us a told us the following:

1) As of this moment this device can no longer be sold. Move it off the floor immediately (he stayed and made sure we did exactly that).

2) That we will immediately issue a recall of said device at your own cost and issue full refunds to the customers.

3) He will return when we decide on further enforcement action which may include punitive fines and recommendations for further remedial action you will need to undertake.

"In theory, it exists to serve the public good and uphold consumer protection laws."

Well here's a (very simplistic) tidbit for the author: In the US, part of the gestation and formation of standards bodies and testing was "market forces", not for the public good. It was to help protect companies from litigation. If you followed the standards, tested and certed to them, paid the fees etc you then had the standards entity bat for you in court (UL is short for Underwriters Laboratory. That name was not chosen for funsies).

"However, in reality, the labs are “too busy” to respond or reply very late and generally sound less than eager to work with you."

Well you don't sound like a serious customer. AND the Labs are not there to give you advice. They're there to do INDEPENDENT testing.

"Variations of the FCC exist in pretty much every developed economy. Putting a poorly tested hardware product on the market immediately puts a target on your back. Maybe you’ll get lucky, but chances are that someone somewhere will report you. And, unless you are operating entirely out of China, it will hurt. A lot. Both your company and maybe even you, personally."

As it should. The electromagnetic spectrum is a very precious and very limited commodity and IMO, the best regulated "commons" in human civilisation (though still not perfect). So no, you are not welcome to just urinate in it willy nilly with your hustler start up product.

"I did not want to spend so much money on testing before I validated the market or gathered a community of believers."

And there it is.

"This way, the electronic device liability will fall on the manufacturer, and the magic of friendship EULA should afford me enough protection to make this a pure software play."

No. That's not how this works.

1) I assume the author is from the US (as they speak about the FCC). I had a 30 second look at these dev boards and their instructions. There is no FCC conformity declarations or markings, so US customers can't use it.

2) It has CE and UKCA though, so customers from EU+UK (and some other countries) can buy them but the certs only cover the dev boards AS SOLD. (i.e without the authors software)

3) Author is modifying the product behavior with their software. So yes author. You are still liable. Technically, your customers are first in the line of fire. But the likely sequence of steps is: Friendly Spectrum Representative will visit them first, have a chat, ask them to stop using the device, then leave them a lone and then come for YOU.

4) What the author has actually done is "buy down" their risk. It is simply less likely that the product will become non-compliant when their software is loaded. But it is still possible. At second glance, those dev boards don't come with a power supply. What is your recommended power supply to use Author? Have you tested your setup with said power supply and have test reports at the ready for when Friendly Spectrum Person comes knocking?

5) Sure it seems clever but Friendly Spectrum Agencies actually have quite far reaching and scary powers. Don't think that your little sleight of hand here is clever and protects you. Fundamentally: You are repackaging + modifying an existing product. The steps you are taking in between to "launder" your liability are irrelevant.

Frankly, it's shit like this, that makes it harder for everyone else playing by the rules. It did actually used to be easier. There used to be exemptions for "low volume" products. But all of those were seen as loopholes and HEAVILY abused. Now these toys have been taken away, with more to follow.

We have to be honest with ourselves about this, recognise how the deck is stacked against us and respond accordingly.

I picked five years half arbitrarily and half what I think is fair. Perhaps what most people think is fair is a lower or higher number.

> The point is, I OWN the device. It's mine. If I can find someone with the expertise to keep it running past its intended life, that should be looked at favorably.

Why as a company owner should I have to support the chance of you wanting to repair your device in 10 years? I have another big post in two parts where I try to illustrate that it's just not practical technologically and legally => it's why I proposed good long warranties. You just cannot give these companies an inch. Right-for-repair legislation will just be messy and give them too many inches to weasel out of it.

> But Apple, Samsung, and many other companies are actively preventing feasible repairs based on unreasonable and arbitrary cooked-up "company policies." Attaching serial numbers to parts and making them inoperable until they're blessed by the manufacturer is a racket and everyone knows it.

This will be harsh, and probably unpopular on HN, but in ALMOST all cases these steps are not put in to prevent repairability. Nobody cares about repairability. This is not some romantic fight of the big evil company screwing the little guy out of repairability. Repairability doesn't register on the radar. They don't care. These measures are taken to protect the supply chain against counterfeit parts and counterfeit products because they have a brand to protect. It's as simple as that.

> If I can manage to keep my iPad working as a photo frame for another 40 years, how does that hurt anyone?

It doesn't. I'm not sure why you think I implied it does sorry.

Edits: Spelling and formatting

No problem :) I take the issue with short life products and e-waste very seriously and have given it much thought.

> It sounds messy, but then again I can't help but feel that every single point you mentioned is quite complex because we managed to reach a point in time where a device designed with repairability first, seems such a farcical concept.

I think we are also just at a natural point in technology where it is just hard to repair some of these things. Either we eschew these new technologies completely and loose their benefits to keep repairability, or accept that a lot of it isn't just repairable and we need:

1) Strong laws to protect the consumers investment in devices

2) Properly fund research into e-waste recycling

3) Mandate e-waste recycling and support specialist waste companies to do that.

We're literally counting atoms worth of materials to cut costs, reduce sizes and increase performance.

> We might have become really precise with manufacturing, and produced beautifully thin and solid devices. But the fact that Apple needs to ship a 79-pound/36kg repair kit just to change the battery of a phone, doesn't really demostrate how clueless people are about the repair process, on the contrary it demonstrates the absurd lengths Apple is willing to go just to mock open access to tools, parts and processes.

But this is my point. I don't think Apple was being absurd. This is just want it takes these days and almost all people don't appreciate that a jig like that is what it takes. And it's not even all that complex or expensive compared to jigs I have worked on.

Even many hardware engineers don't have a full grasp. Many these days have never been on a CM floor because a lot of it is abstracted away for them. And/Or they have never really talked to the mechanical engineers making jigs etc. because of internal company siloing.

> Regarding longer warranties, that would be an excellent step, but warranties won't solve the same problems, as they will never cover user caused damage which I'm guessing is the cause for most repairs.

This is a good point and my best idea for that is that, as apart of the warranty, the consumer gets one free/cost at percentage of purchase price (maybe 30%), no questions asked repair/replace for accidental damage. Simple, it's the manufacturers problem and they'll work out that optimum point between: make it more rugged for drops vs not rugged enough for surviving being run over by a car. (We already have standards for drops, water etc. They'll just get made more robust).

> What if we started with the obligation of the manufacturer to provide access to reasonably priced parts along with schematics, without altering their manufacturing process? Would that be an acceptable first step towards making repairs more accessible?

I have a very long, 2 part post, (sorry) to a another commenter which I think addresses this.

Edits: formatting

> Perfect is the enemy of the good. If your phone is a brick and an improper fix makes it useful at a much lower cost than a whole new phone, that's all that matters. Sorry, but your comment just sounds super elitist. Even if only 50% of devices are successfully repaired because they're being done "improperly", that's still a 50% reduction in ewaste.

This is nothing to do with perfect. This is serviced to an acceptable standard. I don't mean to sound elitist, but I make no apology for defending my workers who are like highly trained mechanics that will properly assemble / repair your car. Joe's corner mechanic using cooking oil in your car engine rather than 20-5W is not an acceptable repair IMO. But if cooking oil gets you 50% success in repair and you're happy with that, well all power to you. I don't think most regular people would agree though.

> Then don't. I don't see why the manufacturer should be on the hook to repair a counterfeit.

I should have explained more: These counterfeits in particular (and many of them for modern products) are sooo good WE couldn't tell that they were counterfeit initially. It manifested as a % increase in the number of failures in the field. We thought it was a genuine QA issue and wasted 100s of hours of engineer and QA time and easily tens of thousands of dollars trying to figure this out.

We eventually developed a special jig to tell the difference to deny warranty claims. But issues like this is why manufacturers are and will continue to go hard on protecting their supply chains which normally also means the device is harder to repair especially for an outside party to repair.

Btw, The open documentation of everything for right-to-repair, while laudable, it is something for a fantasy world. Companies will fight tooth and nail to stop that information getting out and the politicians will oblige them. Also, you just gave the counterfeiters the keys to the kingdom for making fakes and fake repair parts. You're not going to "legislate them away" because they're not in the US or any country with decent courts, laws and IP protection.

Closer to home, I am trying to develop my own hardware products. I am a one person team. Now you are going to force me to publish a big chunk of my IP? You've just killed me by counterfeit and giving the keys to the big companies who will squish me. You think I have the money to litigate against a big company? It just means I won't bother. You've just entrenched the big companies even more. Fighting both of these issues requires barriers like lasering off part numbers, spare parts with encryption keys etc. because the problem is THAT big. No it's not a perfect barrier, but just like parking your car in a bad neighbourhood: park next to a better car and have a steering lock so that when the thief comes a long they go for the easier target. It's a stupid cat and mouse game, but it is what it is.

> I disagree 200%. I've repaired countless phones, TVs, computers and other devices for myself and friends and family, all without help of legislation that would ensure the availability of parts and instructions, and the right to repair would only expand this trend. Most people wouldn't do this themselves even with the right to repair, but they are almost certainly within 2 degrees of separation of someone that would.

Again laundable and more power to you but you are super unique and niche. Also I personally don't want your repaired-with-vegetable-oil car engine thank you. Further, you fundamentally cannot repair something for infinite time and the technology for something like a phone moves so fast that that prospect is silly. You are merely delaying the item making it into waste. It's going to end up in landfill eventually. It's MAYBE possible that you will reduce the amount getting in there, which is nice but it doesn't address the fundamental gap in our waste management of e-waste where the ONLY (IMO) proper solution is material recycling to fully close the loop. Yes it will need to subsidised (maybe in an ideal world eventually that won't be needed). But, to me, paying that subsidy is preferable to adding to our debt of biosphere destruction.

Btw, all that stock the manufacturer had to keep for repairing stuff for right-to-repair ... you know where any excess is going when it's not needed AND the accountants can write it off? Straight to landfill. To me, refunding the customer seems preferable.

So again, right-to-repair MIGHT reduce e-waste, it will certainly not eliminate it.

>You're also looking at this very myopically through a specific tech industry lens and ignoring one of the main motivations of the right to repair: super expensive farm equipment. John Deere has a stranglehold on farmers who tend to be very DIY, and this has been driving up their costs and sometimes even driving them out of business because they can't access service or parts at affordable prices, and they can't repair the devices themselves. Breaking this stranglehold would be huge. This is why I caveated my initial post with "won't ever work for something like a consumer phone". Is John Deere one of the main motivations now? That's not what I've observed in media. Maybe that's where it started, but it has grown to encompass many more devices like a mobile phone.

I have many four letter words for John Deere and it is not an industry I have worked in. But again I think a solid, compulsory, no carve outs, warranty would help immensely. Personally I think 25 years is fair for a tractor. Maybe slap in a SLA too like 1 week maximum time to repair. Do that and now you've just made all the issues, with spare part costs, reliability, distribution, inventory, a 3rd party repair network, fabrication by authorised 3rd parties etc. you've made it ALL John Deere's problem. All those managers, lawyers and bean counters will suddenly be driving the engineers and ops people in a direction that (IMO) is fair to the consumer. And don't worry they'll be just fine. They'll rejig those spreadsheets and solve the problem VERY quickly.

They will kick and scream but you've given them very little leeway AND you've given politicians and advocates an easy moral argument: "We think 25 years is fair, especially since there are tractors that are 100+ years old that STILL work just fine."

Edits: Formatting

Please don't misunderstand. I would want something love something like right-to-repair for phones to succeed. I am trying to emphasise that, from an insiders perspective, good warranties are a MUCH better way to achieve most of the same goals.

(apologies in advance for being verbose)

(Please note, I am intentionally using the voice of "the cynical manufacturer", it will sound aggressive, but it is not meant to be aggressive to the poster. I am trying to show how you CANNOT give them even an INCH and right to repair legislation for something like a phone gives too many inches.)

To answer your points:

> "Everything required to replace or repair parts of the device should be fully, clearly and publicly documented, including all discrete part numbers, tools, jigs, etc. Any parts that are manufactured only by the device's manufacturer under patent protection or trade secret must be available for purchase."

No problem:

* Here is a part number: XXX-12345678-FF. It's for a part purchased from a 2nd tier supplier in Taiwan and it's one of a kind. It is now end of life btw so you can't actually purchase it. By the letter of the law, I have met your requirement. Spirit of the law? Well maybe not. Either way, see you in court if you don't like it (and who's going to litigate? the consumer? the government?)

* Did you mean that it should still be purchasable? Well you didn't include that in your legislation but say you do somehow. Now I argue: Don't worry, there's grey market seller in Hong Kong who'll sell them to you for $100 each (original cost was $1 with MOQ 10,000 btw). I have met your requirements.

Still not what you meant I assume? Maybe we legislate: "The manufacturer has to hold enough inventory to supply parts for repairs" Sure ok. Who's paying for keeping this in inventory? Can I on-charge that to the buyer of said spare part? If not, well I guess the phone is going to cost more now because I need to recover that cost. (Bigger warehouses are not free. I also don't keep my own stock, my Contract Manufacturer (CM) in Taiwan does that for me and they'll be charging a fee). Also you didn't specify how long I have to keep this for. I think 1 year + 1 day is fair. Don't like that? See you in court again.

Maybe you now you also legislate "for the reasonable expected life of the product". What's that? I think still it's 1 year + 1 day. See you in court again if you don't like it.

Fine! let's legislate: "... for at least 3 years". Oh I'm sorry, there was an unforseen problem and we went through our inventory-for-repair much faster than expected. There's none left and nobody makes this part anymore. Nobody makes an equivalent either. What now? I hope the customer is entitled to a refund, but (again) you don't have that in your right-to-repair legislation ...

Let's torture this even more: "if for unforseen circumstances manufacturer can no longer supply spare parts, customer will be entitled to a full refund" ...

This sounds awfully like "full repair/replacement warranty of 3 years" but the route you've taken is much more tortured.

> If jigs are required, they must at least fully describe the jig so that people can make their own, if required. Sure thing. Setting aside the fact that jigs can also constitute trade secrets, here is your jig:

* Here is the CAD for the jig you need. We built it for 10k USD because of a bulk discount. Bespoke for you it will probably be 25k USD.

* You also need this air compressor to drive it 2k USD.

* You will need this PXI-e from National Instruments 10k USD.

* That PXI-e needs these two DAQ cards 5k USD each.

* I guess I need to supply the software for that too? For free? Again is that actually fair? What if it has trade secrets? But sure, let's say I have to give it to you for free...

* Well it's NI, you need a license to drive all this stuff and to use the modules we have. 5K USD per year.

So now Joe's Corner Mobile Phone repairs can happily repair your 300 USD phone. He just needs that jig which totals 57k USD BOM and 5K per year on going. But I published it all, he can build it himself. I have met your requirements.

Jigs shouldn't cost that much you say? Well they can and do (and even more). That's the reality. Are you going to ban them? Regulate them too? It's the equivalent of banning / regulating a compiler (ie absolutely absurd).

> You can use glue as long as it can be removed without damaging the device, and the type of glue is documented and available for purchase. I already addressed this in my earlier comment. The easily removable glue is crap. But sure here is the glue part number: GLU-123678-JJ Mfg: GOOD-GLUE-GUYS Btw it's made using a trade secret formula from GOOD-GLUE-GUYS. Do I have to keep it in inventory as well. Or are you going to make GOOD-GLUE-GUYs (who is based outside the US) publish their trade secret formula? We just have the same issue as above. Do I also need to supply to you the special oven for it? Or is the part number enough? (btw that oven weighs 1 ton and is 500k USD, but you got the part number).

> Mandating a level of skill is not necessary. If a repair requires high skill, like desoldering, they can find someone to do that repair, or sell the device to someone willing to do that repair before purchasing a new device. The level of skill required to repair a device will become known, although I'm also not opposed to requiring that be declared up front. If you don't mandate skill requirements, then a manufacturer will just happily NOT make ANY adjustments to make a thing "more-repairable" whatever that means. Example that meets your legislative requirements:

You need to swap the CPU it's a 0.1mm pitch 2048 ball BGA. Here's the part number. Please note: this is a stacked design where the RAM chip (also 2048 balls) is soldered ON TOP of the physical CPU. The practical reality is that few humans on Earth, with very expensive equipment can do this. Joe's Corner Mobile Repairs is not one of them. The reality in manufacturing is that this faulty board would be binned because cost+time+risk means it's not worth it. If it was mega expensive then a fix maybe attempted, either using a very highly skilled technician and an xray afterwards to verify OR the tech removes the part and you run it through the 1-10million USD SMT line with a special program and IF you are very confident in your process engineering you might decide you don't need to xray it. All that said, I have met your requirements as stated in your proposed legislation, but it is of no practical use to you. Perhaps we just swap the whole motherboard? Well you didn't legislate that. Say you do somehow (skill requirements perhaps?), now it's 50% of the cost of a new device because the reality is that that's where most of the cost is. Put on top of that labour at a FAIR price to Joe in his corner repair store in the US and it's just not worth it now. A consumer will just buy a new device (without being compensated by the manufacturer).

Edits: Formatting

hnaccount_rng has already raised good points. I will add to them:

1) Working in product compliance I have learned: The simpler the rules, the harder it is to avoid them/weasel them. "Right to repair" rules will ALWAYS be more complicated than a simple "good" warranty. You are essentially legislating how to design products which has an infinite solution space. AND what do you legislate? "It has to be repairable". What is that?

- What skill level of the technician is required? What is the maximum time that they are allowed to spend to deem it "repairable"? (given enough time and skill you can repair almost anything). How we do verify that? Do they need a certification now? Who sets the requirements for that? Who does the testing? Or should the consumer be able to fix it? What tools are allowed or not allowed? Are custom tools allowed? Do I now have to manufacture them and sell those? (cause we use lots of bespoke tools). Now I have to inventory those items, that's going to cost.

- Are mechanical jigs (which are ubiquitous and very expensive and normally bespoke for manufacturing or repairs) allowed? How complicated can they be? Say they are allowed, how does the technician use it? Do I now have to manufacturer it and make is saleable? How much can it cost? (they can easily cost tens of thousands). Can I just lend said jig? For how long? Who insures it when it is in transit? How many jigs must I have in circulation at any time so that repairs are conducted fast enough?

- Can I not use glue anymore? Or only certain types? Say you legislate types that are easy to remove or desolve, ok well their mechanical properties suck and the device will be crappier now.

- How long does this need to be repairable? The reality these days is that a lot of PCBs are cheaper and/or easier to just scrap and replace ... so do I now have to keep repair stock? How much? For how long? What if I run out? Am I now obligated to spin up a 1 million dollar production line to make a few very uneconomic spares?

I could go on ALL day. How do you legislate all of that? Cause the parts that don't now have to go through the courts. Now it's just a big steaming mess that doesn't work AND it's complicated AND you have many smart engineers, who just want to get paid and go home and smart lawyers to circumvent it.

2) I know this might be very unpopular to say on HN, but the reality is that MOST (not all) of what companies do that makes things "unrepairable" is mainly because it's a) cheaper or b) securing the supply chain against counterfeiters because counterfeits devalue your brand and also you don't want to be on the hook for repairing really good counterfeits (and I have personally experienced the latter).

3) The "good warranty" solution is utilising an internal manufacturer calculus that already exists. Right now it is "tuned" to if US market => it only has to last a year + 1 day. Then "not our problem". In a "hand wavy based on experienced way" it's easier to get change by just shifting the goal posts (longer warranty).

4) I applaud you on fixing the items yourself but while it was fine for you, the quality probably wouldn't have passed on my production line. I have also observed many of those little phone repair shops do work and every single one I would have booted off my line. I am yet to see a single one of them use proper ESD protection (in any modern factory you are not even allowed inside without ESD gear). Sure they fixed it for you, but some other customers phone is now a walking wounded. I guarantee it.

I found this article very illustrative about just how clueless, many people, even "right to repair" proponents are about the systems that they are trying to regulate: https://www.theverge.com/2022/5/21/23079058/apple-self-servi... Yes, that jig Apple supplied, that's what it takes these days. Modern production and repair lines are soooo tuned for efficiency it's insane. That tuning introduces complexity which then goes through the roof for repairing stuff outside of said line. It's why often it's cheaper and quicker to throw parts out and replace it. We've gotten THAT good.

Finally, I actually think it is actually rather insulting how many people believe that fixing something like a phone PROPERLY is "not that hard" and "any tech can do it". I see these comments as demeaning and insulting to the experienced people working on these production and repair lines who are often underpaid and treated very poorly.

5) Right to repair will not solve e-waste. My opinion is it won't make much of a dent. E-waste is a separate issue that absolutely also needs to be tackled by compulsory recycling. And actually, in the case of phones and many other consumer electronics, making them "repairable" can mean more resources being used. People (especially on HN) bemoan glue being used. Modern glues are great. They're used because they speed up assembly, are fairly easy to apply and make stuff thinner and mechanically simpler. Say you ban glue as a part of Right to repair legislation, I guarantee the screws and extra plastic you need instead use more material and have more embodied energy. You've actually now increased the amount of e-waste.

Finally, I think fundamentally, rather than being repairable, I think most people just want these devices to last longer (so again just force that through long warranties). And it can be done. I have personally worked on products with a 10 year "official" warranty and a "quiet internal" 20 year one. It wasn't an exotic product or industry either. In my opinion, repairing a thing is the ambulance at the bottom of the hill, it should not have broken in the first place. Why mandate the ambulance in all cases when you can mandate the minimisation of pushing stuff off the cliff instead?

Right to repair is a nice idea and it's heart is in the right place, but won't ever work for something like a consumer phone. Further, IMO, it's really just a band aid for the US's extremely poor consumer protections which manufacturers are hell bent on exporting to the rest of the world.

The most effective way to approach this problem is known and proven: mandate long (I think 5 years is fair) 100% repair/replace/refund waranty periods with no cost to the consumer (including shipping).

Then the manufacturer themselves will figure out the details on how to meet that. And don't worry they are perfectly capable of it because it's what they do RIGHT NOW.

The hardware will become more reliable or it'll be repairable or they'll just refund you or a combination of those.

Batteries just need a requirement such as minimum 80% of capacity at 5 years. Overnight they'll become replacable/over-provisioned/better chemistry/better thermals or again a combination of those.

I've never had "repairability" raised to me as an engineer. It's a nebulous thing nobody understands or cares about and can be just paid lip service to or effectively ignored. But waranty IS something bean-counters and managers understand. It's: "this thing must work for X time or it costs us money" with the added threat of "lawyers might get involved".

It's not perfect, but still far more effective and practical than "right to repair".

I really wish it were possible to calculate the total destruction of human productivity caused by whitespace and "progressive disclosure".

The writing was on the wall for years. The difference is that Poland started constructing an alternative pipeline to Norway. Poland also appealed to an arbitration panel to have the Russian gas contract right to renewal clause removed (which it was successful in doing).

Germany meanwhile doubled down on Russian gas and built Nordstream 1 & 2.

It might net neutral or net benefit. Now the lack of maintenance and underinvestment is visible, but you're taking strain off the (mostly invisible and no doubt underinvested in) storm water system by swapping impermeable surfaces for permeable ones. (This is a good way to save money on storm water systems in general).

That said, my cynical side would still somehow expect my local council to screw it up anyway.

But it was for a cup of coffee which probably will be extinct as well so jokes on them...

I don't mean to merely imply that only charging up to 80% charge is (essentially) irrelevant. I mean to state that it is.

What actually happens at around 80% is that the charging regime changes. It's nothing to do with "making the battery age less". A lithium battery has two charging regimes: Constant Current and Constant Voltage. Up to about 80% a lithium battery is charged with constant current => charge speed is limited by the maximum output current of the charger => bigger charger faster charger speed => happy customer.

Above ~80% you switch to Constant Voltage. Charger now charges at a constant voltage and the charge current drops off following a log curve. The closer you get to 100% the lower the current => battery charges slower and slower the closer you get to 100%. This is a simple matter of physics and is the antithesis to "Fast Charging" which is why fast charging always talks about charging up to 80%.

"but the things you mention PLUS the discharge depth or how full you charge also affect the equation from what I gather."

Yes, depth of discharge (DoD) does affect battery ageing. But there's also a dozen other factors as well. Some affect the battery life more than DoD.

So yeah don't waste your life trying to compile custom kernels or whatever to only charge to 80% :) Just help the battery keep cool with what I posted earlier. It's all you can do. Worry about other things in life :)

And now it's appearing on HN seemingly once a week. What has changed? Is someone running an information(or disinformation) campaign? Blog or app to promote?

I've not spoken earlier for fear of being downvoted into oblivion: I am sorry to say, but this 80% nonsense is just ... terrible advice and is 90% wrong. Like "skipping a daily coffee will let you retire 10 years sooner" wrong. (And all these lovely graphs I see thrown around are from poorly setup and poorly controlled tests using small samples or maybe even they're faked idk).

To be horribly simplistic about it, the biggest factor in battery ageing is thermals. So if you want actionable advice on increasing the longevity of your battery (in the mobile phone context):

Don't let it get hot, which means things like:

* Take off that awful plastic insulator you call a phone case. (But we need phone cases)

* Charge it slowly. Lower charge rate = less heat = happier battery. (But people love charging their phone in 1 minute)

* Charge at human ambient temperature. (But on my bed, in the sun is easier)

I guess those are inconvenient and poor sound bites. I'm sorry, but consumer devices (especially phones) have poor thermals and the environment they're subjected to sucks. That's just a fact of life (and economics and physics).

Very simplistically, the only way "charge to 80% only" *might* be helping you is by keeping the battery cooler (In which case the above advice is much better).

It's an extroverts world and we're all forced to conform to the "extroverts narrative".

When all the extroverts were losing their minds because of COVID induced forced WFH, I frankly had no sympathy (and even a little sadistically felt a little glee). Didn't like your work environment for just one or two years? Cry me a river little extrovert and try it for a whole life time.