This is part 2 (distributor) in a series of hypotheticals designed to show the steps to take for compliance with the European Accessibility Act (EAA).
Kiosk Tech Distribution is a European distributor of self-service terminals, including payment terminals, ATMs, ticketing machines, and check-in kiosks. As a distributor of self-service terminals, Kiosk Tech must ensure compliance with the European Accessibility Act (EAA) for products placed on the market after June 28, 2025.
The EAA requires that distributors verify accessibility compliance only for products first placed on the EU market after the enforcement date. Products that were first placed on the market before June 28, 2025 can continue to be distributed without EAA verification requirements, regardless of when they enter a distributor’s inventory.
Here’s the general path forward to EAA compliance for Kiosk Tech.
Step 1: Identify Which Products Fall Under EAA
Begin by inventorying all self-service terminal types in your distribution portfolio. Under Article 2(1)(b) of the EAA, covered self-service terminals include:
- Payment terminals (all types)
- Automated teller machines (ATMs)
- Ticketing machines (transport, events, parking)
- Check-in machines (airports, hotels, clinics)
- Interactive self-service terminals providing information
Remember, we’re only focused on terminals that are first placed on the EU market after June 28, 2025.
Note that terminals installed as integrated parts of vehicles, aircraft, ships, or rolling stock are excluded. Review your product catalog to separate covered terminals from excluded ones.
Step 2: Verify Compliance Documentation from Manufacturers
As a distributor, your primary obligation under Article 10(2) is verifying that products have proper compliance documentation before making them available on the market. For each product line:
- Confirm CE marking is present
- Verify EU Declaration of Conformity exists
- Check instructions and safety information are available in appropriate languages for your target Member State(s)
- Ensure manufacturer identification is clearly indicated (Article 7(5) and (6))
- Verify importer compliance labeling if applicable (Article 9(4))
Key accessibility requirements from Annex I for self-service terminals include:
- Text-to-speech technology capability
- Allowance for personal headset use
- Multi-sensory alerts when timed responses are required
- Ability to extend time limits
- Adequate contrast and tactilely discernible keys/controls
- No requirement to activate accessibility features to enable them
- Privacy protection when using accessibility features
Step 3: Establish Supplier Verification Procedures
Create systematic processes to verify manufacturer and importer compliance before accepting new products:
Documentation checklist:
- CE marking verification protocol
- EU Declaration of Conformity review
- Technical documentation availability confirmation (you don’t need copies, just confirmation it exists)
- Language requirement verification for target markets
Supplier assessment:
- Manufacturer’s track record with accessibility
- Quality of compliance documentation
- Responsiveness to compliance queries
- Corrective action history
Working with accessibility compliance experts can help establish robust verification procedures that protect your business while ensuring only compliant products enter your supply chain.
Step 4: Understand When You Become a Manufacturer
Under Article 11, be aware that you assume manufacturer obligations if you:
- Place products on the market under your own name or trademark
- Modify products already placed on the market in ways that affect compliance with EAA requirements
If either situation applies, you must fulfill all manufacturer obligations under Article 7, including conformity assessments and technical documentation creation.
Step 5: Implement Storage and Transport Protocols
Per Article 10(4), develop procedures ensuring products maintain compliance throughout distribution:
Storage requirements:
- Environmental conditions that preserve accessibility features
- Protection of tactile surfaces and markings
- Safeguarding of electronic components
- Maintain association between products and their compliance documentation
Transport protocols:
- Packaging that protects accessibility features
- Handling instructions for sensitive components
- Procedures to ensure documentation travels with products
- Damage inspection procedures
Step 6: Create Market Surveillance Response Systems
Establish procedures for responding to market surveillance authorities per Article 10(6):
Information management:
- System to quickly provide all required information and documentation
- Translation capabilities for authority communications
- Designated compliance officer for authority interactions
- Cooperation protocols for compliance actions
Response protocols:
- Immediate response procedures for authority requests
- Documentation provision in languages authorities can understand
- Action plans for eliminating non-compliance
- Record-keeping of all authority interactions
Step 7: Develop Non-Compliance Procedures
Create clear processes for handling non-compliant products per Articles 10(3) and 10(5):
Detection procedures:
- Regular compliance spot checks
- Customer complaint monitoring
- Authority notification tracking
- Manufacturer/importer alert systems
Response actions:
- Immediate stop-distribution protocols for non-compliant products
- Notification to manufacturer or importer and market surveillance authorities
- Ensure corrective measures are taken (bring into conformity or withdraw)
- Detailed reporting of non-compliance and corrective measures
- Customer notification processes where applicable
Professional compliance services can provide templates and guidance for developing these critical procedures, ensuring swift and appropriate responses to non-compliance issues.
Step 8: Maintain Supply Chain Identification Records
Implement record-keeping systems as required by Article 12:
Required identification capabilities:
- Identify any economic operator who has supplied you with products
- Identify any economic operator to whom you have supplied products
- Maintain these identification capabilities for 5 years after being supplied
- Maintain these identification capabilities for 5 years after supplying
Important clarification: Unlike manufacturers and importers, distributors are NOT required to retain copies of EU declarations of conformity or technical documentation. You only need to verify these exist and maintain records of your supply chain partners.
Recommended practices:
- Digital database of all suppliers and customers
- Product tracking by batch/serial numbers
- Date records for all transactions
- Quick retrieval systems for authority requests
Step 9: Train Staff and Monitor Compliance
Ensure all relevant staff understand EAA requirements:
Training programs:
- EAA requirements overview for distributors
- Product identification procedures
- Documentation verification protocols
- Understanding Article 11 (when distributors become manufacturers)
- Non-compliance response procedures
- Authority interaction guidelines
Ongoing monitoring:
- Regular internal audits
- Supplier compliance reviews
- Customer feedback analysis
- Regulatory update tracking
- Continuous improvement processes
Conclusion
EAA compliance for self-service kiosk distributors centers on verification, vigilance, and proper supply chain management. While distributors don’t bear the same design and documentation burdens as manufacturers or importers, they serve as crucial gatekeepers ensuring only compliant products reach European markets.
Key points to remember:
- You must verify compliance documentation exists (but don’t need to retain copies)
- You only need to track supply chain partners for 5 years, not maintain all documentation
- Be aware of situations where you might assume manufacturer obligations
- Storage and transport conditions must not compromise product accessibility
The June 28, 2025 deadline is now in effect. All self-service terminals first placed on the EU market after this date must have proper compliance documentation. Working with accessibility and compliance experts like Accessible.org throughout this process ensures you meet all distributor obligations while building supplier relationships based on excellent execution.
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.
