CDT Letter to California Assembly Supporting Connected Consumer Product End-of-Life Disclosure Bill
CDT submitted a letter to the California Assembly Privacy and Consumer Protection Committee in support of SB 898, legislation to ensure that consumers will have a reliable guarantee that products they purchase that depend for their functioning on software connection to the internet will have a reasonable useful life before the manufacturer abandons them. The bill is based on a Model Act that Consumer Reports developed with the assistance of CDT.
In its letter, CDT recommends making two changes to the bill in line with the approach taken in the Model Act, to make it more workable for manufacturers and consumers alike —
(1) Giving a specified end date for guaranteed support, not a number of years tied to the date of purchase, and requiring that the period be not a specified number of years, but a more flexible period that is “not inconsistent with reasonable consumer expectations” for the particular product.
(2) Specifying that the notice that the product’s end of life is approaching or has arrived be given in three ways, to the extent feasible for the manufacturer: through an interface on the product or an associated application, if practicable; through email to owners of the product for whom the manufacturer possesses an email address; and on the product webpage.
