The European Accessibility Act (EAA) has different requirements for products and services. In this guide, we’ll cover the primary accessibility requirements for products and product information. We’ll leave product information (think labels and instructions) for the end of this post.
The way this guide will work is we’ll first define what products mean under the EAA and then we’ll go through each of the primary 14 EAA product requirements and explain in plain language what it means. We’ll also add a few more relevant compliance details when it comes to product accessibility.
Table of Contents
EAA Products Definition
What exactly does a product mean under the EAA? First, here’s the official definition:
(2) ‘product’ means a substance, preparation, or good produced through a manufacturing process, other than food, feed, living plants and animals, products of human origin and products of plants and animals relating directly to their future reproduction;
In plain language, this means anything made through a manufacturing process, except for:
- Food and animal feed,
- Living plants and animals,
- Products made from humans (like blood or organs),
- Items from plants and animals that are specifically for creating more plants or animals in the future (like seeds or breeding animals).
So, “product” here covers most manufactured goods but leaves out these specific categories.
Annex 1, Section 1
Now let’s address the primary 14 product accessibility requirements starting with the general, overarching requirement.
User interface and functionality design:
The product, including its user interface, shall contain features, elements and functions, that allow persons with disabilities to access, perceive, operate, understand and control the product by ensuring that:
(a) when the product provides for communication, including interpersonal communication, operation, information, control and orientation, it shall do so via more than one sensory channel; this shall include providing alternatives to vision, auditory, speech and tactile elements;
This requirement means that if a product includes any kind of communication—like talking to others, operating controls, getting information, or helping with directions—it should not rely on only one sense (like sight or hearing). Instead, it must provide different ways to interact with it.
For example:
- If it has visual information, it should also provide audio or tactile options (like spoken instructions or vibrations).
- If it has sounds, it should also provide visual options (like captions or lights).
The goal is to make sure that people with different sensory needs—whether related to sight, hearing, speech, or touch—can still use the product effectively.
(b) when the product uses speech it shall provide alternatives to speech and vocal input for communication, operation control and orientation;
This requirement means that if a product relies on spoken commands or voice input (like voice-activated controls), it must also offer other ways to interact with it that don’t require speaking.
For instance:
- If you can control the product by speaking, there should also be options like buttons, text, or touch controls to achieve the same tasks.
- If the product gives information or directions through speech, it should also show this information visually (like on a screen) or through touch (like vibrations or braille).
The idea is to make sure that people who can’t speak or prefer not to use voice commands can still fully use the product.
(c) when the product uses visual elements it shall provide for flexible magnification, brightness and contrast for communication, information and operation, as well as ensure interoperability with programmes and assistive devices to navigate the interface;
This requirement means that if a product relies on visual elements (like screens, text, or images), it must offer ways to adjust those visuals to make them easier to see. Specifically, it should allow users to:
- Change the size of the visuals (magnification),
- Adjust brightness and contrast to make things clearer.
Additionally, the product should work well with assistive devices and software (like screen readers or magnification tools) to help people navigate and use the interface easily. This ensures that people with various visual needs can still access and interact with the product effectively.
(d) when the product uses colour to convey information, indicate an action, require a response or identify elements, it shall provide an alternative to colour;
This requirement means that if a product uses color to show information, prompt actions, ask for responses, or highlight elements, it must also offer a way to understand that information without relying on color alone.
For example:
- If a button turns red to signal an error, there should also be text, an icon, or a sound indicating the error.
- If different items are color-coded, there should be labels or symbols so users who can’t see color differences can still identify them.
This ensures that people with color vision deficiencies or who cannot rely on color cues can still use the product accurately.
(e) when the product uses audible signals to convey information, indicate an action, require a response or identify elements, it shall provide an alternative to audible signals;
This requirement means that if a product uses sounds (like beeps, alerts, or spoken instructions) to provide information, prompt actions, request responses, or identify certain elements, it must also offer another way to communicate that information without relying on sound alone.
For example:
- If there’s a beep to indicate a low battery, there should also be a visual alert, like a flashing icon or a message on the screen.
- If spoken instructions are given, they should also be available in text or as symbols.
This ensures that people who are deaf, hard of hearing, or unable to hear in certain situations can still receive important information and use the product correctly.
(f) when the product uses visual elements it shall provide for flexible ways of improving vision clarity;
This requirement means that if a product uses visual elements (like screens, images, or text), it must offer options to make these visuals easier to see for people with different vision needs.
For example:
- It might allow users to adjust text size, colors, or contrast.
- It could offer options to make images sharper or text clearer.
The goal is to ensure that people can adjust the visuals to improve clarity, making the product accessible to those with various vision levels.
(g) when the product uses audio it shall provide for user control of volume and speed, and enhanced audio features including the reduction of interfering audio signals from surrounding products and audio clarity;
This requirement means that if a product uses audio (like spoken instructions, alerts, or sounds), it must allow users to control and improve the audio experience. Specifically, it should provide:
- Volume control so users can make the sound louder or quieter.
- Speed control so users can slow down or speed up the audio if needed.
- Enhanced audio clarity, which could include features that make the sound clearer or easier to understand.
- Reduction of background noise from other devices or surroundings, helping users focus on the main audio.
The goal is to ensure users can hear and understand the audio comfortably, even in noisy environments or with personal preferences for sound settings.
(h) when the product requires manual operation and control, it shall provide for sequential control and alternatives to fine motor control, avoiding the need for simultaneous controls for manipulation, and shall use tactile discernible parts;
This requirement means that if a product requires hands-on operation (like pressing buttons, turning knobs, or using touch controls), it must be designed to accommodate users with limited hand dexterity or strength. Specifically, it should:
- Allow sequential control (one action at a time) rather than requiring multiple controls to be used at the same time, which can be challenging for people with limited mobility.
- Offer alternatives to fine motor control, meaning it should work even if a user can’t make small, precise movements.
- Use tactilely discernible parts, so buttons and controls are easy to identify by touch.
The goal is to make the product accessible to people with various motor abilities, ensuring they can operate it comfortably and accurately.
- (i) the product shall avoid modes of operation requiring extensive reach and great strength;
This requirement means that the product should be designed in a way that doesn’t require users to stretch too far or use a lot of physical strength to operate it.
For example:
- Controls should be positioned within easy reach for most users.
- Actions like pushing, pulling, or turning should not require excessive force.
The goal is to ensure that people of different physical abilities can use the product without strain or difficulty.
(j) the product shall avoid triggering photosensitive seizures;
This requirement means that the product should be designed to prevent visual elements that could trigger seizures in people with photosensitivity. Specifically, it should:
- Avoid flashing lights or patterns, especially those that blink at certain speeds or brightness levels known to cause seizures.
- Ensure any animations or transitions don’t create rapid or intense visual effects.
The goal is to make the product safe for users with photosensitivity, reducing the risk of seizures triggered by visual stimuli.
(k) the product shall protect the user’s privacy when he or she uses the accessibility features;
This requirement means that the product must ensure users’ privacy when they use accessibility features. Specifically, it should:
- Avoid revealing to others that accessibility features are being used, so users aren’t identified or singled out due to their needs.
- Protect any personal information or settings related to accessibility features from unauthorized access.
The goal is to respect and safeguard users’ privacy, allowing them to use accessibility features discreetly and securely.
Here are different ways to protect privacy with product design and functionality:
- Privacy Mode for Screen Readers:
- When a screen reader is activated, the product should disable or mask any visual indicators showing that it’s being used, especially in shared or public settings. For instance, when screen readers are on, no icons or labels should pop up that might reveal to others the accessibility setting in use.
- Confidentiality for Voice Assistants:
- Products using voice assistants should avoid loud or visible confirmations of voice commands if the user is in a public space. Instead, they could use subtle haptic feedback or private notifications on a connected personal device.
- Inconspicuous Visual Adjustments:
- If a product provides options for users to change font sizes, high-contrast modes, or color filters, it should do so in a way that doesn’t alter the interface in a way others can easily notice. For instance, adjustments could be applied in a personal user profile rather than globally on a shared device.
- Data Security for Personal Accessibility Settings:
- Products should store personalized accessibility settings (like preferred volume levels, speech speeds, or visual contrast preferences) in a secure, user-specific way. This could mean saving settings locally rather than in a shared space or in an encrypted profile only accessible by the user.
- Private Notifications for Accessibility Actions:
- When an accessibility feature is turned on, the product should avoid displaying notifications or indicators in shared interfaces. For example, a product that provides text-to-speech could activate the feature silently without showing an “accessibility mode” alert that others could see.
- Selective Data Sharing in Multi-User Environments:
- If the product is used by multiple people, it should avoid sharing data or usage history of accessibility features. For example, a shared device could allow accessibility settings to be saved to a personal profile without displaying those settings to other users.
(l) the product shall provide an alternative to biometrics identification and control;
This requirement means that if a product uses biometric identification (like fingerprint, face recognition, or voice recognition) for access or control, it must also provide another non-biometric option. This ensures that users who cannot or prefer not to use biometrics can still access and control the product.
For example:
- PIN or Password Entry: Offer a PIN or password entry option alongside biometric authentication, so users can choose either method to access the product.
- Physical Access Key: Provide an option to use a physical key, card, or token instead of biometric identification, especially for users who have difficulties with fingerprint or facial recognition.
- Alternative Input Device: Allow access through a compatible input device, like a keypad or touchscreen, for users who may not be able to use voice or fingerprint controls.
This approach ensures that the product remains accessible and usable by everyone, regardless of their ability to use biometric features.
(m) the product shall ensure the consistency of the functionality and shall provide enough, and flexible amounts of, time for interaction;
This requirement means that a product should be predictable in how it works and give users flexible, sufficient time to complete tasks. Specifically:
- Consistent Functionality: All actions and controls should work the same way throughout the product, so users can rely on familiar patterns and won’t need to relearn different controls or interactions for similar tasks.
- Flexible Time for Interaction: If the product requires actions within a certain time frame (like filling out a form or reading information before it disappears), it should offer options to extend or remove time limits. For example, users could be given the choice to disable timeouts or to receive a reminder before a session expires.
This ensures that users of all abilities can interact with the product confidently and at their own pace, without feeling rushed or facing unexpected changes in functionality.
(n) the product shall provide software and hardware for interfacing with the assistive technologies;
This requirement means that the product must be compatible with various assistive technologies (AT) and provide both the software and hardware support necessary for these tools to work effectively. Specifically, it should:
- Support AT Integration: Ensure compatibility with common assistive technologies, such as screen readers, magnifiers, alternative input devices (like switch controls), and voice recognition software.
- Provide Necessary Hardware Interfaces: Include ports, connectors, or wireless compatibility that allows physical assistive devices (like braille displays or adaptive keyboards) to connect to the product.
- Software Accessibility APIs: Use accessibility APIs and standards within the software so assistive technology can interpret and interact with the product’s content and controls accurately.
The goal is to make sure that users who rely on assistive technologies can use the product seamlessly, without needing additional adapters or struggling with compatibility issues.
This section now switches into sector-specific requirements for self-service terminals, e-readers, and consumer terminal equipment.
(o) the product shall comply with the following sector-specific requirements:
(i) self-service terminals:
- shall provide for text-to-speech technology;
- Shall allow for the use of personal headsets;
- Where a timed response is required, shall alert the user via more than one sensory channel;
- Shall give the possibility to extend the time given;
- Shall have an adequate contrast and tactilely discernible keys and controls when keys and controls are available;
- Shall not require an accessibility feature to be activated in order to enable a user who needs the feature to turn it on;
- When the product uses audio or audible signals, it shall be compatible with assistive devices and technologies available at Union level, including hearing technologies such as hearing aids, telecoils, cochlear implants and assistive listening devices;
(ii) e-readers shall provide for text-to-speech technology;
(iii) consumer terminal equipment with interactive computing capability, used for the provision of electronic communications services:
- Shall, when such products have text capability in addition to voice, provide for the handling of real time text and support high fidelity audio;
- Shall, when they have video capabilities in addition to or in combination with text and voice, provide for the handling of total conversation including synchronised voice, real time text, and video with a resolution enabling sign language communication;
- Shall ensure effective wireless coupling to hearing technologies;
- Shall avoid interferences with assistive devices;
(iv) consumer terminal equipment with interactive computing capability, used for accessing audio visual media services shall make available to persons with disabilities the accessibility components provided by the audiovisual media service provider, for user access, selection, control, and personalisation and for transmission to assistive devices.
Product Information Requirements
There are also accessibility requirements when it comes to information about the product (e.g., packaging, labels, instructions, etc.). Let’s go through these now (for reference, these are in Annex I, Section I).
- Requirements on the provision of information:
(a) the information on the use of the product provided on the product itself (labelling, instructions and warning) shall be:
(i) made available via more than one sensory channel;
This means the product’s information, like labels, instructions, and warnings, must be presented in more than one way so people with different abilities can access it. For example:
- Text and Symbols: Use both written words and icons or symbols.
- Audio and Visual Cues: Provide spoken instructions or sounds along with printed text.
This way, if someone can’t read the text, they can still understand the product’s use through another form, like listening.
(ii) presented in an understandable way;
The requirement here is the product’s information should be clear and easy to understand for everyone. This means:
- Simple Language: Avoid complex words or jargon so people of all reading levels can understand it.
- Clear Layout: Organize the information logically and use easy-to-read fonts and colors.
The goal is to make sure anyone can quickly grasp how to use the product safely and effectively.
(iii) presented to users in ways they can perceive;
The requirement here is the product’s information must be shared in formats that users can detect, regardless of their abilities. This means:
- Accessible Formats: Use formats that work for people with different sensory needs, such as large print, Braille, or audio.
- Compatible with Assistive Devices: Ensure the information can be read or heard with tools like screen readers or hearing aids.
This helps make sure everyone, including those with disabilities, can perceive and understand the product information.
(iv) presented in fonts of adequate size and suitable shape, taking into account foreseeable conditions of use, and using sufficient contrast, as well as adjustable spacing between letters, lines and paragraphs;
This means the product’s information must use fonts that are easy to read, considering how and where it might be used. This includes:
- Font Size and Shape: Large enough and with a clear, simple shape to be readable in different settings, like low light or on a moving vehicle.
- Contrast: Strong contrast between text and background to make reading easier, even for people with visual impairments.
- Adjustable Spacing: Enough space between letters, lines, and paragraphs to improve readability, especially for those with dyslexia or low vision.
These design choices help ensure that everyone can read and understand the information comfortably.
(b) the instructions for use of a product, where not provided on the product itself but made available through the use of the product or through other means such as a website, including the accessibility functions of the product, how to activate them and their interoperability with assistive solutions shall be publicly available when the product is placed on the market and shall:
(i) be made available via more than one sensory channel;
Here, this means means that instructions provided separately from the product—such as online or in a digital format—must be accessible in different ways to accommodate various sensory needs. This could include:
- Text and Audio Options: Providing both written instructions and audio recordings for people who may have difficulty reading.
- Visuals and Descriptions: Using images or videos alongside descriptive text for clearer understanding.
This ensures that all users, including those with visual or hearing impairments, can access and understand the instructions through methods that suit their sensory abilities.
(ii) be presented in an understandable way;
This means that the instructions should be clear, straightforward, and easy for anyone to follow. This includes:
- Simple Language: Avoiding technical jargon and using plain, everyday words.
- Step-by-Step Format: Organizing instructions in a logical, step-by-step manner to make it easy to follow.
- Consistent Terminology: Using the same terms consistently to avoid confusion.
The goal is to ensure that anyone, regardless of their background or reading level, can easily comprehend how to use the product and its accessibility features.
(iii) be presented to users in ways they can perceive;
This means that the instructions should be accessible to people with various sensory abilities. This includes:
- Formats for Different Needs: Providing instructions in formats like large print, Braille, or screen-reader compatible text for people with visual impairments.
- Audio and Visual Options: Ensuring instructions are available as both text and audio, so users who can’t read printed materials can listen instead.
The objective is to make sure everyone, regardless of sensory limitations, can access and understand the instructions.
(iv) be presented in fonts of adequate size and suitable shape, taking into account foreseeable conditions of use and using sufficient contrast, as well as adjustable spacing between letters, lines and paragraphs;
This requirement means that the instructions should be designed to be easy to read in various situations. Specifically, this includes:
- Font Size and Shape: Using large, simple fonts that are readable under different conditions, such as in low light or on small screens.
- High Contrast: Ensuring there’s a clear contrast between text and background so that people with visual impairments can read it easily.
- Spacing: Providing enough space between letters, lines, and paragraphs, with adjustable spacing if possible, to improve readability for those with visual or reading challenges.
The goal is to make the instructions accessible and comfortable to read for all users, regardless of setting or personal needs.
(v) with regard to content, be made available in text formats that can be used for generating alternative assistive formats to be presented in different ways and via more than one sensory channel;
This requirement means that the instructions should be provided in text formats that can be easily converted into other accessible formats for different sensory needs. This includes:
- Assistive Technology Compatibility: Using formats that work with screen readers, Braille displays, or text-to-speech software, allowing users to choose the format that suits them best.
- Flexible Output Options: Making the text easy to convert into alternative formats, like audio files or large print, so it can be presented in multiple ways.
The goal is to ensure that the instructions are versatile and can be adapted to meet the needs of users with various disabilities.
(vi) be accompanied by an alternative presentation of any non-textual content;
This requirement means that any non-text content (like images, icons, or videos) in the instructions must have a text-based alternative. This includes:
- Text Descriptions for Images: Providing written descriptions or alt text for images, so users with visual impairments can understand visual information.
- Captions and Transcripts for Audio/Video: Including captions for videos and transcripts for audio content, ensuring that users with hearing impairments can access the information.
The goal is to make sure all information, regardless of format, is accessible to everyone.
(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;
This requirement means that the instructions must include a clear description of the product’s user interface, detailing how to handle and control it, as well as any feedback it provides. Specifically, the instructions should:
- Describe Interaction Points: Explain how users can operate the product (e.g., buttons, touchscreens) and how it responds to inputs.
- Outline Input and Output Features: Indicate what input methods (like touch, voice) and output formats (like sound, visual cues) are available.
- Reference Accessibility Features: For each interface feature required in “point 2,” the instructions should clarify if and how the product meets those accessibility standards.
The purpose is to help users understand how to interact with the product and to clarify its accessibility features or limitations.
(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;
This requirement means the instructions must describe any accessibility features specifically designed to help people with disabilities. For each accessibility function required in “point 2,” the instructions should:
- Explain Accessibility Features: Describe how the product’s functions address specific needs, such as adjustable sound levels, screen magnification, or tactile feedback.
- Clarify Availability of Each Feature: Clearly state which accessibility features are provided and which are not, based on the criteria listed in point 2.
- Detail How to Activate and Use These Features: Offer guidance on enabling and using these features so users can easily benefit from them.
The purpose is to ensure users with disabilities understand how the product can meet their needs and know exactly what accessibility functions are included.
(ix) include a description of the software and hardware interfacing of the product with assistive devices; the description shall include a list of those assistive devices which have been tested together with the product.
This requirement means that the instructions must explain how the product interacts with assistive devices and should specifically:
- Describe Compatibility: Provide information on how the product’s software and hardware can connect or work with assistive devices, like screen readers, hearing aids, or Braille displays.
- List Tested Devices: Include a list of assistive devices that have been tested with the product, confirming compatibility and functionality.
This ensures that users know which assistive devices are compatible and reliable when used with the product.
Notes
Section VII, Functional performance criteria provides for examples of how to make products and services EAA compliant when the requirements named above do not address one or more functions “do not address one or more functions of the design and production of products or the provision of services those functions or means shall be accessible by complying with the related functional performance criteria.”
Importantly, “Those functional performance criteria may only be used as an alternative to one or more specific technical requirements, when these are referred to in the accessibility requirements, if and only if the application of the relevant functional performance criteria complies with the accessibility requirements and it determines that the design and production of products and the provision of services results in equivalent or increased accessibility for the foreseable use by persons with disabilities.”
Refer to Section VII for the examples.
Summary
We’ve now covered the 14 primary product accessibility requirements along with packaging accessibility requirements.. Remember, that there are certain sector-specific requirements.
If you need help with making your products accessible, we have experts in physical accessibility who can help with EAA compliance. Our services include audits, remediation, user testing, documentation, training, and consulting.
Feel free to contact us if you need help and we’ll be with you shortly.
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.
