South Africa Just Made Parts Pairing a Competition Case Waiting to Happen

On a Monday that most of the repair world missed, South Africa's Competition Commission published the document the country's independent repairers have been asking for since at least 2024: the final Guidelines on Repair, Service and Maintenance Aftermarkets, the first formal right-to-repair framework for consumer electronics in the country. It is not a law. It is arguably more interesting than a law. The guidelines lay out exactly which manufacturer behaviors the commission considers anti-competitive, name software locks on spare parts as the top enforcement priority, and tell repair shops to start reporting manufacturers that frustrate them.

TechCentral reported in May 2026 that South Africa had no right-to-repair framework for consumer electronics, more than two years after industry groups began pressing for one. Five months later, the gap is closed, at least on paper. The framework works through competition law rather than a standalone repair statute, and that choice shapes everything about it: how it is enforced, who it applies to, and how far it reaches.

What the guidelines actually say

The guidelines cover a broad sweep of products: mobile phones, tablets, gaming consoles, televisions, household appliances such as washing machines and tumble dryers, medical devices, and backup power and water systems. Motor vehicles are excluded, but only because they already have their own dedicated automotive aftermarket guidelines, introduced in 2021.

The commission's list of potentially harmful practices reads like a greatest-hits album of repair complaints: blocking access to spare parts or repair information, preventing independent repairers from entering or growing in the market, and pressuring consumers not to use independent shops. Each is assessed against the Competition Act on a case-by-case basis, with the commission weighing justifications such as consumer safety, the protection of intellectual property, and compliance with other laws. The guidelines apply mainly to repairs that consumers pay for themselves, because the fault falls outside warranty.

Parts pairing gets named

The sharpest section never uses the term "parts pairing," but everybody in the industry will recognize the target. When software stops a replacement part from working until the manufacturer activates it, or when a phone throws up a warning message after an independent repair, the commission will treat those as indirect restrictions on access to spare parts. Such restrictions, the guidelines say, will be "a priority for investigation and enforcement."

South Africa just told manufacturers that a software lock on a spare part is not a design decision, it is a competition case waiting to happen.

Parts pairing is the mechanism that has made modern repairs strange: a screen or battery that works perfectly as hardware but refuses to function until a server somewhere approves the serial number. It is also the mechanism the industry has fought hardest to keep, usually on security grounds. The commission heard that argument and gave it a narrow answer. Controls tied to device security or safety, such as anti-theft mechanisms, authentication systems, and battery management, are permitted, but only when applied on objective, transparent, and non-discriminatory terms. Independent repairers who meet the manufacturer's accreditation requirements must get access on terms no less favorable than those offered to authorized service networks.

Non-binding, with teeth

The guidelines are explicitly not binding, and they "do not create obligations beyond those already contained in the act." That sentence will get quoted by every manufacturer lawyer in Johannesburg, so it is worth understanding what follows it. Under South African law, the Competition Tribunal must consider whether alleged anti-competitive conduct is substantially the same as conduct described in official guidelines when it sets a penalty. In practice, a guideline that names your practice as an enforcement priority raises the cost of being found in breach.

The framework's other quiet strength is its reporting channel. The commission has urged independent repairers to report manufacturers that engage in restrictive practices or frustrate third-party servicing. Enforcement of this kind lives or dies on complaints, and the commission is explicitly asking the trade to supply them.

How Europe compares

The natural comparison is the European Union, which has gone further on binding rules. Since June 2025, an EU regulation has required smartphone and tablet makers to keep key spare parts available for at least seven years after a model stops being sold in the EU. Europe permits parts pairing too, but with a hard clock: manufacturers must give professional repairers access to the software needed to make a paired replacement part work within three working days of a request. A separate EU repair directive, which member states had to apply from 31 July 2026, obliges manufacturers to repair products such as phones, televisions, and washing machines on request, free of charge or at a reasonable price, and bars them from using contractual, hardware, or software techniques that impede repair unless justified by legitimate and objective factors such as protecting intellectual property.

South Africa's version is broader in product scope, extending to medical devices and backup power systems that the EU directive does not cover, but thinner on fixed obligations. Where Brussels sets clocks and year counts, Pretoria relies on case-by-case competition enforcement. Which model works better will depend less on the legal architecture than on whether complaints actually arrive and get acted on.

What to watch

The first signal will be whether the commission opens an investigation under the guidelines' parts-pairing priority. Smartphone and appliance makers run the same global parts systems in Johannesburg as in Berlin, so a South African enforcement action would have implications beyond one market. The second signal is the complaint channel: if independent repairers start reporting, the commission has promised the practices will be treated as a priority. If they do not, the guidelines become an elegant document with nothing to attach to. Either way, the repair world got its clearest statement yet from the Global South that software locks on hardware are a competition problem, not a design freedom.