For several years, Colorado has positioned itself as the vanguard of the “right to repair” movement, systematically dismantling the barriers manufacturers place between owners and their hardware. From the fields of industrial farming to the essential mobility of powered wheelchairs, the state has built a legislative framework designed to ensure that the person who buys the equipment actually owns the right to fix it.
However, this momentum is facing a critical test. Even as the state recently expanded protections to cover a vast array of digital electronics, a fresh legislative effort—Senate Bill 26-090—threatens to introduce a loophole that could shift control back to vendors. By introducing a broad exemption for “critical infrastructure,” the bill could potentially hollow out some of the strongest consumer protections in the United States, leaving IT leaders and independent repair providers with diminished authority over their own hardware.
The struggle in Colorado is more than a local regulatory dispute. it is a bellwether for the global tech industry. As other states look to Colorado for model language, the outcome of this fight will likely determine whether the trend toward open repair continues or if manufacturers can successfully reclaim a monopoly on maintenance through strategic legal carve-outs.
The Digital Expansion: Understanding HB24-1121
Colorado’s commitment to repair rights reached a new milestone with the passing of HB24-1121. This legislation significantly expands the scope of existing right-to-repair statutes to include digital electronic equipment. Specifically, the act applies to equipment manufactured and sold, or used for the first time in Colorado, on or after July 1, 2021.
Beginning January 1, 2026, the law mandates that manufacturers facilitate repairs by providing the necessary resources—including parts, tools, and documentation—to both owners and independent repair providers. This move is designed to prevent “vendor lock-in,” where a manufacturer is the only entity capable of performing a repair, often at a premium price and on a restrictive timeline.
One of the most significant technical hurdles addressed by HB24-1121 is “parts pairing.” This is a practice where manufacturers use software to lock a specific component to a device’s motherboard, preventing the device from recognizing or functioning correctly if a third-party or salvaged part is installed. For digital electronic equipment sold or used in Colorado after January 1, 2026, the act prohibits parts pairing if it:
- Prevents an independent repair provider or owner from installing or enabling replacement parts.
- Reduces the overall functionality or performance of the equipment.
- Triggers misleading alerts or warnings regarding “unidentified” parts.
Despite these protections, the law is not universal. The act includes specific exemptions for several categories, including marine vessels, aviation, motor vehicles, video game consoles, and certain safety, security, construction, and energy-related equipment. It also excludes medical devices, with the notable exception of powered wheelchairs, which were protected under earlier legislation.
The “Critical Infrastructure” Loophole: SB 26-090
While HB24-1121 expanded the umbrella of protection, Senate Bill 26-090 represents a potential retreat. Critics, including repair advocates at iFixit, warn that the bill seeks to carve out a category for “critical infrastructure” that is dangerously overbroad.
The concern is that the term “critical infrastructure” is sufficiently “fuzzy” and “lawyer-friendly” that manufacturers could apply it to a wide range of digital electronic equipment to bypass right-to-repair requirements. If a vendor can successfully claim that a piece of hardware is part of critical infrastructure, they may no longer be required to provide the parts, tools, or documentation necessary for independent repair.
This shift would effectively move the “control of the fix” away from the owner and back to the vendor. For Chief Information Officers (CIOs) and IT managers, this creates a strategic risk. When a vendor controls the repair ecosystem, the organization loses the ability to maintain its own infrastructure efficiently, increasing dependency on proprietary service contracts and potentially extending downtime during critical failures.
A Legacy of Repair Leadership
To understand why SB 26-090 is viewed as such a significant threat, one must look at the trajectory of Colorado’s legislation since 2022. The state has not relied on symbolic gestures but has instead built a comprehensive framework category by category:
- Powered Wheelchairs: In 2022, Colorado passed HB22-1031, the first Right to Repair bill in a decade, focusing on essential mobility devices.
- Agricultural Equipment: In 2023, the state passed HB23-1011, which remains the only agricultural repair bill to have passed in the U.S. So far.
- Digital Electronics: In 2024, HB24-1121 expanded these rights to the broader consumer and professional electronics market.
By establishing these laws, Colorado created a precedent where failure to comply with right-to-repair statutes is classified as a deceptive trade practice. This gives the state a powerful mechanism to hold manufacturers accountable, ensuring that the “right” to repair is backed by actual legal consequences.
Comparison of Colorado Right to Repair Milestones
| Bill | Year Passed | Equipment Covered | Key Focus |
|---|---|---|---|
| HB22-1031 | 2022 | Powered Wheelchairs | Essential mobility and accessibility |
| HB23-1011 | 2023 | Agricultural Equipment | Farmer autonomy and equipment uptime |
| HB24-1121 | 2024 | Digital Electronic Equipment | Ending parts pairing and vendor lock-in |
The Global Ripple Effect
The battle over SB 26-090 is not just about Colorado; it is about the blueprint for future legislation. Since 2022, eight other states have passed Right to Repair laws, often looking to Colorado’s specific language as a gold standard. If Colorado allows a broad “critical infrastructure” exemption, it provides a ready-made template for manufacturers to lobby for similar carve-outs in other jurisdictions.
For the global tech community, this represents a tug-of-war between two philosophies of ownership. One side argues that for the sake of security and stability, only the original manufacturer should handle “critical” systems. The other side argues that true ownership—and the ability to maintain the longevity of hardware—requires that the owner has the legal and technical means to perform repairs independently.
If the “critical infrastructure” carve-out passes, the definition of what is “critical” will turn into the new battlefield. Without a strict, narrow definition, almost any piece of enterprise-grade hardware could be reclassified to exempt it from repair mandates, effectively neutralizing the progress made over the last four years.
What Happens Next
The industry is now watching closely to see how the Colorado legislature handles the tension between consumer rights and the “critical infrastructure” arguments presented by vendors. The immediate focus remains on the implementation of HB24-1121, which will see its most stringent prohibitions on parts pairing take effect on January 1, 2026.
Whether the state maintains its position as the national leader in repair rights or allows a significant retreat via SB 26-090 will likely be determined in upcoming legislative sessions and committee hearings. For now, the “right to repair” remains a contested territory where the definition of a single phrase could determine who holds the screwdriver.
Do you believe “critical infrastructure” should be exempt from right-to-repair laws, or does that create too large a loophole for manufacturers? Share your thoughts in the comments below.