South Africa Takes Aim at Parts Pairing, and the Repair Wars Go Global

On October 9, South Africa's Competition Commission finalized its Guidelines on Repair, Service and Maintenance Aftermarkets, issuing a formal warning to manufacturers of smartphones, home appliances, and consumer electronics: restricting independent repairers could violate the country's Competition Act. It is South Africa's first formal framework addressing right to repair in consumer electronics, and it puts one practice squarely in the crosshairs. The practice is parts pairing, the software trick that ties a replacement component to a specific device serial number.

The timing matters. Right to repair has spent a decade winning legislative battles. Now the fight is moving to enforcement: what manufacturers are actually allowed to do inside the devices they already sell.

What the guidelines actually do

The guidelines cover a broad sweep of consumer technology: mobile phones, tablets, gaming consoles, televisions, household appliances, medical devices, and backup power and water systems. Motor vehicles are excluded, but only because they already sit under dedicated automotive aftermarket guidelines the commission introduced in 2021.

The central target is explicit. Software that prevents a replacement part from functioning without manufacturer activation, or that throws warning messages after an independent repair, will be treated as an indirect restriction on spare parts access. The commission said such practices will be prioritized for investigation and enforcement. It carved out narrow exceptions for components tied directly to device security or safety, such as anti-theft mechanisms, authentication systems, and battery management. Even there, manufacturers must apply those controls on objective, non-discriminatory terms and give accredited independent repairers access on conditions no less favorable than those offered to authorized service networks.

There is a subtlety worth noting. The guidelines are not a statute; they do not create obligations beyond what the Competition Act already says. But they carry real weight, because the Competition Tribunal is required to consider whether alleged anti-competitive conduct mirrors practices described in official guidelines when it sets penalties. Enforcement will focus on out-of-warranty repairs paid for directly by consumers, evaluated case by case against justifications such as intellectual property protection and user safety. The commission has urged independent repairers to report manufacturers that engage in restrictive practices or frustrate third-party servicing efforts.

Parts pairing, explained

Parts pairing is simple to describe and hard to defeat. When you replace a screen, battery, or camera, the device checks the new component's identity against a whitelist tied to the original serial number. If the part is not the one the manufacturer blessed, it may refuse to work at all, work with degraded functionality, or trigger a nagging warning that the phone contains an "unknown" part. Genuine parts harvested from identical devices, sometimes even from the same model, can fail the check.

Manufacturers defend the practice on security and quality grounds. Apple has long argued that pairing authenticates biometric components against spoofing and ensures proper calibration of cameras and displays. Apple told TechCrunch in 2024 that it does not block third-party parts from working, framing pairing as authentication rather than exclusion. In that same year, the company began allowing used parts in iPhone 15 repairs, including batteries, cameras, and displays, a concession widely read as a response to mounting regulatory pressure.

The laws are on the books. The fight now is over how manufacturers comply with them, one serialized component at a time.

Regulators are not persuaded by the authentication argument alone. Oregon outlawed parts pairing outright in its 2024 right-to-repair law, signed by Governor Tina Kotek, making it the first US state to ban the practice. Colorado and Washington have followed with similar restrictions. The European Union took a different route in its binding rules: manufacturers must supply key spare parts for seven years and actively facilitate parts-pairing activations so independent repairers are not locked out of the handshake.

Why South Africa chose competition law

South Africa's approach is distinct from the legislative wave in the United States and Europe. Instead of a new statute, the commission is using competition enforcement, treating repair restrictions as aftermarket abuses akin to the ones automakers were warned about in 2021. The advantage is speed: no parliament vote required, and the framework can reach products that legislators often carve out. The guidelines' product scope is notably broader than most American laws, extending to medical devices and backup energy systems that US state laws typically exclude.

The trade-off is uncertainty. Guidelines lack the crisp obligations of a statute, and each enforcement action will be decided on its own facts. Manufacturers can argue that a particular lock protects users or secures a payment system, and the commission will weigh those claims case by case. That makes South Africa a testing ground for a question every regulator will eventually face: how much security theater is acceptable inside a repair lock?

The enforcement era has begun

Zoom out, and South Africa's move is part of a pattern. In the United States, Texas became the ninth state with an electronics right-to-repair law when HB 2963 took effect on September 1, 2026. The bill passed with striking unanimity, 130 to 0 in the House and 31 to 0 in the Senate, and Texas's law even included anti-parts-pairing language. It covers phones, laptops, tablets, cameras, and speakers with a wholesale price above $50, requires documentation to be retained for three to seven years depending on price, and excludes consoles, home appliances, medical devices, and farm equipment. TexPIRG estimates the state generates roughly 621,000 tons of electronic waste each year, and the law's supporters argue that more than one-third of Americans now live in a state with electronics repair protections.

That is the new landscape: laws in effect across nine US states, binding EU requirements, and now competition-law enforcement in one of Africa's largest economies. The manufacturers' old playbook, lobbying to weaken or kill repair bills, is giving way to a compliance playbook, and advocates will be watching closely for the loopholes repairers have long complained about, such as selling glued assemblies instead of individual parts, or pricing official components so high that independent repair cannot compete.

The deeper question is whether manufacturers will respond globally or jurisdiction by jurisdiction. Designing one device architecture that respects every regime's repair rules is expensive; maintaining parallel pairing systems for paired and unpaired markets is expensive too. Every new enforcement action, from Cape Town to Austin, narrows the space in between.