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5.5.2 (Operable parts discernibility) is less stringent than EAA Annex I(I)(2)(h)

Currently

EAA Annex I(I)(2)(h), emphasis mine:

when the product requires manual operation and control, it shall provide for sequential control and alternatives to fine motor control, avoiding the need for simultaneous controls for manipulation, and shall use tactile discernible parts

Currently in the 2025-02-07 draft:

5.5.2       Operable parts discernibility

Where ICT includes operable parts,
the ICT shall provide a means to discern each operable part, without requiring vision and without performing the action associated with the operable part.

Note 1:  One way of meeting this requirement is by making the operable parts tactilely discernible.

Note 2:  Where physical buttons are arranged in small functional groups, or on-screen buttons are positioned in fixed positions adjacent to tactilely discernible boundaries (such as screen edges or surrounds), their position can be tactilely discerned.

Note 3:  Clause 8.4.2.1 “Mechanical operable parts discernibility" makes the provision of tactile identification a requirement and not "one way" of meeting the requirement as it is in the present clause.

This means that for on-screen controls, clause 5.5.2 currently allows either tactile discernibility or other "means to discern... without requiring vision" such as smartphone-style screen reader interactions with audio. Thus clause 5.5.2 is less stringent than the EAA provision.

Clause 8.4.2.1 currently does require tactile discernibility, but only for mechanical operable parts, not for on-screen controls.

Proposed

Add a new requirement or update 5.5.2 to require tactile discernibility for on-screen controls.

This note would also be useful:

Note: Where ICT allows users to connect a mechanical keyboard or controller and perform all functions, this requirement would be met.

Feasibility

Personal phones, tablets, and general-purpose computers do generally support users' own mechanical keyboards, so this is feasible.

Thus within the scope of EAA "products", the enhanced requirement mainly affects:

  • E-readers — the requirement can be met by including support for users' own keyboard.
  • Self-service terminals — the requirement can be met with a variety of industry-standard mechanical keypads.

For applications of EN 301 549 beyond EAA scope, for example to other personal electronic devices, there are adequate precedents of tactile features on the device itself or via adaptive controllers.

Alignment with other global standards

Compare with US Section 508, which covers on-screen closed functionality together with mechanical hardware controls:

407.3.1 Tactilely Discernible

Input controls shall be operable by touch and tactilely discernible without activation.