Thank you so much. It's a pleasure to see that we have our own kind of repair-related beginning to all this.
Thank you very much, Mr. Chair and members of the committee, for inviting me to appear on behalf of the Canadian Repair Coalition or CanRepair.
I'd like to start by saying that CanRepair supports Bill C-267. However, that support is on the basis that we see this as a constructive first step toward a more comprehensive national and federally led approach to the right to repair.
We've provided a written brief with five recommendations for strengthening the legislation. For now, I'd like to focus on three primary considerations from the right to repair advocacy perspective.
The first is that repairability is not simply a characteristic of how a product is designed. It's also a characteristic of the systems and markets that support the product or device throughout its useful life. A product can be designed to be durable, but it can become practically unrepairable when its manufacturer restricts access to replacement parts, diagnostic information, software or the tools necessary to maintain it. We would encourage the committee to make the repair ecosystem—and that includes independent and third party repairers—a more explicit focus of the national framework.
In particular, clause 3 should direct the framework to consider the practical ability of independent repair providers to access the resources necessary to perform repairs, including on fair and commercially reasonable terms. We also call for broader consultation with the people and the businesses who actually perform repairs, rather than limiting mandatory consultation to provincial consumer protection representatives.
Second, we believe that the right to repair is increasingly a matter of national economic resilience and technological sovereignty. In its submission, the Electronic Products Association Canada points out that Canada is overwhelmingly an “importing nation” when it comes to electronic products. As much as we may import many of these products and devices, repair is always local, and repair is always Canadian.
Canadians should have the technical capacity and resources necessary to maintain the technologies on which they depend. We would encourage the committee to build on the domestic resilience aspects of this bill by expanding its practical scope to additional product and device categories—such as the automotive sector, the agricultural equipment sector and other sectors—and requiring the framework to assess the availability of domestic repair and maintenance capacity for these products and high-value goods.
Third, CanRepair rejects the argument made by manufacturer industry groups that repairability, safety, IP protection and cybersecurity are all necessarily competing objectives. We shouldn't confuse protecting genuinely sensitive information with the monopolization of manufacturers' exclusive control over repair through abusive IP or other strategies. The common industry argument here is that consumers are safer the less they know about how products are designed. That stands on very questionable foundations.
Let me be clear: Nobody is calling for unsafe, insecure or infringing repairs. For that matter, repair restrictions can themselves create security and safety risks when products can no longer be diagnosed, maintained or updated properly. We're calling for the standards contemplated in the bill to balance repair access with safeguards that are evidence-based rather than fearmongering.
I'd like to close by calling upon the Government of Canada to renew its prior commitment to taking on a leadership role on the right to repair policy nationally. While no doubt a step forward, this bill is, after all, a framework bill that does not in itself create enforceable repair rights. As you know, Canada has already taken important steps through Bill C-59, Bill C-244 and Bill C-294, but these reforms have only addressed parts of the problem.
Currently, a disjointed patchwork of provincial legislation needs focused coordination and standardization for consumers, repairers and manufacturers alike. Our hope is that Bill C-267 becomes the beginning of renewed federal leadership on this file.
Thank you very much for your time. I look forward to your questions.