The Federal Trade Commission has pursued right-to-repair enforcement through warning letters, a landmark antitrust lawsuit, and a 2021 staff report to Congress, yet formal rulemaking has stalled, and the agency’s direction shifted sharply after the change in administration in January 2025. Statutory authority rests on FTC Act Section 5 and the Magnuson-Moss Warranty Act (15 U.S.C. § 2301). The most consequential action to date is the January 2025 federal complaint against Deere & Company, which remains active in the U.S. District Court for the Northern District of Illinois.
Nixing the Fix: The 2021 Staff Report to Congress
In May 2021, the FTC released Nixing the Fix: An FTC Report to Congress on Repair Restrictions, the agency’s first comprehensive survey of manufacturer practices that limit independent and self-repair. The report catalogued seven categories of restriction: parts pairing through software locks, parts serialization, tying warranty coverage to manufacturer-only service, withholding diagnostic tools and technical documentation, refusal to sell spare parts, physical design choices that complicate disassembly, and exclusive dealing with authorized service networks.
The report found no empirical evidence that independent repair increases safety risk to consumers, a direct rebuke to the primary industry justification. It documented harms to consumers and small repair businesses, citing inflated repair costs and shortened product lifespans. Agricultural equipment, mobile devices, and medical devices received particular attention as sectors with severe restriction practices.
One month after publication, President Biden signed Executive Order 14036 on July 9, 2021, directing the FTC to “limit powerful equipment manufacturers from restricting people’s ability to use independent repair shops.” The Commission voted 5-0 to prioritize right-to-repair enforcement and adopt a policy statement pledging stepped-up use of FTC Act Section 5 against unfair or anticompetitive repair restrictions. That unanimity would not last.
The FTC’s July 2021 policy statement identified five enforcement priorities: warranty tying, parts and tools lockdown, software-based locks, data access restrictions, and safety and security justifications used pretextually. The statement signaled that the Commission viewed existing statutory authority as sufficient, formal rulemaking was described as one option among several, not an immediate priority.
Magnuson-Moss Warning Letters: 2022 and 2024 Rounds
The Magnuson-Moss Warranty Act prohibits warrantors from conditioning warranty coverage on the consumer’s use of manufacturer-specified parts or service providers, unless those parts or services are provided free of charge or the FTC grants a waiver. In 2022, the FTC sent warning letters to 50 companies citing potential MMWA violations, the largest such enforcement sweep in the statute’s history.
A second round followed in July 2024. FTC staff sent letters to eight companies, air purifier manufacturers aeris Health, Blueair, Medify Air, and Oransi; treadmill company InMovement; and gaming hardware firms ASRock, Zotac, and Gigabyte. Five companies received warnings about statements that consumers must use specified parts or service providers to maintain warranty coverage. Three received warnings for placing “warranty void if removed” stickers in locations that obstruct routine maintenance access, a practice the FTC has characterized as per se deceptive under the MMWA.
The July 2024 letters specified a 30-day compliance window before FTC staff would review company websites again. Failure to correct identified violations was stated as potentially triggering formal law enforcement action. No formal complaints against these eight companies had been filed as of mid-2025. The warning-letter approach reflects a deterrence strategy rather than adjudicated enforcement, critics including PIRG and iFixit have argued the agency needs to move beyond letters to demonstrate real consequences.
For the broader landscape of state-level statutes building on this federal framework, see the right-to-repair laws U.S. tracker.
FTC v. Deere & Company: The First Major Antitrust Action
On January 15, 2025: five days before the presidential transition, the FTC, the state of Minnesota, and the state of Illinois filed a federal antitrust complaint against Deere & Company in the U.S. District Court for the Northern District of Illinois (Case No. 3:25-cv-50017). Michigan, Wisconsin, and Arizona subsequently joined. The complaint alleged violations of Section 2 of the Sherman Act, Section 5 of the FTC Act, and five state antitrust statutes.
The core allegation centers on Deere’s diagnostic and calibration software, Service ADVISOR. The complaint asserts that the fully functional version of Service ADVISOR is available only to Deere’s authorized dealer network, while the version sold to farmers and independent repair facilities is technically crippled, lacking calibration routines, error-code resolution, and controller updates that authorized dealers can access. The FTC characterized this as maintenance of a repair services monopoly through technological lock-in rather than product superiority.
The Commission voted 3-2 to file the complaint, with Republican Commissioners Melissa Holyoak and Andrew Ferguson dissenting. Ferguson, who now chairs the FTC under the Trump administration: argued in his dissent that litigation was premature given ongoing negotiations between federal agencies and Deere. His January 2023 Memorandum of Understanding with the American Farm Bureau Federation, in which Deere committed to expanding repair access, had not produced the diagnostic tool parity the FTC ultimately demanded.
As of mid-2025, the lawsuit has not been dropped or dismissed. Ferguson cannot unilaterally withdraw the case without a majority vote of commissioners. The states’ participation provides an independent litigation track that would survive any federal withdrawal. The case represents the first time the FTC has brought a formal antitrust complaint specifically targeting repair restrictions, a significant doctrinal step regardless of its ultimate outcome.
Apple, Parts Pairing, and the Limits of Voluntary Action
Apple occupies a distinct position in the FTC’s right-to-repair record: the subject of extensive staff scrutiny but no formal enforcement action. The Nixing the Fix report cited parts pairing, the software-based serialization that links specific components to a specific device’s logic board, as a primary mechanism through which Apple controlled repair access. Replacing an iPhone screen or camera module with a genuine Apple component obtained from a third-party source triggered persistent “non-genuine part” warnings in iOS Settings, degrading functionality even when the hardware was identical.
In November 2021, Apple launched its Self Repair Program, allowing consumers to purchase genuine parts and tools for select iPhone models. The program initially covered iPhone 12 and 13 series displays, batteries, and cameras. Critics, including iFixit and U.S. PIRG, noted that parts still required software activation through Apple’s system: effectively preserving the pairing requirement in a new form.
Apple announced in April 2024 that it would permit repairs using used genuine parts, beginning with select iPhone models in the fall. The policy change acknowledged that iPhone components harvested from donor devices could be activated without triggering non-genuine warnings. Oregon’s right-to-repair law, signed in 2023 and effective January 2025 for smartphones, explicitly prohibits parts pairing that causes devices to display misleading alerts, the first state to codify this prohibition. Colorado followed with similar legislation in May 2024.
The FTC has not filed a complaint against Apple. The agency’s 2024 warning letters to gaming hardware manufacturers, firms with far less market power than Apple, illustrate the gap between the agency’s rhetoric on parts pairing and its enforcement record against the largest consumer electronics manufacturers. The FTC’s broader consumer protection authority under Section 5 of the FTC Act connects directly to data access and digital rights issues; for context on how the agency approaches consumer data in adjacent markets, see the ADPPA and U.S. data privacy law guide.
Rulemaking Status and the Post-2025 Regulatory Environment
Formal FTC rulemaking on right-to-repair: anticipated by the 2021 policy statement, has not materialized. The Magnuson-Moss Warranty Act grants the FTC rulemaking authority to define unfair warranty practices, and the FTC Act’s Section 18 rulemaking process provides a second avenue. Neither has been invoked to produce binding right-to-repair regulations at the federal level.
Under Chair Lina Khan (2021–2025), the FTC pursued enforcement through warning letters, the Deere complaint, and policy statements while exploring but not completing a formal rulemaking proceeding. The transition to Chair Andrew Ferguson in January 2025 brought a declared shift in enforcement priorities. Ferguson had dissented from the Deere complaint and has publicly indicated the Trump-era FTC will focus on what he characterizes as government overreach and ideological enforcement rather than expanding manufacturer liability for repair restrictions.
The practical result is a federal enforcement gap. The Deere litigation continues, carried in part by state attorneys general. Warning letters have produced no public follow-on complaints. No MMWA rulemaking docket is active. Industry observers at PIRG and iFixit note that the locus of right-to-repair policy has effectively shifted to the states, with at least 19 states having enacted some form of right-to-repair statute as of early 2025, and to antitrust enforcement in courts rather than agency rulemaking. Whether the FTC under its current leadership will maintain, settle, or seek to withdraw from the Deere litigation will serve as the clearest near-term indicator of federal enforcement trajectory.