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 and reuse without the consumer safety, security, or business concerns raised by insecure repair mandates. Similarly, in a joint comment submitted to the Commission, several organizations representing manufacturers argued that member organizations ensure that repairs are conducted to manufacturer requirements and thus maximize products’ useful life and “contribute significantly to e-waste reduction by returning products to service, thereby diverting products from end-of-life management.”

Regardless of whether the total amount of e-waste is on the rise or decline, extending the life of consumer products unquestionably delays these products’ entry into the waste stream and reduces the amount of energy used to generate replacement products. A study conducted by the European Environmental Bureau found that a 1-year lifetime extension of all smartphones in the EU would prevent the release of 2.1 million metric tons of carbon dioxide per year by 2030, the equivalent of taking more than a million cars off the roads for a year. And extending the lifetime of all washing machines, notebooks, vacuum cleaners, and smartphones in the EU by just one year would reduce around 4 million metric tons of carbon dioxide annually by 2030, the equivalent of taking more than 2 million cars off the roads for a year. Additionally, the EPA encourages improved life cycle management of electronics, through “source reduction of materials used, increasing reuse, refurbishing, extending the life of products, and recycling of electronics,” to reduce the total quantity of domestic and global waste. And, EPA encourages manufacturers to create products for longevity, durability, reusability and recyclability. The EPA also recommends that consumers do their part to prevent waste by recycling, donating functional, used electronics for reuse, and buying products with environmental concerns in mind. Increasing repair options for consumers is harmonious with the responsibilities identified by the EPA (longer-living devices, giving consumers more ability to maintain those devices, and allowing for educated consumer purchases) and is likely to further decrease the production of e-waste. D.Small Businesses and Employment Right to repair advocates argue that repair restrictions negatively impact not only consumers, but independent repair shops and the individuals those shops employ, by limiting the