Incomplete requirements for EAA: compatibility with hearing technologies

EAA

EAA Annex I(I)(2)(o)(i)(indent 7):

Self-service terminals: when the product uses audio or audible signals, it shall be compatible with assistive devices and technologies available at Union level, including hearing technologies such as hearing aids, telecoils, cochlear implants and assistive listening devices

EAA Annex I(I)(2)(o)(iii)(indent 3):

Consumer terminal equipment with interactive computing capability, used for the provision of electronic communications services: shall ensure effective wireless coupling to hearing technologies

EAA Annex I(I)(2)(o)(iii)(indent 4):

Consumer terminal equipment with interactive computing capability, used for the provision of electronic communications services: shall avoid interferences with assistive devices

Currently in EN 301 549

In the 2025-02-07 draft:

8.2.2 Magnetic coupling:

8.2.2.1         Fixed-line devices

Where ICT is, or includes, hardware, and has speech output, and is a fixed-line communication device that is normally held to the ear,
the ICT shall provide a means of magnetic coupling which meets the requirements of ETSI ES 200 381-1 [2] and shall carry the "T" symbol specified in ETSI ETS 300 381 [1].

Note 1:  ICT fulfilling the requirements of TIA-1083-A [i.24] is deemed to comply with the requirements of this clause.

Note 2:  Magnetic coupling is also known as inductive coupling for T-coil.

8.2.2.2         Wireless communication devices

Where ICT is, or includes, hardware, and has speech output, and is a wireless communication device that is normally held to the ear,
the ICT shall provide a means of magnetic coupling to hearing technologies which meets the requirements of ETSI ES 200 381-2 [3].

Note:      ICT fulfilling the requirements of ANSI/IEEE C63.19 [i.1] is deemed to comply with the requirements of this clause.

Issues

8.2.2 is limited to two-way voice communications, and further limited to devices "normally held to the ear", and further limited to fixed-line or wireless devices.

The above EAA provisions apply to:

• Self-service terminals that use audio
• Consumer communication devices without the scope limitations — for example Internet Protocol (IP) phones, or speakerphones

Proposed

Add or expand clauses to cover the increased scope.

Confirm the added or expanded clauses match the EAA requirements — compatibility, coupling, non-interference

Comparison with other global standards

US Section 508, 402.3.1 Private Listening

US Section 508, 412.3 Interference Reduction and Magnetic Coupling

changed the description

Those of us who are telecom industry veterans will know that the key phrase in the magnetic coupling requirements is “normally held to the ear”. Magnetic coupling is critically dependent on the distance and relative position between the device and the hearing aid or telecoil. Removing that phrase and applying the requirement to devices that are not held to the ear would literally require bending the laws of physics.

Please be aware that the old "hearing aid loops" for amplifier systems in buildings are now becoming obsolete and are being replaced with Bluetooth systems.

added EAA Alignment label

we already cover all of these

1) FIRST ITEM

EAA Annex I(I)(2)(o)(i)(indent 7):
Self-service terminals: when the product uses audio or audible signals, it shall be compatible with assistive devices and technologies available at Union level, including hearing technologies such as hearing aids, telecoils, cochlear implants and assistive listening devices

Our requirement for a headphone jack in 5.1.3.2 satisfies this

all of those things can connect to kiosks using the jack and either a wire or dongle with a headphone plug on it. (in fact this is the only known way that will work with all of those).

2) SECOND ITEM

EAA Annex I(I)(2)(o)(iii)(indent 3):

Consumer terminal equipment with interactive computing capability, used for the provision of electronic communications services: shall ensure effective wireless coupling to hearing technologies

8.2.2.1 and 8.2.2.2 would cover this

IF we change "wireless" to "wireless and cellular" in 8.2.2.2.

(wired internet is covered under 8.2.2.1 since it is fixed).

"held to the ear" is needed for magnetic coupling but not for the other modes of connection.

Headphone jacks are no longer provided on many cell phones -- and we don't really need them added back (though many would prefer them).

I think - we can make the wireless/wireless+cellular change and consider this closed

3) Third item

EAA Annex I(I)(2)(o)(iii)(indent 4):\

Consumer terminal equipment with interactive computing capability, used for the provision of electronic communications services: shall avoid interferences with assistive devices

ADD a new requirement

6.8 Non-Interference Where ICT provides continuous bidirectional voice communication, and is or includes a communication client,
the ICT shall meet applicable telecommunication regulations regarding interfence with assistive technologies

In American English compared to ETSI English, cellular = mobile.

And in ETSI English wireless includes Bluetooth and NFC etc, and not so much mobile phone technology.

So your proposals are good but need to be translated to ETSI English.

Possibly USB-C should replace or complement the headphone jack, but there may be other SDO:s involved in such decisions(?)

Cannot replace USB-C for headphone jack since usb-c is a security threat and will not be put on many public systems. if we say headphone jack or usb-c then we have a different problem in that users now have to carry different solutions around with them and simple headphones will no longer work. better to stick with headphone jack and allow people to use simple headphones or a simple single adapter from whatever they are using to the headphone jack

oh by the way -- in WCAG mobile means smartphones and tablets etc. Basically all the touchscreen devices. since it is also an international standard (actually I guess ETSI is european not international - though european is international.... unghh ) how do we write EN 301 549 to work for all countries that we want to use it -- and not make it euro-specific if we can help it?

Every Microsoft Surface laptop is a touchscreen device. There are also touchscreen desktop devices. It would be a mistake to assume it only applies to phones and small-screen tablets.

ETSI standards are used worldwide. In fact we often have to remind some people that ETSI are not officially an "international standards organisation" in the WTO sense.

For example, some of the ETSI television standards are used almost everywhere, even in the USA (for some satellite services).

As you know this causes problems when countries want to use our EN locally because many countries don't recognise European standards as acceptable for referencing in local regulations, so they make (often inferior) copies. Hence all the debate about globalising the EN by making it also an ISO standard where it could be directly adopted in many more countries.

+1 good point @jeffreym

I think it is sufficient that we change your proposal:

"wireless and cellular" in 8.2.2.2."

to

"wireless and mobile"

Yes, ETSI is European but has a tendency to be used e.g. in Canada and Australia etc.