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Relocate Clause 10.8 to Clarify Applicability to Time-Based Media

REFERENCE: Clause 10.8, Annex C, Table ZB.5 No. 4

Clause 10.8 and its subclauses are intended to address the European Accessibility Act (EAA) requirement that electronic program guides (EPGs) provide information about the availability of accessibility features in audiovisual media. However, its current placement implies that it applies broadly to all non-web documents, including formats such as PDF or Word files, which is not the intent.

Additionally, Clause 10.8 is not currently cited in Table ZB.5, which obscures its connection to EAA compliance, and there are no corresponding conformance test procedures in Annex C.

PROPOSED CHANGE

  • Move the content of Clause 10.8 under Clause 10.1.2 (Time-Based Media) to clarify that it pertains specifically to audiovisual media.
  • Add test procedures for these requirements in Annex C to support conformance verification.
  • List these requirements in Table ZB.5 No 4 to clarify they address the EAA requirement for EPGs.