Harmonized Standards and Technical Specifications

Harmonized standards play a crucial role in the implementation of the European Accessibility Act (EAA). They provide technical means to meet the accessibility requirements and create a presumption of conformity, making it easier for economic operators to demonstrate compliance with the directive.

Article 15 of the EAA establishes the framework for using harmonized standards and technical specifications to assess the conformity of products and services with the accessibility requirements set forth in the directive.

Harmonized standards are European standards that have been developed by recognized European Standards Organizations (ESOs) such as CEN, CENELEC, or ETSI, following a standardization request from the European Commission.

Under the EAA, products and services that comply with harmonized standards (or parts thereof), whose references have been published in the Official Journal of the European Union, benefit from a presumption of conformity with the accessibility requirements covered by those standards.

This means that when a manufacturer or service provider applies a harmonized standard correctly, authorities must presume that the product or service complies with the accessibility requirements covered by that standard.

Key Harmonized Standards for Accessibility

Some important harmonized standards related to accessibility include:

• EN 301 549: "Accessibility requirements suitable for public procurement of ICT products and services" - This standard covers a wide range of digital accessibility requirements and is frequently referenced for EAA compliance
• EN 17161: "Design for All - Accessibility following a Design for All approach in products, goods and services - Extending the range of users"
• EN 17210: "Accessibility and usability of the built environment - Functional requirements"
• EN 82079-1: "Preparation of instructions for use - Structuring, content and presentation"

In the absence of published harmonized standards, the EAA allows for the use of technical specifications to assess conformity with the accessibility requirements.

According to Article 15 of the EAA, the Commission may adopt implementing acts establishing technical specifications that meet the accessibility requirements of the directive. These implementing acts are adopted in accordance with the examination procedure referred to in Article 27(2) of the EAA.

Products and services that conform with these technical specifications, or parts thereof, are presumed to conform with the accessibility requirements of the EAA covered by those technical specifications.

Development of Technical Specifications

Technical specifications are developed when:

• There is an undue delay in the standardization procedure
• No request to develop a harmonized standard has been made
• The Commission observes shortcomings in harmonized standards

Before adopting technical specifications, the Commission conducts consultations with relevant stakeholders, including organizations representing persons with disabilities.

Utilizing harmonized standards and technical specifications offers several benefits to economic operators:

• Presumption of Conformity: The most significant benefit is the legal presumption of conformity with the EAA requirements
• Reduced Compliance Burden: Standards provide clear technical guidance, reducing the need for extensive interpretation of legal requirements
• Market Recognition: Using recognized standards can enhance market acceptance of products and services
• Consistency: Standards promote a consistent approach to accessibility across different products and services
• Risk Reduction: Following standards reduces the risk of non-compliance findings by market surveillance authorities

For more information about conformity assessment, see theConformity Assessment page.

The EAA recognizes that harmonized standards may not always cover all aspects of the accessibility requirements. In such cases:

• The presumption of conformity applies only to those aspects covered by the harmonized standard
• For remaining aspects, economic operators must demonstrate compliance through other means
• A standard may be cited in the Official Journal with restrictions if it does not fully address all requirements

This allows for flexibility while still promoting the use of standards where they are available and appropriate.

To effectively use harmonized standards for compliance with the EAA:

1. Identify Relevant Standards: Check the Official Journal of the European Union for published references to harmonized standards under the EAA
2. Assess Applicability: Determine which standards apply to your specific product or service
3. Obtain Standards: Purchase or access the standards from the relevant standardization organizations (CEN, CENELEC, ETSI)
4. Apply Standards Correctly: Ensure proper application of the standards during design, development, and testing
5. Document Compliance: Maintain documentation showing how the standards have been applied
6. Monitor Updates: Stay informed about updates or revisions to standards that may affect compliance

It's important to note that the list of harmonized standards under the EAA will evolve over time as new standards are developed and existing ones are revised.

The European standardization process is ongoing, with new standards continuously being developed to address emerging technologies and refine existing requirements. For the EAA:

• The European Commission works with European standardization organizations to identify gaps in standards coverage
• Standardization requests (mandates) are issued to develop new harmonized standards where needed
• Stakeholders, including organizations representing persons with disabilities, are involved in the standards development process
• Technical specifications may be developed as interim measures while standardization work is in progress

Economic operators should regularly check for updates to ensure they are using the most current standards for compliance.