Beginning early this year, several developments under the second Trump administration have affected the right to repair for digital electronic devices by both independent repair shops and individual consumers. These changes have already had an impact by offering consumers more choices regarding their digital electronic devices while simultaneously making repairs harder to access and afford.
Policy and Regulatory Changes
Several policy and regulatory changes affect consumers’ ability to repair their own devices. These include the new Executive Order on digital assets, increased tariffs on China-sourced goods, the suspension of programs to promote electric vehicles, and the reversal of recently-increased standards for light bulb and appliance energy efficiency.
On January 23, 2025, President Trump signed Executive Order 14178, titled “Strengthening American Leadership in Digital Financial Technology,” revoking the previous Executive Order 14067 which focused on responsible development of digital assets. New EO 14178 is aimed at fostering innovation and reinforcing the U.S.’s position on digital finance to support a more combined and centralized governance of the economy. This new regulatory framework is intended to balance advancements in the digital asset economy with consumer protections and financial stability. This EO may also influence subsequent policies related to digital electronic device repair because it implies changes to regulations governing original equipment manufacturers’ responsibilities to provide repair parts, tools, and documentation to individuals and independent repair shops as well as attenuate consumers’ rights to repair their own devices.
The Trump administration’s newly-imposed tariffs on imports from China will apply to many consumer electronics. Effective from February 4, 2025, a 10% tariff was imposed on imports from China. On March 3, 2025, President Trump signed an executive order raising the additional tariff rate from 10% to 20% on certain Chinese products. This increase became effective on March 4, 2025, and applies broadly to all products imported from China, including consumer electronics, machinery, textiles, and manufactured items. Thus, the ability of individuals and independent repair shops to procure repair parts, tools, and replacement components to repair their own consumer devices is likely to become more difficult because of the tariff-related increased costs expected to be passed on to consumers. Individuals and independent repair shops will also likely face challenges with less access to necessary repair parts, tools, and replacement components.
On February 6, 2025, the Trump administration suspended the National Electric Vehicle (EV) Infrastructure Program (NEVI Program) as part of the administration’s efforts to reassess and potentially eliminate federal support for EV infrastructure and incentives. The NEVI Program is a $5 billion program aimed at expanding EV charging stations, and is intended to fund the construction and maintenance of EV charging stations across the U.S. Suspension of the NEVI Program will limit access to EV charging facilities and slow the adoption of repair-friendly technologies in the automotive sector as well as the use of parts and tools used for the maintenance and repair of these EV charging stations.
On February 11, 2025, the administration announced the reversal of previously enacted energy efficiency standards affecting incandescent light bulbs and water-using appliances. The announced basis for this reversal was to reduce regulatory burdens for manufacturers and consumers while allowing the continued sale of incandescent light bulbs and permitting higher water flow in certain appliance fixtures. This rollback will likely affect the availability of repair information and components for the affected light systems and appliances and hinder consumers’ ability to repair them. Many consumers have already transitioned into owning and installing the more efficient lights and appliances in their homes, and this regulatory change will limit the accessibility of necessary repair and maintenance parts and tools.
Trade Policies and Additional Resulting Tariffs
The relationship between Trump’s newly-announced trade policies and tariffs is complex because higher costs for electronic devices overall may encourage repair efforts by individuals and independent repair shops, but the higher prices may also deter them.
The amount and target of the tariffs is also changing quickly. The initial additional 10% tariff levied on Chinese imports was meant to address concerns related to intellectual property theft, transfers of technology, and some other trade imbalances. When this tariff was raised to 20%, effective March 4, 2025, the cost for consumer electronics noticeably increased, including components for digital electronic devices and their replacement parts.
Then, on February 10, 2025, President Trump imposed 25%-100% tariffs on certain semiconductor imports, implemented on March 12, 2025. These semiconductor tariffs specifically target imports from Taiwan. Semiconductors are essential components in digital electronic devices, including tools and parts used in repair, performing a crucial role in the functioning of electronic systems, including computers, smartphones, tablets, and other digital devices. This targeted tariff on semiconductors will have a significant impact on individuals and independent repair shops due to the necessity of semiconductor components for the functional use of digital electronic devices and their corresponding increased costs for importing necessary repair parts.
Most recently, as of early March 2025, the Trump administration substantially expanded Section 232 tariffs. Section 232 tariffs may be imposed or adjusted by the president if certain imported products are determined to threaten national security by weakening important domestic industries. On February 10, 2025, President Trump issued proclamations modifying existing Section 232 tariffs on steel and aluminum imports, which are both key materials that are often used in digital electronic devices, effective March 12, 2025. Specifically, the modifications to Section 232 tariffs include the reinstatement (from the first Trump administration) of a 25% tariff on all steel imports from China, Canada, Mexico, and members of the European Union. Further, the modifications to Section 232 tariffs include an increase on the 10% tariff on aluminum imports (originally imposed under the first Trump administration and kept in place under the Biden administration) to a 25% tariff. Typically, steel is used in the structural components and internal parts of digital electronic devices for strength and durability, and aluminum is commonly used in outer casings, housings, and heat sinks for thermal conductivity in keeping digital electronic devices cool due to its lightweight and heat-dissipating properties. So, these tariffs are sure to affect the ability of individuals and independent repair shops to afford the components required to repair digital electronic devices.
Environmental and Recycling Policies
Environmental policies promulgated by the current Trump administration primarily focus on deregulation and the promotion of fossil fuel development, both of which can indirectly influence the availability and cost of electronics repair resources and affect consumers’ ability to repair digital electronic devices. Although these policy changes are not directly targeting digital electronic repair and recycling, their indirect effects can dramatically alter the environmental landscape in which repair and replacement activities occur. For example, these policy changes are likely to discourage electronic waste (e-waste) recycling as a more affordable and accessible means for consumers to repair their own digital electronic devices.
As of March 17, 2025, the Trump administration has implemented several policies affecting e-waste and recycling regulations, including those relating to restrictions on single-use plastics. Tariffs aimed to protect domestic industries simultaneously have led to increased costs for recycling facilities, particularly for machinery components and materials. This consequently increases costs for businesses and manufacturers looking to dispose of e-waste as well as individuals and independent repair shops who similarly may be disposing of their own e-waste from digital electronic devices and looking for a return or trade-in value for such disposal.
As a result, some foreign companies are seizing their opportunity to profit from and alleviate potential increases in undisposed and unrecycled e-waste in the U.S. as domestic policies leave such industries underdeveloped. With fewer initiatives and programs aimed at resolving e-waste challenges and more e-waste and related issues entering the recycling stream, it is likely that the cost of recycling old and outdated digital electronic devices as e-waste will increase, discouraging consumers from making such efforts, and the cost of obtaining recycled repair parts and digital electronic devices will increase, hindering the ability of individuals and independent repair shops to repair their own consumer devices.
As manufacturers’ control over repair information and parts may change so too will consumers’ ability to repair their own digital electronic devices independently. While it remains possible that a reduction in regulations could lead to more consumer devices becoming available in circulation and offering consumers more choices, it also remains possible that the increase in tariffs could lead to consumer devices, replacement parts, and repair equipment becoming more expensive and inaccessible. Undoubtedly, as new policy and regulatory changes continue to develop, the right to repair landscape will continue to evolve.
This article was written by Jennifer L. Frank (212-238-8650, frank@clm.com), Matthew D. Dunn (212-238-8706, mdunn@clm.com), and John M. Griem, Jr. (212-238-8659, griem@clm.com) of Carter Ledyard & Milburn LLP.
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