Incomplete requirements for EAA: information about accessibility of items being sold
EAA Annex I(IV)(g)(i)
E-Commerce services: providing the information concerning accessibility of the products and services being sold when this information is provided by the responsible economic operator
Currently in EN 301 549
The 2025-02-07 draft does not have a requirement for this EAA provision.
Proposed
Something like this:
Where ICT lists item(s) for sale at a distance, and information concerning accessibility of an item is provided by the responsible economic operator,
ICT presents the information concerning accessibility of the item for sale.
The logic is clear enough. The terms might need work. "Sale at a distance" is part of the definition of 'e-commerce'. Maybe "responsible economic operator" will need further description or examples.
Activity
added EAA Alignment label
When describing what should be in EN 301 549 Mandate M/587 says, in Annex IV, Part C 2.1
"The harmonised standard shall describe the technical solutions for accessibility to ensure conformity with the accessibility requirements of Annex I section I, II, III, IV, excluding point (f) of section IV on e-books of Directive 2019/882."
Part B lists (c), (d), and (e) of IV are assigned to the non-digital EN and (f) is excluded altogether - but there is no mention of (g). So, the implication is that, despite all the faultless logic above, Mandate M/587 assigns this topic to EN 301 549.
Edited by Michael Pluke... Mandate M/587 assigns this topic to EN 301 549.
That's how I read it too.
EN 301 549 deals with the ICT or service providing the information in accessible ways and formats, not about the contents of the information to be provided!
Certainly that's the overall emphasis, but it seems like 12.1.1 is a relevant precedent.
12.1.1 Accessibility and compatibility features
Where ICT includes product documentation, whether provided separately or integrated within the ICT,
the documentation shall list and explain how to use the accessibility features of the ICT and its compatibility features with assistive technology.Regarding the idea of providing information to the extent it's available, that reminds me of 5.4.
5.4 Preservation of accessibility information during conversion
Where ICT converts information or communication, the ICT shall preserve all documented non-proprietary information that is provided for accessibility to the extent that such information can be contained in or supported by the destination format.
Regarding the relevant precedent found in clause 12.1.1:
I agree it is related, but 12.1.1 is still about the accessibility of the ICT. The EAA requirement for information about products being sold via the ICT is extending the scope one more order of magnitude, since it is about the accessibility of something other than the ICT. Still accessibility, and still relevant, but nonetheless a step further away from the ICT.
Hmmm I reluctantly agree with the arguments above that we were asked (required) to include this and it is unlike anything else we have - though close to 5.4.
Note that it does not ask that any information be created or added. It only requires that information about accessibility not be dropped.
So I agree with Mitchell and we should add an item in 12
Here is nominated language for this based off of Mitchell's original post.
Preservation of information on accessibility
Where ICT lists an items for sale at a distance, and information concerning the accessibility of the item is provided by the responsible economic operator,
ICT shall preserve and convay the information concerning the accessibility of the item for sale.@pluke Advance to discussion to decide if 1) we are going to add something to address the requirement on us and 2) see if this fills the bill?
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On closer examination of what Mandate m/587 says, the text that I quoted:
"The harmonised standard shall describe the technical solutions for accessibility to ensure conformity with the accessibility requirements of Annex I section I, II, III, IV, excluding point (f) of section IV on e-books of Directive 2019/882,"
is only part of the story! I failed to quote the important second part of this sentence! This reads:
, except for those included in part B of this annex, namely those covered by new standards.
The misleadingly named first standard in part B, the "non-digital information" standard, is the standard that should be the single source that describes what information "about" ICT (including information that describes the accessibility of ICT, user guides, etc.) is required to be provided. The role of EN 301 549 is simply to ensure that when such information is provided, that it is made available in accessible ways. The requirements of clauses 9, 10, and 11 do that.
The team that are preparing this second standard now appear to share this perspective, so this requirement needs to be addressed by that standard, and not by EN 301 549.
The role of EN 301 549 is simply to ensure that when such information is provided, that it is made available in accessible ways. The requirements of clauses 9, 10, and 11 do that.
The team that are preparing this second standard now appear to share this perspective, so this requirement needs to be addressed by that standard, and not by EN 301 549
That sounds correct for some EAA provisions but not this one.
Standardisation request M/587 Annex IV Part B does not mention EAA Annex I(IV)(g), so EN 301 549 is required to include this provision for e-commerce. Is my understanding correct?
Or does @hellstromgu's "modify the WI proposal" mean to supersede the standardisation request? I don't recognize the term "WI".
