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The European Accessibility Act: Key Implications for Consumer Hardware Manufacturers

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THE EAA AT A GLANCE

On 28 June 2025, the key requirements of Directive (EU) 2019/882 – also known as the European Accessibility Act or “EAA” – will take effect. The EAA is expected to lift barriers to accessibility across the EU, in turn improving inclusion and facilitating more independent living for people with disabilities (physical and mental) and individuals with other functional limitations (e.g., the elderly).

The EAA, which extends beyond traditional mobility-focused accessibility (i.e. accessibility of physical spaces) to cover digital accessibility, sets out minimum accessibility requirements for a wide range of products and services, including elements of public transportation services, consumer banking, and, importantly, consumer electronics and technology.

Consumer hardware manufacturers are particularly impacted by the requirements of the EAA; they will need to consider how their products may foreseeably be used by persons with disabilities, and must design their products in a way to accommodate such use.

In this article, we take a look at what the EAA requires from consumer device manufacturers, and what the future may hold.

KEY REQUIREMENTS FOR CONSUMER HARDWARE MANUFACTURERS

The EAA applies to a range of consumer hardware including everyday devices like smartphones, laptops and tablets, as well as a number of electronic products with which consumers regularly interact (such as payment terminals and ticket machines).

Annex I sets out general requirements applicable to all in-scope products and services, and also contains some further requirements for specific types of products only. The requirements under Annex I are generally ‘outcome-focussed’ i.e. they set out the results that must be achieved (e.g. that product labelling and instructions are “presented in an understandable way”), but do not impose detailed technical measures on how manufacturers achieve those results. Instead, by way of Annex II, the EAA lays out several non-binding examples of measures that may be implemented to meet the accessibility requirements (e.g. “using the same words in a consistent manner, or in a clear and logical structure, so that persons with intellectual disabilities can better understand it”).

Below, we outline some of the key requirements relevant to in-scope consumer hardware.

1. Accessibility in design

The design of consumer hardware must ensure that the products’ user interface and controls are easy to understand and can be operated by individuals of all abilities and limitations. For example, when a device uses visual elements, its interface must be rendered more navigable through the ability to customise magnification (e.g. enlarge text and zoom in on a particular image) as well as brightness and contrast. The manual controls of devices must similarly be accessible; for example, it is recommended for touch screen buttons to be bigger and well separated, and for buttons or switches to not require excessive force to operate the device, to ensure that the device can be used by individuals with motor impairments.

2. Compatibility with Assistive Technology

Assistive technologies are add-on features that are designed to improve a product’s functionality for people with disabilities. Such technologies could be physical hardware (such as hearing aids or specialist keyboards) or software (such as text-to-speech tools and voice recognition software). The EAA places various obligations on manufacturers to ensure their products are compatible and interoperable with assistive technologies.

3. Packaging and instructions

The EAA mandates that all information related to the use of products – including packaging, labelling, instructions (covering e.g., installation, maintenance, storage and disposal of the product), safety information and warnings – must be accessible to individuals with disabilities and those with functional limitations. For example, instructions and product warnings must be provided via more than one sensory channel (e.g. text, Braille and via audio). In respect of text-based information, the formatting, layout and spacing should ensure the information can be easily read by persons who are visually impaired (e.g. through large print and/or high-contrast text).

4. Accessible customer support

The EAA also requires that, where a manufacturer of a product provides customer support services (e.g., help desks, call centres, and technical support), the manufacturer must also provide support services relating to the product’s accessibility. In such cases, the support services on these topics must be offered via accessible means. This obligation would include, for example, offering support assistance in alternative formats that meet the needs of certain types of users (e.g., Braille documents for blind people or easy-to-read information for persons with limited cognitive, language and learning abilities).

The EAA undoubtedly presents manufacturers of in-scope consumer hardware with plenty to consider. In addition to keeping on top of harmonised standards (to the extent manufacturers wish to rely on these to presume conformity with the EAA), manufacturers must also:

  • Draw up compliant technical documentation;
  • Carry out conformity assessment procedures; and
  • Demonstrate compliance with applicable accessibility requirements by drawing up an EU declaration of conformity and affixing a CE mark to their products.

What’s more is that, where manufacturers have reason to believe their product is not in conformity with the EAA, they must inform national authorities and take appropriate corrective measures to bring the product into conformity or withdraw it from the market.

LOOKING AHEAD TO UNLOCK POSSIBILITY

Challenges:

Evidently, the EAA provides manufacturers with new obligations and risks to manage: a failure to meet the applicable accessibility requirements could lead to regulatory scrutiny, financial penalties, obligations to take corrective action, and could result in reputational damage. This means that product design, labelling and packaging, as well as product testing processes, will all need to be reviewed and potentially adapted to ensure that they are compliant with the EAA.

Opportunities:

Digital accessibility can also serve as an exciting opportunity. The EAA will effectively serve as a framework for manufacturers to ensure that their products are accessible to a far wider and more diverse consumer base. Adapting products to be compliant will require innovation. Manufacturers that embrace the spirit of the EAA will lead the way in creating products that are better for everyone. If done properly, compliance with the EAA will signal an inclusive and forward-thinking approach.

Additionally, the need for accessible design will inevitably lead to the development of features and technologies that benefit all users. For example, accessibility improvements like voice controls often enhance the user experience for all users, setting products apart in a competitive market.

Takeaway:

The need to comply with the EAA has transformed digital accessibility from a once-optional enhancement into a critical business need. To stay competitive in this rapidly evolving market, manufacturers in scope of the EAA must consider their products carefully and implement necessary adjustments to meet the new standards.

Our Digital Accessibility Team, composed of highly experienced global lawyers, offers unmatched expertise of digital accessibility requirements, emerging trends, and regulatory developments. With a focus on practical, solution-oriented advice, we guide clients through complex regulations and help them bring innovative, accessible products to market with confidence.

For future updates and insights, please visit our Global Digital Accessibility Hub.

Authored by Valerie Kenyon, Eshana Subherwal, Lorena Baltazar and Femi Williams.


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