Requirements on information on services are needed in clause 12

EAA Annex I, Section III(b) requires:

(b)	providing information about the functioning of the service, and where products are used in the provision of the service, its link to these products as well as information about their accessibility characteristics and interoperability with assistive devices and facilities:

M/587 requires EN 301 549 to contain requirements on information when it is digital.

Clause 12 seems to be a suitable place for these requirements, but currently clause 12 has only clauses for info on products and support services.

Requirements for info on services is suggested to be added, either by adding clauses or by expanding the scope of the current product clauses to cover products and services.

added EAA Alignment label

marked this issue as related to #432 (closed)

Annex I section III (b) is expliclitly assigned to be covered by the harmonised standard setting up requirements on the accessibility of non-digital information related to products and services - see M/587, Part B, section 2.1, point 1.

The only aspects covered by the EN 301 549 is meeting the specific requirements specified in bullet points (i)-(vii), but ONLY when the information is provided in a digital format.

The requirement for provision of such information or its content is assigned to the scope of the EN 301 549 by M/587, which clearly says that the EN 301 549 should address only the aspects that are not addressed by the other standards. And it is the harmonised standard on non-digital information that is to address among others Annex I Section III (b) requirements.

Yes, that is a way to see it. But then the title of the EN on "Accessibility of non-digital information related to products and services" is very misleading for cases when the service provider did not have any intention to provide non-digital information. Where will the provider go to find requirements for contents of the service information for the case when no non-digital info was planned, which is a very common case nowadays?

"Non-digital information" is not mentioned at all in the EAA and itis not defined in M/587!

Since M/587 was produced, everyone has asked the question "What does non-digital information mean" and I have not heard a single person propose a coherent attempt at trying to define it. It has always been a total mystery. This is not surprising as neither "digital" or "non-digital" are meaningful adjectives to use to describe types of information!

At its core, "information" refers to processed or organized data that conveys meaning or knowledge. It's the content or message communicated through signals, symbols, or signs, enabling understanding or decision-making. Digital or "non-digital" refers to the medium or format by which the information is conveyed to the user. The same information, such as user instructions, or accessibility information, could be conveyed to the user by one or more digital media (websites, pdfs, etc) or my non-digital media (printed instructions provided separately from the ICT or stuck to it or its packaging, including information provided in Braille). The information would be the same, but the format of that information might be digital (files, websites) or analogue (printed material).

The EAA makes very little use of the word "digital", but it does mention "digital files" and gives pdfs as examples of "digital files".

In contrast to the confusion caused by the use of the term "non-digital information", the EAA is very clear about categories of information and the usages of that information it is concerned with.

Conclusion

Forget the proposed title! M/587 gives clearly laid out explanaitions of what it believes belongs in each HEN, and then totally confuses people's understanding by linking it with a meaningless title for one of the HENs!

Yes, the title is misleading and it would be highly beneficial if it is modified.

Nevertheless, the M587 is extremely clear that Annex I section III (b) is to be covered by the harmonised standard setting up requirements on the accessibility of non-digital information related to products and services - see M/587, Part B, section 2.1, point 1.

The way the standard is referred to in this context (its tilte) is of a secondary importance and cannot be used to modify the scope of the new harmonized standard.

M587 clearly indicates that the EN 301 549 should cover any aspects of Annex I section III that are not covered by the other standards.

Looking at the EAA requirements of Annex I section III point (b), the only aspects that would not be covered by the new hEN are ensuring that points (i)-(vii) are met WHENEVER the information is provided in a digital format.

So @agata --

1. what exactly is needed to close this issue. and
2. Do you have suggested language (or even a direction) for doing this?

The issue requests adding to the EN 301 549 requirements for information on services to address the EAA Annex I, Section III(b).

To close this issue we need to agree that:

• PTS-SIS-031 comment on the latest draft that requested such change has been wrongly accepted. M587 in Part B unambigously assigns this requirement to be addressed by another harmonised standard:

1. The harmonised standard setting up requirements on the accessibility of non-digital information related to products and services shall describe the technical solutions for accessibility to ensure conformity with the following requirements set out in Annex I of Directive 2019/882: (...) Annex I section III (a) and (b)

• M587 requires that the EN 301 549 addresses only the aspects that are not covered by the other standards:

2.1. Existing harmonised standard EN 301 549: v3.2.1 2021 covering accessibility requirements of ICT products and services shall be revised. 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, except for those included in part B of this annex, namely those covered by new standards. The issue should be closed because the request is contrary to M587 standardization request. The only aspects of Annex I Section III(b) that are to be covered by the EN are the (i)-(vii) requirments.

If the EN was to address other parts of Annex I Section III (b), how the indicated new hEN would address the Annex I Section III (b) requirment as explicilty requested by the M/587 standardization request?

Im not sure I follow.

I think when someone says non-digital information they mean information that is communicated without using digital technologies. Not good English - but a lot shorter than "information that is communicated without using digital technologies”

Examples are anything face to face, and paper (all types - instructions, quickstart cards, text on the box) and any other - well - non-digital technologies.

However since we are limited to just access to ICT including DIGITALLY conveyed information -- I think we can just treat our responsibility as being limited to just making digitally conveyed information accessible.

Yes, it is challenging to follow because of a difficult language of the implied title for the new hEN. One strategy is to disregard the implied tile of the new hEN, and focus on the clearly assigned and requested scope exclusively:

• The new hEN is to cover Annex I section III (a) and (b) according to M587.

I agree with @gregg 's conclusion:

However since we are limited to just access to ICT including DIGITALLY conveyed information -- I think we can just treat our responsibility as being limited to just making digitally conveyed information accessible.

@hellstromgu claims that

M/587 requires EN 301 549 to contain requirements on information when it is digital.

I think, also in accordance with what @gregg has concluded, we opught to be very specific and say rather:

M/587 requires EN 301 549 to contain requirments on accessibilty of information, when it is in digital format.

Consequently any requirement for provision of any type of information where the test would require checking that the information is provided at all and with the requested content, seems naturally out of the scope of the EN 301 549.

Should one asume that both the EN 301 549 and the new hEN are to contain all the aspects of Annex I section III (b), though each for different format of information, conveyed digitally and non-digitally, respectively, we would be heading for a situation where:

• the EN 301 549 has a requiremnt to provide "information about the functioning of the service, and where products are used in the provision of the service, its link to these products as well as information about their accessibility characteristics and interoperability with assistive devices and facilities"

AND

• the new hEN would have an identical requirment!

It is essential to note that the requirment has nothing to do with the format of information. It is about its contents and existance - regardless the format in which it is provided.

This may seem to be not a big issue for Annex I Section III (b), but there are a number of requirments on providing specific information in Section I, II, III, IV that M/587 indicates as containing the requirments that ought to be coverd by both the new hEN and the EN 301 549.

However, M/587 also states clearly that the EN 301 549 should address only the requirments that are NOT covered by the new hEN. And for the new hEN specific items of Sections I, II, III and IV are mentioned.

Consequently, it seems reasonable to scrutinize the Section I, II, III and IV requiments and identify those that have to do with access to digital informaiton, excluding those that only require provision of information.

On that grounds, Annex I Section III (b) does not qualify as the requirment to be addressed by the EN 301 549.

Thanks for the discussions above, which are really useful for understanding and framing the issue.

I have shared a document in our working repository: 12-1 Product information

where I have compiled the EAA requirements in those EAA sections that M/587 assignes to the new hEN, namely:

• Annex I section I point 1 (a) and (b) and Annex I section II
• Also covering Annex I section III (a) and (b)
• Also covering Section IV (c) and (d) transport
• Also covering Section IV (e) (ii) banking information
• Excluding Section IV (f) e-books

and I have made a first attempt to analyze them.

The document contains a table with the following columns:

• EAA Annex/Section/Point + Common text & Specific Text (if any)
• Is the EAA requirement about what information to be provided (hence, to be addressed in new hEN, not in EN 301549)?
• Does the EAA requiremens have any implication with how the information is provided digitally? (hence, to be addressed in EN 301 549)
• Comments

The analysis is on-going, and everyone is invited to edit the table contents and to make proposals on how to improve its structure.

The very preliminary results indicate that the following EAA requirements may need to be analyzed with care:

• I-I-1(b) (ii) be presented in an understandable way;
• I-I-1(b) (vii) include a description of the user interface of the product (handling, control and feedback, input and output) which is provided in accordance with point 2; the description shall indicate for each of the points in point 2 whether the product provides those features;
• I-I-1(b) (viii) include a description of the functionality of the product which is provided by functions aiming to address the needs of persons with disabilities in accordance with point 2; the description shall indicate for each of the points in point 2 whether the product provides those features;
• I-II-(b) (ii) be presented in an understandable way;
• I-III-(b) (ii) presenting the information in an understandable way;
• I-IV-(c) (ii) ensuring the provision of information about smart ticketing (electronic reservation, booking of tickets, etc.), real- time travel information (timetables, information about traffic disruptions, connecting services, onwards travel with other transport modes, etc.), and additional service information (e.g. staffing of stations, lifts that are out of order or services that are temporarily unavailable).
• I-IV-(e) Consumer banking services: | (ii) ensuring that the information is understandable, without exceeding a level of complexity superior to level B2 (upper intermediate) of the Council of Europe’s Common European Framework of Reference for Languages.

Hi. I have quickly read @rodriguezasc 12.1 document, adding my comments there. My impression is that the EN does not need to add anything.

added Documentation and Support Services label

removed EAA Alignment label

mentioned in issue #541 (closed)

As a result of adopting the proposed changes from Issue #541 (closed), this requirement, and all others that concern the content of information about ICT are not appropriate to the scope of EN 301 549. It is the "non-digital" HEN and the "support services" HEN that will need to address all such issues.

closed