This is part 1 (manufacturer) in a series of hypotheticals designed to show the steps to take for compliance with the European Accessibility Act (EAA).
Consumer Tech Manufacturing is a European computer hardware company producing desktop computers, laptops, and tablets for consumer markets. As a manufacturer of general-purpose computer hardware systems, Consumer Tech falls directly under the European Accessibility Act (EAA), which became enforceable on June 28, 2025.
The EAA requires that all new (or significantly modified) computer hardware systems be designed and manufactured to be accessible to persons with disabilities, covering everything from physical design to operating system compatibility.
Here’s the general path forward to compliance for Consumer Tech.
Step 1: Identify Which Products Fall Under EAA
Start by cataloging your entire product line to determine EAA coverage. Remember, we’re concerned with new products placed on the market or existing products that have undergone significant modifications. For computer hardware manufacturers, the EAA specifically covers “consumer general purpose computer hardware systems and operating systems for those hardware systems.” This includes:
- Desktop computers and their operating systems
- Notebooks and laptops with their OS
- Smartphones and their operating systems
- Tablets and their OS
Review each product model and its operating system to confirm it qualifies as a general-purpose system capable of performing common computing tasks with appropriate software. Specialized embedded computers within other consumer electronics are excluded, but standalone computing devices and their operating systems marketed to consumers are covered.
Step 2: Determine Applicable Standards and Requirements
The technical accessibility requirements are set out in Annex I of the EAA. For computer hardware, you must comply with:
- Section I of Annex I (General accessibility requirements for all products)
- Section II of Annex I (Additional requirements – applicable to all products except self-service terminals)
Begin by:
- Reviewing Annex I requirements in detail
- Understanding that conformance with technical standards like EN 301 549 can be used demonstrate compliance
- Map each product feature to Annex I requirements
Key requirement areas from Annex I include:
- Information provision (multi-sensory channels, understandable presentation)
- User interface and functionality design
- Support services and documentation
- Packaging accessibility
- Compatibility with assistive technologies
Note: The EAA provides flexibility in demonstrating compliance. You can use harmonized standards (once published in the Official Journal), technical specifications, or develop your own method that meet the accessibility requirements. While standards like EN 301 549 may provide a structured approach, they are not mandatory. Per Annex IV, if you don’t use harmonized standards, your technical documentation must describe the alternative solutions adopted to meet each accessibility requirement. This flexibility allows for innovation while ensuring accessibility outcomes are achieved.
Step 3: Assess Current Accessibility Status
Conduct a comprehensive accessibility audit of your existing product lines against Annex I requirements. This critical step reveals the gap between current designs and EAA requirements. At this stage, working with a company who specializes in physical or hybrid accessibility is recommended.
Document findings for each product model, including:
- Compliant features
- Non-compliant elements requiring modification
- Features requiring complete redesign
- Missing accessibility functionality
Step 4: Implement Necessary Modifications
Based on your assessment, develop an implementation roadmap addressing identified gaps. This typically involves:
Hardware modifications:
- Adding tactile markers to keyboards and controls
- Ensuring adequate button spacing and resistance
- Implementing LED indicators for audio alerts
- Designing accessible port layouts
Software/firmware updates:
- Ensuring BIOS/UEFI accessibility
- Supporting screen reader compatibility
- Implementing keyboard navigation throughout
- Providing visual and audio redundancy for alerts
Documentation improvements:
- Creating accessible user manuals (multiple formats)
- Developing quick-start guides with clear visuals
- Providing accessibility feature documentation
- Including safety information in accessible formats
At this critical implementation stage, expert consulting services can provide strategic guidance on prioritizing modifications, developing implementation timelines, and ensuring changes meet Annex I requirements while minimizing disruption to existing production processes.
Step 5: Ensure Product Labeling and Language Compliance
Per Articles 7(5), 7(6), and 7(7), manufacturers must fulfill specific labeling obligations often overlooked in accessibility planning:
- Each product must bear a type, batch, or serial number for identification (or on packaging if size doesn’t permit)
- Your name, registered trade name/trademark, and contact address must be on the product (or packaging/accompanying document)
- All instructions and safety information must be in languages easily understood by consumers in each target Member State
- Instructions and labeling must be “clear, understandable and intelligible”
These requirements apply to every unit produced and directly impact packaging design, documentation translation, and production line processes.
Step 6: Create Required Documentation
The EAA mandates specific technical documentation demonstrating compliance. Prepare:
Technical Documentation File containing:
- General product descriptions
- List of applied technical standards (if used, such as EN 301 549)
- Explanation of how Annex I requirements are met
- Design specifications showing accessibility features
- Test results demonstrating compliance
- Solutions adopted where harmonized standards weren’t applied
EU Declaration of Conformity including:
- Product identification (model numbers, series)
- Manufacturer details and contact information
- Statement of compliance with Directive 2019/882
- References to harmonized standards used
- Date and authorized signature
Accessible.org’s documentation support service helps structure these documents correctly, ensuring all required elements are included and properly formatted for regulatory review.
Step 7: Set Up Conformity Assessment Procedures
Implement internal production control procedures (Module A) as specified in the EAA:
- Establish quality control checkpoints for accessibility features
- Create testing protocols for each accessibility requirement
- Document manufacturing processes ensuring consistent compliance
- Set up batch testing procedures for ongoing verification
Develop a formal process for:
- Pre-production accessibility review
- Production line quality checks
- Final product accessibility testing
- Documentation of all test results
Step 8: Establish Monitoring and Feedback Systems
Create systems to maintain ongoing compliance:
Customer feedback channels:
- Dedicated accessibility helpline
- Online feedback forms with accessible design
- Process for handling accessibility complaints
- Regular review of user feedback
Internal monitoring:
- Maintain a register of non-compliant products and related complaints
- Quarterly accessibility audits of production samples
- Annual review of standards updates
- Continuous improvement tracking
- Staff training on accessibility requirements
Understanding Article 14 Exceptions
While striving for full compliance, Article 14 provides limited exceptions where compliance would either fundamentally alter the product’s basic nature or impose a disproportionate burden. If relying on these exceptions:
- Conduct and document a thorough assessment per Article 14(2)
- Keep assessment results for 5 years from last market placement
- Note in your EU Declaration of Conformity which requirements are subject to exception
- Be prepared to provide assessment copies to authorities upon request
Important: These exceptions are narrowly interpreted and heavily scrutinized. They should never be your first option – only use after exhausting all reasonable compliance approaches.
Step 8: Prepare for Market Surveillance
Market surveillance authorities will verify EAA compliance through:
- Documentation reviews
- Product testing
- Facility inspections
- Complaint investigations
Prepare by:
- Organizing all technical documentation for quick access
- Training staff on surveillance procedures
- Maintaining test equipment and protocols
- Keeping records of any product modifications
Ensure your authorized representative (if applicable) has:
- Full access to technical documentation
- Authority to cooperate with surveillance authorities
- Understanding of compliance requirements
- Clear communication protocols with manufacturing
Mandatory Cooperation with Authorities (Article 7(9))
Beyond documentation, manufacturers have an active cooperation duty with market surveillance authorities. You must:
- Provide all requested information and documentation in the authority’s preferred language
- Actively cooperate on any action to eliminate non-compliance
- Participate in bringing products into compliance with accessibility requirements
- Respond promptly to all authority requests (delays can trigger enforcement action)
This cooperation is not optional – it’s a legal obligation that continues as long as your products remain on the market. Establish clear internal protocols for authority interactions, including designated compliance officers with decision-making authority and rapid translation capabilities.
Conclusion
EAA compliance for computer hardware manufacturers requires systematic planning and execution across design, manufacturing, and documentation processes. Start immediately with product assessment and gap analysis, as retrofitting existing designs takes considerable time. Working with accessibility and compliance experts like Accessible.org throughout ensures you follow best practices for compliance while minimizing business disruption.
Remember that June 28, 2025 deadline is now in effect. New products placed on the market after this date (or products with significant modifications) must be fully compliant.
Legal Disclaimer: This post represents our interpretation and analysis of the European Accessibility Act (EAA) and related accessibility requirements and obligations but does not constitute legal advice. While we strive for accuracy, Directives and their interpretation may vary by EU member state and change over time. Consult with legal counsel regarding your specific situation.
