Right To Repair Bill NZ

It will probably come as no surprise that Need A Part supports the proposed Right to Repair bill. Here is the submission we made back in April:


Submission on the Consumer Guarantees (Right to Repair) Amendment Bill

Introduction

Thank you for the opportunity to make a submission on the Consumer Guarantees (Right to Repair) Amendment Bill (the Bill). This submission is from Andy Abel, on behalf of Need A Part Limited.

Need A Part was founded in 2009, with a goal of making appliance spare parts more accessible to consumers. At the time, spare parts were typically only available through authorised repair agents. However, it was often not cost effective for repair agents to source individual spare parts, and was a distraction from their primary job of fixing appliances.

Following in the footsteps of some overseas companies, Jared Tasker and Andy Abel launched an online store which stocked common parts for household appliances, and made it easy to source other parts on request. The website was targeted at consumers who didn’t need a service technician to diagnose an issue; they just needed a part to fix things themselves (as is often the Kiwi way).

Need A Part is still a self-sustaining business more than 15 years later, and now sees competition in the market from at least 4 other online parts retailers. This is not only testament to the demand for appliance spare parts in New Zealand, but proof that it is possible to provide such a service.

General comments on the Bill

Need A Part strongly supports the Bill, and recommends that it move through Parliament and become legislation. 

Kiwis want access to spare parts

There is clear demand for access to appliance spare parts, as evidenced by many of Need A Part’s public reviews on Google:

  • “I no longer had to buy a new food processor.”

  • “Saved me $100s of dollars to replace with a new unit.”

  • “So pleased to get replacement bowl for my 45 year old Kenwood mixer”

  • “Great for the environment, for we did not have to throw out an otherwise good appliance and buy a new one.”

  • “More people need to use this instead of putting things into landfill thinking they can not be fixed or able to purchase a part to keep something going.”

  • “We didn't need to throw the machine and get a new one”

A clear theme from these comments is that the ability to repair appliances leads to a significant reduction in waste.

Conversely, when spare parts are not available, customer feedback usually confirms that their appliances are now destined for landfill:

  • “That's a shame because now it will become landfill. Thanks for checking.”

  • “So do I have to throw the whole food processor in the landfill? Nothing can be done? I don’t know much about these things but just seems such a big waste.”

  • “That’s disappointing. So it basically is set for landfill now.”

Need A Part can only supply parts that the manufacturers make available. One recent piece of customer feedback highlights the fact that some manufacturers make spare parts obsolete even while the appliances are still on sale:

“I don’t understand this. This model is currently being sold, so how can parts be "no longer available"?  It seems like [manufacturer] has never supplied parts for this product. If this is the case, I will not be buying another [manufacturer] product again – and I’d be pleased if you could feed that back to [manufacturer]. I’m disgusted that an otherwise functional product is now going to landfill simply because one little (and poorly designed) plastic part cannot be supplied.”

Strengthening the economy

While Need A Part is not in the business of repairs, we are well aware that the industry is in decline. Many of our customers need to be referred to service agents, and over the last 15 years we have observed a sharp decrease in the number of technicians available for referral. Check any appliance manufacturer’s website for service agents, and you will find a dearth of options outside of main centres. One prominent brand lists no repair agents north of Takapuna, or south of Blenheim.

It is our firm belief that “right to repair” legislation will revitalise the repair industry, creating jobs and strengthening the local economy.

Supplying spare parts needn’t be burdensome

A criticism of the Bill is that forcing manufacturers to supply parts and information to consumers is burdensome and costly. However, this is contrary to Need A Part’s experience.

Many brands – such as Breville, Bosch and Shark – already sell spare parts direct to consumers online, proving that it is very much possible.

Other brands – such as LG, Sony and Sunbeam – do not sell parts directly, but refer customers to Need A Part as their official spare parts supplier.

It is true that for organisations primarily set up for “Business to Business” operations, it can be difficult to handle “Business to Consumer” transactions (think invoicing a small number of businesses on monthly accounts, compared to operating a website and taking credit card payments from hundreds of consumers). However, the Bill allows the distribution of parts and the dissemination of repair information to be outsourced to third parties.

As previously mentioned, Need A Part is just one of several players in the spare parts industry, so manufacturers have a variety of options should they not wish to handle the sale of spare parts themselves.

Finally, it should be noted that most appliance brands operating in New Zealand are global companies, and already have “right to repair” obligations in other territories. If spare parts and information are already being produced to satisfy legislation in Europe, then there is no logical reason why they can’t extend the supply to New Zealand. As an example, Need A Part has been working with Sony to develop a “self repair” section on their NZ website, which in part replicates information already available on their other regional websites.

Specific comments on the Bill

The scope of goods covered by this Bill may be too broad, inadvertently covering items that are not repairable. Consider an explicit list of goods to be covered, under categories such as “large household appliances”, “consumer electronics”...etc.

Section 12 allows manufacturers to locate repair facilities offshore, which is likely to discourage consumers from pursuing repairs. Consider requiring manufacturers to provide repair service and access to spare parts in New Zealand (which could include contracting to third parties).

Section 12 places the burden on the consumer to request information and spare parts from the manufacturer. This is an unnecessary obstacle, especially in an age where it is trivial to publish information online. Consider compelling manufacturers to pro-actively publish relevant information, and remove the 20 working day response time.

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