EAA EU Accessibility Act (EU) 2019/882 Q&A

1. This product comes in a series of models. Can we test only one model to generate a report for all models?

From the perspective of inspection/testing, unless all contents (hardware, software, instructions, etc.) of all other models are 100% consistent, the testing party cannot responsibly promise that "the result of testing one can represent all".

From the perspective of certification/reporting, the usual principle is that different models of products cannot be included in the same report.

2. In order to save time and budget, it is impossible for enterprises to test all products in the entire series. What are the ways to deal with this situation?

In practice, considering objective limiting factors such as enterprise time cost, budget, and team workload, there are plans to minimize repetitive work as much as possible for reference.

For example, Model A and Models B and C are 100% identical at the software level, with only differences in the manual and hardware dimensions; So, the software detection results of model A can be reused on B and C, but B and C need to separately detect the parts that differ from A. Of course, it is recommended that companies provide explanations in their self declarations or related reports to increase the authenticity and transparency of information and further reduce unnecessary risks.

3. What are the differences to be tested for different models of the same product, and what dimensions should be considered?

From the current mainstream consideration of EAA compliant product forms (mobile phones, smart screens, laptops, routers, smartwatches, cameras, apps, web, doorbells, projectors, etc.), the differences between different models of the same product include but are not limited to:

Operating system (specific to system and version number)

Brand self-developed application pre installed at the factory (specific to application and version number)

Hardware (appearance/size/interface)

Instruction manual (paper/electronic version)

Web cross end (such as PC web adaptation to mobile)

other

4. Is the smart TV/conference TV all-in-one machine/smart screen within the scope of EAA requirements?

Very clear, in.

5. What are the key points to pay attention to when considering accessibility for smart TVs/conference TV all-in-one machines/smart screens?

Most of these products that go global are equipped with the operating system (OS) Google TV OS, and the brand itself pre installs some self-developed applications in the OS.

In this case, when considering accessibility for such products, the focus is actually on the accessibility of self-developed applications by the brand.

Of course, although according to the terms of EAA, the brand has an obligation to urge third parties (Google TV OS) to consider accessibility, that is not within the brand's control, so it usually does not involve illegal activities.

6. What is the workload for the brand to comply with EAA for smart TV/conference TV all-in-one machine/smart screen?

The brand should mainly cooperate to confirm whether their products have accessibility testing conditions (such as whether the OS has "accessibility functions", whether it can install Talkback, etc.).

And provide a list of pre installed self-developed applications.

7. Is it only necessary to do EAA compliance for one of the products in the same series with different screen sizes for different models?

If it can be confirmed that different models only have different screen sizes, everything else is not different. ——That really only requires conducting accessibility testing for one of them (as for the report and certificate, it's another matter).

If the above cannot be 100% confirmed, no one can guarantee that the accessibility of one of them can represent the other.

8. Is the accompanying remote control within the EAA requirements?

In there.

For example, if the remote control has a numeric keypad, the numbers must have a unique design that can be touched.

9. There is a paid toolbar abroad that claims to be accessible when loaded on a website. Can I directly purchase and use this toolbar to achieve EAA compliance?

There are many solutions for website accessibility, such as the toolbar solution, which can also improve the accessibility of the website to a certain extent.

However, when it comes to the EU Accessibility Act (EAA), whether it is the provisions of the act itself or the EN 301 549 standard requirements corresponding to the web, relying solely on "tools" is not enough to meet standards or comply.

10. Some people say that in order for the web to comply with EAA, it is necessary to do a good job with cookie pop ups. Is that correct?

Whether it is the concept of accessibility, related technical standards (EN301549, WCAG), or the requirements of the EAA bill, it is far more than just "pop ups" or "cookies".

11. My product is just a camera connected to a computer. Do I need to comply with EAA?

If this camera:

1) It is a pure camera that can perform its basic functions as long as it is connected to a computer;

2) There are no drivers, configuration software, etc;

3) Even with configuration software, the most basic functions of the camera can be used without using the configuration software.

——So, it can be considered as not within the scope of EAA requirements.

Of course, since EAA has not yet officially come into effect and there are no precedents, considering accessibility is safer than not considering it in order to ensure that everything is foolproof.

12. My product is not sold offline in the EU region, but on the Amazon website in Europe. It is an enterprise level product, not a consumer level product. Do I need EAA compliance?

As long as the products are sold in EU countries (regardless of where or how they are sold) and within the scope of EAA requirements, they must comply with EAA.

Even if it is an enterprise level product that does not appear to be within the scope of EAA requirements, if the sales channel is aimed at or allows individual consumers to purchase, and individual consumers can still use the product after purchasing, then the product must passively comply with EAA. ——In other words, the "enterprise level" is not the "the final say" of the enterprise itself.

13. EAA will officially come into effect on June 28, 2025. Does this mean that from that date onwards, companies will need to self declare their compliance with EAA requirements during customs clearance?

Yes, new products launched on the market after June 28, 2025 are required to make a self declaration of conformity during customs clearance. For example, the product should comply with the recommended standard EN 301 549 of the European Union Accessibility Act (EAA).

14. The regulation states that "services provided and contracted before June 28, 2025 may continue to be used during the validity period of the contract, with a maximum transition period of 5 years, and must be fully implemented until June 28, 2030. How do you understand this sentence?

Firstly, this clause only applies to service providers and not to product manufacturers. That is to say, there is no concept of transition period for software and hardware products that are solely targeted at sellers, and they must comply with the EU Accessibility Act (EAA) from June 28, 2025 onwards. For service providers, the bill provides a five-year transition period for services that have been put into use or contracted before June 28, 2025, allowing companies to gradually phase out software and hardware products that do not meet accessibility requirements and are compatible with the service to meet new standards and requirements.

15. If I am a service provider, since there is a 5-year transition period, can I not consider EAA compliance?

Taking service provider: telecommunications operator as an example. Assuming it provides broadband services while also offering a router to users, this router has a 5-year exemption period, and telecom operators can replace it with a product that meets EAA requirements within 5 years. However, the manufacturer of this router, which is sold independently to the market, does not have the concept of a 5-year exemption period.

16. At the time when the bill is officially implemented on June 28, 2025, do companies still have other common questions and misconceptions?

Due to the fact that the EU Accessibility Act (EAA) has not yet officially come into effect, no one can predict the enforcement efforts, judicial interpretations, and judgment cases at that time, and there is a lot of uncertainty involved. However, based on historical experience and the implementation of similar laws in other countries and regions, any newly effective accessibility related laws or disability assistance related laws have strong enforcement efforts, and the probability of companies losing lawsuits is also high. Even products will be given special attention to accessibility by people with disabilities and disability assistance organizations. In view of this, we suggest that companies that value the EU market should not take risks and strive to ensure that their products comply with the EU Accessibility Act (EAA) as much as possible. ——This is not only to avoid illegal activities, but also to enable the product to be truly better used by disabled users, achieving multiple benefits in one fell swoop.