ASPIRE papers

So, we know that we need to supply accessibility information. Good start. Let’s dive a little deeper and explore the annexes of the legislation. Everyone reads the annexes of 24,855-word legal documents, right? Oh.

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Let’s start at the beginning with Annex I. This annex deals with the accessibility requirements for products and services. Section I of Annex 1 relates to general accessibility requirements related to all products. So, this section focuses on products. Services are dealt with in Section II (something to look forward to later).

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Products refer to things like ATMs and ticketing machines and other exciting things that you’ll encounter at airports whilst waiting for your flight. They also relate ebook readers (something else you may encounter at an airport waiting for your flight).

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Essentially, ebook readers need to provide “information on the use of the product on the product itself” or “instructions for use of a product…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.”

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If we return to our shaky Star Wars metaphor, this is like Luke Skywalker learning to use his lightsaber as the Millenium Falcon races through space. Obi Wan Kenobi is essentially an instruction manual. With a beard.

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At this point, it’s probably worth mentioning that ebooks are considered a service rather than a product. But it doesn’t mean that you shouldn’t include accessibility information in your ebook file. This is known as metadata. Far cleverer people have discussed metadata issues around accessibility and I direct you to EDItEUR and their fantastic  guides to ONIX and Thema for teachings in the ways of the metadata force. For the relevant EAA text, see Section IV, (f) (v) “making them discoverable by providing information through metadata about their accessibility features.”

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CONCLUSION: if you make/distribute ebook readers in the EU, you’ll need to provide the information about the e-reader’s accessibility features.

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STAR WARS CONCLUSION: If you have an electronic device, it’s best to have a Jedi explain it to you and talk you through the Dark Side of the Force.

 

THE RELEVANT TEXT FROM THE EAA:

 

ANNEX I: ACCESSIBILITY REQUIREMENTS FOR PRODUCTS AND SERVICES. Section I: General accessibility requirements related to all products covered by this directive in accordance with Article 2(1).

Products must be designed and produced in such a way as to maximise their foreseeable use by persons with disabilities and shall be accompanied where possible in or on the product by accessible information on their functioning and on their accessibility features.

1. Requirements on the provision of information:

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     A) the information on the use of the product provided on the product itself (labelling, instructions and warning) shall be:

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     (i) made available via more than one sensory channel;

     (ii) presented in an understandable way;

     (iii) presented to users in ways they can perceive;

     (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;

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     (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:

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     (i) be made available via more than one sensory channel;

     (ii) be presented in an understandable way;

     (iii) be presented to users in ways they can perceive;

     (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;

     (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;

     (vi) be accompanied by an alternative presentation of any non-textual content;

     (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;

     (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;

    (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.

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DEFINITION: E-readers are defined as follows: e-reader’ means dedicated equipment, including both hardware and software, used to access, navigate, read and use e-book files. (Article 3, Clause 42). This definition may not apply to ligthsabers.