Aligning clause 12 with the EAA use of "information" instead of "documentation"

Clause 12 in EN 301 549 v.3.2.1 and recent revisions uses the term "documentation", but this term does not occur in the EAA requirements.

Instead, the EAA talks about "information" about the "the use of" a product or about "the functioning of" a service. The information referred to includes such aspects as "instructions for use of a product", descriptions of the "features, elements, and functions" of a product or service, and "information concerning accessibility of the products and services".

EN 301 549 is not expected to detail what that information is, but there is an obligation that such information must be presented in accessible ways when it is made available in a digital format.

Wnat EN 301 549 is expected to ensure is that when such information is made available in the form of digital media, it shall be accessible. An alternative for the EN 301 549 v.3.2.1 version of clause 12 could be:

12 Information about products and services

12.1 Accessible information about products
Where ICT is, or includes, information about a product, made available in a digital format,
the presentation of the information shall conform to the requirements of clause 9 if it is available in a Web format, clause 10 if it is available as a non-web document, and clause 11 if it is available as part of software.

12.2 Accessible information about services
Where ICT is, or includes, information about a service, made available in a digital format,
the presentation of the information shall conform to the requirements of clause 9 if it is available in a Web format, clause 10 if it is available as a non-web document, and clause 11 if it is available as part of software.

NOTE: The term service in the pre-condition of this requirement includes all support services.

Requirements in the HEN standards on "non-digital information" and "support services" are expected to describe what information shall be made available, and also for the accessibility of that information when it is presented in a non-digital format. The above reformulation of clause 12 covers the EN 301 549 responsibility for ensuring the accessibility of the information when it is made available in a digital format.

added Documentation and Support Services label

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marked this issue as related to #432 (closed)

mentioned in issue #432 (closed)

Good,

But I se an ambiguity in the clause headers.

What is accessible? The information or the product or service?

I suggest:

"Accessible information on products"

and

"Accessible information on services"

Agreed, I have modified the titles to read:

"Accessible information about products"

and

"Accessible information about services"

using "about" rather than "on".

changed the description

I have changed the "or"s to "and"s in the original proposal in the first comment of the issue, as this is logically correct.

changed the description

mentioned in issue #485

since sometimes it is hard to tell if something is a product or a service and increasingly products include services

why not just make it one.

12 Information about products and services

12.1 Accessible ICT information ................... (or if you like Accessible Product and/or Service information)
Where ICT is, or includes, information about the product and/or service,
the presentation of the information shall conform to the requirements of clause 9, 10 and 11.

The above comment is referring to a version of the proposed requirements that is different to the currently proposed wording. But the split into two requirements was an intentional choice to provide unique links to the categories identified in the EAA, which specifies requirements for products in one place, services, in another place, and support services in a third place.

But I think that a single requirement might be suitable. So, basing it on the current proposal for the two separate requirements, it would read:

12 Accessible information about products and services
Where ICT is, or includes, information about a product or service, made available in a digital format,
the presentation of the information shall conform to the requirements of clause 9 if it is available in a Web format, clause 10 if it is available as a non-web document, and clause 11 if it is available as part of software.

NOTE: The term service in the pre-condition of this requirement includes all support services.

The pre-condition refers to "a product or service" rather than "the product or service" as the ICT might be a website related to any product or service not to a specific one referenced elsewhere in the requirement.

Current proposed note:

The term service in the pre-condition of this requirement includes all support services.

This conveys that information about support services would be included, which doesn't make sense.

An editorial change is needed in the note, something like this:

The term 'information about a product or service' in the pre-condition of this requirement includes documentation for ICT.

I'm not clear why "information about support services" doesn't make sense. It is surely useful for people to have information about what a support service does and how it can be accessed. Would it improve things if the proposed note was changed to:

NOTE: The term service in the pre-condition of this requirement also includes all support services.

In 3.2.1, product documentation seemed to be about the ICT itself. See for example the wording of C.12.1.1: "Check that product documentation provided with the ICT lists and explains how to use the accessibility and compatibility features of the ICT".

The scope here is broader, and encompasses any information about products of services, regardless of the ICT itself. The ICT could be the product or service but this would be just a special case.

Is this correct?

@vagnera wrote:

The scope here is broader, and encompasses any information about products of services, regardless of the ICT itself. The ICT could be the product or service but this would be just a special case. Is this correct?

Yes, especially for services.

EAA Article 2 enumerates the kinds of products and services that it directly regulates. EAA's enumerated 'products' are all digital products (phones, smart TVs, payment terminals, etc.), which would equate to an ICT under EN 301 549. In EAA Annex I, provisions (I)(1) and (II) give the requirements for the digital and non-digital information about these products.

EAA's enumerated 'services' are a different story.

• Example: for an 'e-commerce service', the e-commerce website or app would be the ICT (and possibly something like an electronic delivery locker). There could also be aspects of e-commerce that are not fully digital, like "how to return merchandise" mentioned in #432 (closed).
• Another example: a 'consumer banking service' includes things like cash deposit accounts, credit cards, and some kinds of financial advice. It's easy to foresee aspects of service delivery that are not digital.
• The "information" requirements in EAA Annex I(III)(b) apply broadly to the information (digital or not) about any aspect of an enumerated service (digital or not).

The standardisation request M/587 assigns these information requirements to the "non-digital" EN as described in #494 (closed). I leave it to the standards organisations to decide whether EN 301 549 will provide a complementary clause 12. If there is a clause 12, I support the language proposed in the present issue.

added Included in EN label

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mentioned in issue #115 (closed)

mentioned in issue #229 (closed)

mentioned in issue #276 (closed)

mentioned in issue #494 (closed)

mentioned in issue #454 (closed)