Accessibility

An elderly couple seating on a bench, overlooking the sea

It is a basic consumer right to have access to products and services. Discrimination exists if older people, and persons with disabilities, cannot use today’s mainstream consumer products and services. ANEC believes that standards are a suitable tool to overcome this discrimination if Design for All (DfA) principles are applied. Design for All means designing mainstream products and services so that as many people as possible can use them, regardless of age or ability.

The ANEC Accessibility Working Group unites experts from both the consumer movement and organisations representing older people and persons with disabilities. Its work is based on the ANEC Policy Statement on Design for All.

Work areas

1) Safety and Usability of products and services for older people and people with disabilities

For several years now, ANEC has lobbied for standards to be used to enhance the safety and usability of products and services for older people and persons with disabilities. If standards for mainstream products and services do not meet the requirements of all consumers, it means that many products and services cannot be used by a large part of the population, despite the current demographic trends that include an Ageing Europe.

As a result of ANEC‘s lobbying, several working groups focusing on the accessibility of product and services standards have been set up such as, CEN/CENELEC JTC 11 'Accessibility in the built environment, 'CEN/BT/WG 213 ‘Strategic Advisory Group on Accessibility (SAGA)’ and CEN-CENELEC JTC 12 'Design for All'.

ISO/IEC Guide 71 (CEN-CENELEC Guide 6)

ANEC contributed to revising ISO/IEC Guide 71 ‘Guide for addressing accessibility in standards', published in December 2014 by the International Organisation for Standardisation (ISO), International Electrotechnical Commission (IEC) and International Telecommunication Union (ITU). The publication of the revised Guide 71 was accompanied by a policy statement from IEC, ISO & ITU on standardisation and accessibility. Both documents are available on the ISO website.

The document outlines the developments in thinking (on design, and accessibility itself) since publication of the previous version in 2001. It goes on to discuss the various approaches to accessibility in more detail, acknowledging that there is no single definition in current use worldwide.

In 2015, on the occasion of the International Day of Persons with Disabilities celebrated on 3 December, ANEC published guidance on the use of ISO/IEC Guide 71:2014 and CEN-CENELEC Guide 6:2014 “Guide for addressing accessibility in standards”.

ISO/IEC Guide 71 'Guide for addressing accessibility in standards' was also submitted to systematic review until 3 March 2020. Given Guide 71 remains valid, ANEC wants to see the Guide confirmed. The Guide is adopted as the identical CEN-CENELEC Guide 6. In November 2020 we welcomed confirmation of ISO/IEC Guide 71 'Guide for addressing accessibility in standards' which had been submitted to the Systematic Review. We were a key contributor to the revision of Guide 71 in 2014, the first deliverable to be triple-logoed by ISO, IEC & ITU. CEN-CENELEC Guide 6 was also confirmed.

In 2022, ANEC contributed to the CEN/BTWG 213 SAGA Guidelines for accessible Word and PDF documents. SAGA Guidelines for Accessible Word and PDF documents have been made available on CEN BOSS, under Drafting Guidance and on the website. In 2024, ANEC continued to advocate for increased accessibility of the CEN-CENELEC ways of working (eg: templates, platforms and documents) to allow active participation in standardisation of persons with disabilities. ANEC was able to federate support from the CEN BT WG 213 SAGA participants leading CCMC to commit to bring the issue to the attention of ISO IT department (developing the IT tools). ANEC also convinced CEN TC 293 ‘Assistive technologies’ to address the issue.

Reflecting consumers’ needs in vulnerable situations and mainstreaming accessibility in EU policies and standardisation

ANEC is also working to push the European Institutions to put the needs of vulnerable consumers (children, persons with disabilities and older people) at the centre of EU policies. Based on our position paper of December 2011, we influenced the European Parliament Report on Vulnerable Consumers adopted in May 2012 and the European Commission Communication, “Consumer Agenda”.

On 7 February 2013, the European Consumer Consultative Group (ECCG) approved an ECCG Opinion on consumers and vulnerability, drafted by ANEC and BEUC based on ANEC’s position paper on Vulnerable Consumers of December 2011. The aim of the Opinion is to provide a better understanding and increased consideration for all consumers’ needs so as to develop an inclusive and targeted policy approach by the European Commission, and in particular in their response to the European Parliament Resolution on a strategy for strengthening the rights of vulnerable consumers of May 2012.

In February 2014, the Parliament and Council adopted several product safety directives under revision (“recast”) such as the Low Voltage Directive and the Lifts Directive to align them to the New Legislative Framework (NLF). ANEC lobbied for the concept of foreseeable use to be included in the legislation in order to have the needs of all consumers taken into account. We believe consumers can be effectively protected only if their (foreseeable) behaviours are duly taken into account by manufacturers when designing products. MEPs and Member States took on board our call to consider real consumer behaviour when setting safety requirements. We also welcomed the need for standards supporting the Low Voltage Directive to respect the UN Convention on the Rights of Persons with Disabilities.

In April 2014, the revised R&TTE Directive, now called Radio Equipment Directive (RED) was published in the Official Journal of the European Union, after the agreement of the European Parliament and the Council of Ministers. The concept of “foreseeable use” must be taken into account for conformity assessment, as proposed by ANEC, to protect vulnerable consumers.

In 2023, ANEC proposed a similar amendment for the revision of the Machinery Directive, which was accepted. Therefore, the draft standardisation request for the new Machinery Regulation, is covering this aspect too, based on our comments.

The above Directives set the legal basis for safety and accessibility standards to meet the needs of all consumers. New standardisation requests were approved in 2016 and the work started in 2017 should continue on household appliances (CENELEC TC 61) and lifts (CEN TC 10). In 2022, we were pleased to see that the revision of EN 81-70:2021/FprA1 on accessibility of lifts was approved , thus solving the ANEC’s appeal lodged in 2017. In addition, ANEC proposed a fuller revision of the standard to address wider accessibility issues, to which we are contributing.

‘Design for All’ standard

In October 2018, ANEC welcomed the approval of EN 17161 'Design for All - Accessibility following a Design for All approach in products, goods and services - Extending the range of users'. This standard was prepared by CEN-CENELEC Joint Technical Group (JTG) 12 ‘Design for All’ in response to mandate M/473 to include ‘Design for All’ in relevant standardisation initiatives, and in training material on accessibility standardisation. ANEC campaigned for the adoption of the standard and contributed significantly to its drafting. A Design for All approach can maximise the range of potential users of products, goods and services, and so increase market share. It can also increase the proportion of the population, including persons with disabilities, able to participate fully and independently in society. The accessibility of products, goods and services achieved by Design for All therefore represents a win-win for all citizens and organisations.

The standard was published in March 2019 and on 21 May 2019, ANEC, together with the National Standards Authority of Ireland and the European Disability Forum, hosted a webinar on the origins of the M/473 and the purpose of EN 17161, attended by more than 100 persons.

EN 17161 'Design for All – Accessibility following a Design for All approach in products, goods and services – Extending the range of users', should be revised in 2023 to become a Harmonised Standard to implement the European Accessibility Act.

The Protocol on accessibility following a DfA approach in standardisation

The protocol helps standardisers to decide whether and how accessibility following a Design for All approach should be addressed when reviewing an existing standard or developing a new standardisation project. The Protocol can be used at any stage of the standardisation process.

A series of publicly available documents explains the process and shows when the inclusion of accessibility following a Design for All approach could be relevant, with examples of context of use, environmental and human limitations. The Protocol was updated in January 2022.

Related links:

CEN-CENELEC Protocol for Accessibility.

CEN-CENELEC manual and protocol forms.

ANEC contribution to the European Accessibility Act

On 2 December 2015, the Commission published its long-awaited proposal for a directive on accessibility requirements for certain products and services (referred to as the European Accessibility Act or EAA). For many years, ANEC has been pressing for regulatory action to increase access to everyday products and services for consumers of all ages and abilities. Hence, in a press release, ANEC welcomed the European Commission’s proposal to facilitate the accessibility of products and services through standards.

In February 2016, ANEC sent preliminary comments on the proposed directive, in response to a consultation launched by the Commission. In September 2017, the European Parliament adopted the EAA proposal.

The role of standards was agreed to remain the same (presumption of conformity to legal requirements), in line with our position. With European standardisation being the preferred option, Parliament and Council agreed to give the Commission the possibility to adopt technical specifications in specific cases and delegated acts with binding requirements in very justified cases.

In September 2018, ANEC, the European Disability Forum (EDF), AGE Platform Europe and 17 other organisations co-signed an open letter urging Member States to improve the EAA proposal ahead of the next EU interinstitutional negotiations. We called on EU leaders to agree on an ambitious Act before 3 December 2018, the European Day of Persons with Disabilities.

On 8 November 2018, the provisional agreement on the EAA was finally reached by the Institutions after much discussion. The agreement was then submitted to the Council's Permanent Representatives Committee (COREPER) for approval. The Parliament voted in plenary session, with the Council concluding the adoption process.

ANEC welcomed the approval by the European Parliament and Council and the publication of the European Accessibility Act in the Official Journal of the European Union in June 2019. The Directive will apply to several products and services (eg: computers, e-books, self-service terminals, delivery of transport service information, including real-time travel information, consumer banking services, etc.) placed on the market after 28 June 2025. By 28 June 2022 the member states shall adopt and publish the laws, regulations and administrative provisions necessary to comply with this Directive. Harmonised standards will have to be developed to provide presumption of conformity with the legal requirements.

After many years of lobbying, this proves a significant achievement for ANEC and the disability movement.

2) Access and usability of the built environment

A young person seated in a wheelchair and two young persons seated on a bench cheerfully chatting altogether

2021 was a landmark year for Accessibility and usability of the built environment as CEN and ISO published their new Standards on the topic and we are delighted to have played a key role in their development.

ANEC welcomed the ISO standard on access to the built environment, ISO 21542 “Building Construction – Accessibility and usability of the built environment”, published in February 2012. Since work started in 2005, ANEC contributed to drafting of ISO 21542, the purpose of which is to define how the built environment should be designed, constructed and managed in order for people to have independent means of access and egress, irrespective of their ages or abilities. ANEC was able to ensure the standard would not replace national standards that required higher levels of accessibility. In 2017, ISO TC 59 started to revise ISO 21542, in line with the ANEC position. ANEC participates in the revision of the standard, bearing in mind that within Mandate M/420, ISO 21542 is recommended as the basic accessibility standard for the built environment. At the end of 2020 the final draft was delivered to ISO/CS to prepare the Final Voting draft and the FDIS 21542 stage started in the first quarter, i.e. February of 2021. ANEC supported the approval of ISO/FDIS 21542 (Ed 2), as it represents a more advanced state-of-the-art concept on the accessibility and usability of new buildings worldwide. We did nevertheless submit editorial comments, as a few requirements seem too low compared with existing national accessibility standards in Europe. We have proposed data is collected on these aspects and considered at the next review of the standard. In April 2021, the standard was adopted at international level. At the end of 2016, the second phase of M/420 on accessibility requirements for public procurement in the built environment started. ANEC was a Project Leader of the team developing the standards.

On 5 June 2019, ANEC supported the adoption of prEN 17210 'Accessibility and usability of the built environment – Functional requirements' at the CEN-CLC-UNE Workshop ‘M/420 access to the built environment’. The aim of the standard is to help implement UN Convention on Rights of persons with disabilities obligations for Member States. The standard can be used as criteria for awarding public contracts and assisting public procurers. It is also providing an educational function which can be useful for architects who have not enough knowledge in this rather new topic. EN 17210 “Accessibility and usability of the built environment – Functional requirements” was published on the CEN Websites on 31 January 2021. ANEC, who was involved in the drafting of the standard warmly welcomed it.  

In 2022, discussions commenced about the revision of EN 17210 under the European Accessibility Act, and ANEC is contributing to this work.

In 2024, ANEC expert was selected as part of the team revising EN 17210 to ensure its functional requirements remain intact. The team plans to complement these requirements with technical ones if necessary, maintaining a functional approach to accessibility standards across Europe.

ANEC also welcomed the finalisation of FprCEN /TR 17621 “Accessibility and usability of the built environment Technical performance criteria and specifications”: fulfilling the requirements and recommendations of EN 17210 with one/some appropriate example(s) acc. state of the art and of FprCEN /TR 17622 “Accessibility and usability of the built environment Conformity assessment” to fulfil the functional requirements of the EN 17210. Both standards were approved in 2021. The ANEC expert was Project Leader of the team drafting both standards.

In May 2021 we joined the newly established WG 4 of ISO TC 59 SC 16 to work on ISO/AWI 5727 ‘Accessibility and usability of the built environment — Accessibility of immovable cultural heritage — General criteria and methodology for interventions’ which we support as the new project combines two topics of high relevance for today's societies: the conservation of our cultural heritage and unrestricted access for all. These aspects are addressed by the UN SDGs 10 (Reduced inequalities) and 11 (Sustainable cities and communities). The ISO/DIS 5727 ‘Accessibility of immovable cultural heritage Principles and methodology for interventions’ ballot vote period started on 2023-11-30 and ended on 2024-02-22. In its comments ANEC agreed on the content of ISO/DIS 5727 and submitted technical and editorial comments which were accepted. ANEC did a final editorial check of the ISO/FDIS 5727 version during the voting period in the second half of 2024. We were pleased to see the standard approved.

3) Access to electronic communication by older people and persons with disabilities

Due to the enormous impact of the Information Society on consumers’ everyday lives, it is vital for electronic communications to be accessible for all. The ANEC Accessibility WG’s aim is that regulations and standards ensure adequate levels of safety and accessibility for all. This horizontal issue is a common priority of the Accessibility and Digital Society WGs.

4) Horizontal advice

Mainstreaming Design for All principles within and outside ANEC is also a priority for the ANEC Accessibility Working Group. Input on standardisation activities that are related to accessibility issues addressed by the other ANEC Working Groups is provided. As an example, collaboration with the ANEC Domestic Appliances (DOMAP) WG on the exclusion clause issues has proven to be very effective (see section below).

Related European and international references

Furthermore, a close link between research projects and standardisation should be ensured in order to gather scientific evidence to support the application of Design for All principles from the very beginning of product design.

Activities in the European & international standards bodies

ANEC is represented in:

  • CEN BT WG 213 ‘Strategic Advisory Group on Accessibility (SAGA)’
  • CEN TC 293 ‘Assistive products and accessibility’ 
  • CEN TC 293 WG 12 'Accessibility'
  • CEN/TC 293 WG 13 ‘Tactile lettering’
  • ISO TC 173 ‘Assistive products’
  • CEN TC 10 ‘Lifts, escalators and moving walks’
  • CEN TC 10 WG 6 'Fire related issues'
  • CEN TC 10 WG 7 'Accessibility to lifts for persons including persons with disability' 
  • CEN TC 10 WG 8 ‘Stairlifts and vertical platforms for the disabled’
  • CEN TC 10 WG 9 ‘Inclined lifts’
  • CEN TC 122/ISO/TC 159 ‘Ergonomics’
  • CEN TC 449 ‘Quality of care for older people’
  • CEN TC 452 ‘Assistance Dogs’,
  • CEN TC 452 WG 6 ‘Accessibility’
  • CEN-CENELEC-ETSI JTB 'eAccessibility'
  • CEN/CLC/ETSI/JTB eAcc /WG 1, “CEN/CLC/ETSI TR 101551 and CEN/CLC/ETSI/TR 101552”
  • CEN/CENELEC JTC 11 'Accessibility in the built environment'
  • CEN/CLC/JTC 11/WG 1, “Revision of EN 17210”
  • CEN/CENELEC JTC 12 ‘Design for All’
  • CEN/CLC JTC 12/ ad hoc group
  • CEN/CLC JTC 12/WG 1 ‘Revision of EN 17161’
  • CEN TC 331 ‘Postal services’
  • ISO TC 59 SC 16 ‘Accessibility and usability of the built environment’
  • ISO TC 59 SC 16 WG 1 ‘Accessibility and usability of the built environment’ 
  • ISO/TC 59/SC 16 WG 4 ‘Accessibility of the immovable cultural heritage’ 
  • ISO TC 228 WG 14 ‘Accessible Tourism’
  • ETSI TC 'Human Factors'

News and success stories

In July 2021, the European Commission shared with the Committee on Standards (CoS) the Draft Standardisation Request to the European standardisation organisations as regards the accessibility requirements of products and services in support of Directive (EU) 2019/882 of the European Parliament and of the Council. A CEN-CLC Standardisation Request Ad-Hoc Group (SRAHG), SRAHG “ACC”, was created to contribute to shaping the draft SR, which ANEC joined.

In December 2021, ANEC expressed support for the final draft of the SReq and proposal to request six standards, including the revision of the three European standards on accessibility resulting from previous requests, notably EN 301 549, EN 17210, and EN 17161, as well as the development of three new harmonised standards.

ANEC expressed support for the draft EAA SRreq at the EC Committee on Standards meeting on 17 June 2022, as reflecting many of our comments. ANEC also expressed its support for the final SReq in SRAHG ACC which was approved by Member States in July. The ESOs approval is expected by September with work starting immediately after. ANEC also expressed its support for the final SReq in the CEN-CLC SRAHG ACC which was approved by Member States in July and accepted by the ESOs in September 2022.

The request (M/587) refers to:

            - 3 new harmonised standards:

            1. accessibility of non-ICT information-related to products

            2. accessibility of support services related to products and services (help desks, call centres, technical support, relay services and training services)

            3. accessibility and interoperability of emergency communications and for the answering of emergency communications by the public-safety answering point (PSAPs) (including to the single European emergency number 112)

           - European standards to be revised:

                1. EN 301 549 ‘Accessibility requirements for ICT products and services

                2. EN 17161: 2019 ‘Design for all - Accessibility following a design for all approach product, goods and services - Extending the range of users’

         3. EN 17210:2021 ‘Accessibility and usability on the built environment functional requirements’

           - To be also revised:

              - CEN/CLC/ETSI TR 101551:2014 ‘Guidelines on the use of accessibility award criteria suitable for public procurement of ICT products and services in Europe’

              - CEN/CLC/ETSI/TR 101 552 ‘Guidance for the application off conformity assessment to accessibility requirements for public procurement of ICT product and services in Europe’

ANEC is participating in the following activities under M/587:

- revision EN 17210 on access to the built environment (CEN-CLC JTC 11 access to the built environment)

- revision EN 301 549 “Accessibility requirements for public ICT products and services’ (CEN-CLC JTB eAccessibility, ETSI TC Human Factors)

- new standard on Accessibility of non-ICT information-related to products (CEN-CLC JTC 12 Design for All)

The new Harmonised standards should be ready by 15 March 2026/15

January 2027 while the revised Harmonised Standards by 15 September 2025.

In October 2023, ANEC and European Disability Forum (EDF) established ANEC-EDF European Accessibility Act (EAA) Project Team. EDF chaired the Kick-off meeting that took place on 22 November 2023, online. The aim of the Project Team meeting is to discuss the state of play of the standards envisaged in the EAA SReq, as well as future action to influence those standards.

European Accessibility Act standards

In July 2021, the European Commission shared with the Committee on Standards (CoS) the Draft Standardisation Request to the European standardisation organisations as regards the accessibility requirements of products and services in support of Directive (EU) 2019/882 of the European Parliament and of the Council. A CEN-CLC Standardisation Request Ad-Hoc Group (SRAHG), SRAHG “ACC”, was created to contribute to shaping the draft SR, which ANEC joined.

In December 2021, ANEC expressed support for the final draft of the SReq and proposal to request six standards, including the revision of the three European standards on accessibility resulting from previous requests, notably EN 301 549, EN 17210, and EN 17161, as well as the development of three new harmonised standards.

ANEC expressed support for the draft EAA SRreq at the EC Committee on Standards meeting on 17 June 2022, as reflecting many of our comments. ANEC also expressed its support for the final SReq in SRAHG ACC which was approved by Member States in July. The ESOs approval is expected by September with work starting immediately after. ANEC also expressed its support for the final SReq in the CEN-CLC SRAHG ACC which was approved by Member States in July and accepted by the ESOs in September 2022.

The request (M/587) refers to:

            - 3 new harmonised standards:

            1. accessibility of non-ICT information-related to products

            2. accessibility of support services related to products and services (help desks, call centres, technical support, relay services and training services)

            3. accessibility and interoperability of emergency communications and for the answering of emergency communications by the public-safety answering point (PSAPs) (including to the single European emergency number 112)

           - European standards to be revised:

                1. EN 301 549 ‘Accessibility requirements for ICT products and services

                2. EN 17161: 2019 ‘Design for all - Accessibility following a design for all approach product, goods and services - Extending the range of users’

         3. EN 17210:2021 ‘Accessibility and usability on the built environment functional requirements’

           - To be also revised:

              - CEN/CLC/ETSI TR 101551:2014 ‘Guidelines on the use of accessibility award criteria suitable for public procurement of ICT products and services in Europe’

              - CEN/CLC/ETSI/TR 101 552 ‘Guidance for the application off conformity assessment to accessibility requirements for public procurement of ICT product and services in Europe’

ANEC is participating in the following activities under M/587:

- revision EN 17210 on access to the built environment (CEN-CLC JTC 11 access to the built environment)

- revision EN 301 549 “Accessibility requirements for public ICT products and services’ (CEN-CLC JTB eAccessibility, ETSI TC Human Factors)

- new standard on Accessibility of non-ICT information-related to products (CEN-CLC JTC 12 Design for All)

The new Harmonised standards should be ready by 15 March 2026/15

January 2027 while the revised Harmonised Standards by 15 September 2025.

In October 2023, ANEC and European Disability Forum (EDF) established ANEC-EDF European Accessibility Act (EAA) Project Team. EDF chaired the Kick-off meeting that took place on 22 November 2023, online. The aim of the Project Team meeting is to discuss the state of play of the standards envisaged in the EAA SReq, as well as future action to influence those standards.

Evaluation of the Web Accessibility Directive

In October 2021, the European Commission started the review/evaluation of the Directive on the accessibility of public sector websites (Directive (EU) 2016/2102). In coordination with EDF, ANEC contributed to the evaluation by stressing that as increasing number of public services are delivered online, inaccessible websites or other platforms limit or impede access to public services for consumers who use assistive technology to access digital content. As demonstrated by the pandemic crisis, access to digital (public) services might be the only way to continue to conduct our lives of citizens or consumers. The standards ensured the free movement of web accessibility products and services in order to provide a high level of consumer protection and remove barriers both for consumers and for traders. In our view, constant updates to cover new technologies are needed for the standards to continue to function as a harmonisation factor in the Internal Market. 

In May 2022, the consultation results showed that access to public sector websites and mobile apps has improved in the last three years, thanks to the Directive. However, navigation, finding the way around a website, and text forms, such as contact forms, are the most common issues hindering accessibility. In December 2022, the EC published the results of the evaluation of the Web Accessibility Directive (Directive (EU) 2016/2102, to which ANEC contributed). There is still much practical progress to be made for all public sector websites and mobile applications to be fully accessible to persons with disabilities, regardless of the nature of the disability. Most actions to date have been targeted at those with visual impairment, and work is continuing within the standardisation bodies on the requirements for those with cognitive impairment. This last point was stressed by ANEC in its position. We intend to continue to contribute to the evaluation process of the Web Accessibility Directive (and related standards) this year.

In October 2022, the revised version 2.1.2 of ETSI Guide 203 499 – “User-centred terminology for existing and upcoming ICT devices, services and applications; Device and service terminology”, which ANEC supported, was published by ETSI. ANEC submitted comments on "ETSI Accessibility Policy- Draft": ETSI Accessibility Policy for Persons with Disabilities were accepted in line with ANEC’s position. The policy document was approved by the ETSI General Assembly at the end of November 2022, which ANEC welcomed.

ANEC position in EN 81-70 Accessibility of lifts

In June 2021, ANEC published a position paper on technical issues regarding the accessibility of lifts, notably how prEN 81-70:2020 ‘Safety rules for the construction and installation of lifts - Particular applications for passenger and goods passenger lift - Part 70: Accessibility to lifts for persons including persons with disability’ can meet legal requirements (https://bit.ly/3jJ0rze). 

In the paper, we recall that accessibility of the built-environment, products and services, is essential for persons with disabilities, and older people, to be able to exercise their rights and participate independently in society.

Referring to the existing normative framework, “Requiring an accessible built environment not only ensures suitable access and comfort based on ‘Design for all / Universal Design’ for a wider range of users including persons with disabilities but also contributes to their safety by creating a built environment”, products and services, “where particular consideration is taken to avoid and/or reduce risks.

Following our appeal to CEN to respect legal requirements on visual contrast in push buttons and their surroundings in a lift (BT decision C062/2010), and the amendment developed in CEN/TC 10/WG7, we ask CEN/TC 10 WG 7 in the ongoing technical revision of prEN 81-70:

  • to respect the UN CRPD which is legally binding for EU and Member States;
  • to follow Design for All/Universal Design principles;
  • to include technical improvements based on the relevant functional requirements in EN 17210:2021 ‘Accessibility and usability of the built environment - Functional requirements’.

Moreover, in September 2021, the Enquiry for amendment of EN 81-70 on accessibility of lifts, based on previous decisions on ANEC appeal and the agreed solution, was successfully completed and the final draft has been prepared for Formal Vote, scheduled in February 2022. A full technical revision will be launched as soon as EN 81-70/A1:2022 will be published, to reflect the additional ANEC asks.

ANEC submitted comments on EN 81-70:2021/FprA1 Safety rules for the construction and installation of lifts - Particular applications for passenger and goods passenger lift - Part 70: Accessibility to lifts for persons including persons with disability, which were approved in line with ANEC’s position.

We are pleased to see that the standard on the accessibility of lifts has been approved by 17 CEN National members, with only one objecting (Switzerland, Outside EEA). The standard should now proceed to publication. We are also pleased that the European Commission decided not to quote in the EU Official Journal the present version of EN 81-70 but to wait for this amendment (solving the ANEC’s appeal) to be ready. ANEC also submitted a favourable opinion.

EN 17999: Accessible systems for living independently - Requirements and recommendations’ approved during Enquiry stage

We are very pleased that prEN 17999: ‘Accessible systems for living independently - Requirements and recommendations’ was approved during the Enquiry ballot (opened until 23 November 2023) with no objections. Namely, 12 out of 12 member countries voted positively, with 18 countries abstaining. ANEC supported the standard and therefore submitted a positive opinion with only minor editorial comments.

prEN 17999 was drafted by CEN/TC 293 ‘Assistive products and accessibility’. The mainly editorial comments submitted will now be processed by CEN TC 293 and a decision will be taken about the next steps, being Formal Vote or direct publication, the former more likely. 

We believe that Accessible systems for living independently (ASLI) can enable all consumers to control individual situations or surroundings and engage in social activities inside and outside the home. The aim of the draft standard is to enhance the quality of life for everyone by ensuring satisfactory accessibility of systems in everyday life and by improving both independence and full participation in society.

ANEC welcomes the final approval of prEN 17984-6 ‘Assistance Dogs – Part 6: Accessibility and Universal Access’ in September 2024

ANEC welcomes the final approval of prEN 17984-6 ‘Assistance Dogs – Part 6: Accessibility and Universal Access’. The draft standard was open for consultation until 5 October, and we supported its approval. ANEC has played a key role in drafting the prEN 17984-6 standard, titled ‘Assistance Dogs – Part 6: Accessibility and Universal Access’.

This standard is crucial to ensure that both assistance dog users and the dogs themselves have unrestricted access to public and private spaces throughout Europe. In addition, we are supporting prEN 17984-1:2023, ‘Vocabulary’, which aims to harmonise terminology related to dogs specifically trained to enhance independence and reduce the limitations faced by individuals with disabilities.

ANEC is actively involved in CEN/TC 452 ‘Assistance Dogs’, working in partnership with the European Guide Dog Federation. The term "assistance dogs" refers to any dog trained to assist individuals with sensory, physical, mobility, or other medical, mental health, or developmental impairments.

Web Accessibility standard published

The Web Accessibility Directive makes use of Harmonised Standards to provide a presumption of conformity with its essential requirements. The Web Accessibility Directive (Directive (EU) 2016/2102) is applicable as of September 2019 and the work is now focusing on the drafting of Harmonised Standards to implement the directive.

To this end, a draft Standardisation Request for Harmonised Standards on the accessibility of websites and mobile apps was issued by the EC, with ANEC’s support. In May 2017, it was approved by CEN-CENELEC and the EC Committee on Standards. CEN, CENELEC & ETSI were asked to deliver Harmonised Standard(s) based on EN 301 549 V1.1.2 (2015-04), including necessary provisions needed to support the implementation of Article 4 of Directive (EU) 2016/2102.

In August 2018, the Standard EN 301 549 was published and is freely available online at ETSI website. In December 2018, a reference to EN 301 549 was published in the Official Journal of the European Union (OJEU), thus becoming the first Harmonised Standard which aims to provide presumption of conformity to the Directive on the accessibility of the websites & mobile applications of public sector bodies (Directive 2016/2102, the “Web Accessibility Directive”).  The standard was drafted by the CEN/CENELEC/ETSI JWG ‘eAccessibility’ and the ETSI TC ‘Human Factors’, with the assistance of ANEC’s experts.

Another revision of EN 301 549 started in 2019 with an enquiry that ended in September 2019. In September 2019 prEN V3.1.1 (2019-06) 'Accessibility requirements for ICT products and services' was approved. We welcomed the approval as this version of the standard contains several improvements such as WCAG triple A, RealTimeText interoperability and ICT with video capabilities.

ANEC commented on CEN/CLC/ETSI/JWG eAcc decision on the future of prEN 301549 after Enquiry vote. In coordination with EDF, ANEC supported the decision to skip the Formal Vote because of the few editorial comments received on the draft standard during the Enquiry stage. The decision was taken by unanimity, with the support of ANEC. In December 2019, EN 301 549 was published. In October 2020, ANEC supported the editorial revision of EN 301 549:2019 (v3.1.1) before its citation in the EU Official Journal. 

The new version of EN 301 549 (version 3.2.1) had been prepared. The Enquiry vote was opened until 2021-03-05. ANEC submitted comments on ETSI EN 301 549 V3.2.1 (2020-12) ‘Accessibility requirements for ICT products and services’, which were approved in line with ANEC’s position. ETSI has approved the last version of EN 301 549 with 100% positive votes with 11 countries abstaining.

After a discussion on whether to maintain or revoke the technical reports of JWG, it was decided to maintain: CEN/CLC/ETSI TR 101550:2014, CEN/CLC/ETSI TR 101551:2014 and CEN/CLC/ETSI/TR 101 552:2014, in line with ANEC’s position.

Also, in September 2020, the ETSI Human Factors Technical Committee has published ETSI TR 103 455, a Technical Report on standardisation in order to meet citizen and consumer requirements with regards to smart cities.

Prepared with the support of the EC and EFTA Secretariat, the Report aims to demystify standards to local communities. Smart communities enable citizens to have better living conditions, but at the same time empower them to have a say in matters that impact their daily lives. For example, equal treatment of citizens, including their data privacy concerns regarding personal information, needs to come at the forefront as the Report highlights.

A broad set of recommendations is included in the report- for the preparation of guidance material to help cities, codes of conduct to help service to the citizen, and standard measures needed to design citizen services, and improve security, privacy and accessibility.

ANEC hopes the Technical Report will lead to a much-improved understanding of citizens’ needs, within local authorities and the standards organisations.

EN 301549 will be revised in 2023 in the framework of the draft Standardisation Request (SReq) for Harmonised Standards to support accessibility requirements of products and services in line with Directive (EU) 2019/882.

At the end of February 2024, ANEC submitted its comments on the last draft of EN 301549 'Accessibility requirements for ICT products and services' in alignment with the comments by EDF which were mostly accepted.

M/587 also requests the revision of CEN/CLC/ETSI TR 101 551:2014 “Guidelines on the use of accessibility award criteria suitable for public procurement of ICT products and services in Europe”, and of CEN/CLC/ETSI/TR 101 552:2014 “Guidance for the application of conformity assessment to accessibility requirements for public procurement of ICT products and services in Europe”. Both documents should be updated to be aligned with the current Public Procurement Directive and ongoing revision of EN 301549. In February 2024, CEN-CLC-ETSI-JWG eAcc-WG1 decided by consensus to merge TR 101551 and TR101 552 together in line with ANEC’s position. The due date for the TR revision is 15/01/26.

Inclusive service: consumers in vulnerable situations

ISO/PC 311 was a project committee which was established in 2017 for standardisation in the field of services for all consumers. ANEC contributed to the drafting of its first standard: ISO 22458 ‘Inclusive Service: identifying and responding to consumers in vulnerable situations’. Our contributions are based on our long-time assessment that all consumers, irrespective of age and/or knowledge, can become vulnerable at certain times – for example, in having access to knowledge needed to make an optimal choice - and as a result, there is a greater risk of consumer detriment (“the situational dimension”). 

At the beginning of 2022, ANEC submitted comments on ISO/FDIS 22458 Consumer vulnerability – Requirements and guidelines for the design and delivery of inclusive service: approved with 100% positive results in line with ANEC’s position. ANEC is very pleased with the final standard, which we believe is a good new document to refer to at international level and supported it at the final draft stage. The document specifies requirements and guidelines for organizations on how to design and deliver fair, flexible and inclusive services that will increase positive outcomes for consumers in vulnerable situations and minimize the risk of consumer harm. It covers organizational culture and strategy, inclusive design and how to identify and respond to consumer vulnerability. It is applicable to any organization that provides services, including service-related products, to consumers, regardless of location or size.

As the work of ISO/PC 311 and WG 1 is over with the publication of ISO 22458:2022 in April, they were disbanded.

EN 81-40 on stairlifts approved

EN 81-40 'Safety rules for the construction and installation of lifts - Special lifts for the transport of persons and goods - Part 40: Stairlifts and inclined lifting platforms intended for persons with impaired mobility' has been adopted by CEN. ANEC sent a Favourable Opinion in support of the standard. The date of availability is 2020-09-21.

EN 81-40 is a Harmonised Standard under the Machinery Directive. This edition replaces the existing standard published in 2008. The new standard features several changes that are beneficial to consumers. These include improved and new safety devices with barriers and seatbelts that are interlocked, and the introduction of an alarm system to summon assistance if needed. These changes not only make the normal use of a stairlift safer, but reduce the likelihood of a user attempting to dismount the chair mid-travel in the event of a failure, and falling as a result. 

Other changes include a new requirement for a self-levelling system, again making use of the chair safer, and enhancements to aid safe transfer from a wheelchair. A selection of materials to meet fire safety regulations and a new normative annex on installation are also included.

Furthermore, in October 2020 ANEC welcomed the adoption of EN 17210 ‘Accessibility and usability of the built environment - Functional requirements’ by CEN. The new standard describes basic, minimum functional requirements & recommendations for an accessible and usable built environment, following "Design for All"/"Universal Design". The Project Team responsible for drafting the standard was led by ANEC expert, Monika Klenovec. The principles of the standard will facilitate equitable and safe use for a wide range of users, including persons with disabilities. Its requirements and recommendations are applicable across the spectrum of the built environment. These requirements and recommendations are relevant to the design, construction, refurbishment or adaptation, and maintenance of built environments, including outdoor pedestrian and urban areas.

EN IEC 63008 adopted

ANEC welcomed adoption of EN IEC 63008 ‘Household and similar electrical appliances – Accessibility of control elements, doors, lids, drawers and handles’, developed by WG11 of IEC TC 59 ‘Performance of household and similar electrical appliances’. Several ANEC members were involved in the drafting of this standard, which provides information in the form of facts on accessibility, and an understanding of the interaction between appliances and users with a wide range of abilities.

A finger pressing a button on a microwave

EN IEC 63008 contains accessibility requirements to enable more accessible use of certain elements found on household and similar electrical appliances by older persons and persons with disabilities. It provides guidance to achieve accessible design of control elements (e.g. knobs, buttons), including control panels, display screens & doors, lids, drawers & handles. It covers supporting and auxiliary functions that a user performs regularly, as well as test methods and data supporting accessible design. It does not enable the full assessment of the accessibility of an appliance as safety, assembly, installation, configuration and repair.

Support of accessible meetings in the Czech Republic

At the beginning of 2019, ISO 17069 Accessible Design - Considerations and assistive products for accessible meetings was introduced into the national portfolio of Czech Standards (CSN).

The Czech Agency for Standardization (CAS) is responsible for the development of standards and administration of the CSN national system. However, the Cabinet for Standardization was in charge of preparing the above-mentioned tasks. The Cabinet is a public service company founded by the Czech Consumer Association with a view to develop and implement specific tools and ways to involve Czech consumers in standardisation. The fact that CAS entrusted this contractual assignment to the Cabinet reflects its intention to support consumer participation in standardisation. The Cabinet also translated the national adoption of ISO 17069 into Czech.

ISO 17069 defines requirements and good practice related to preparing and hosting meetings so that the organiser does not neglect, as far as possible, any aspect that would cause problems of access. Given that all persons should have the right to attend and participate in meetings, the standard provides a valuable resource in removing obstacles to participation. The Czech consumer movement therefore welcomed the initiatives taken to raise the awareness and use of EN 17069 at the national level.

Are household appliances really safe for all consumers?

Consumers expect domestic appliances to be safe to use, for themselves, their children and the older members of their families. The aim of regulators, as expressed in European Directives, is to achieve a high level of health and safety protection for all consumers. However, in the case of electrical products, these principles were undermined by the EN 60335 series of standards used to support them as they did not "… in general take into account the use of appliances by young children or infirm persons without supervision", the so-called “Exclusion Clause”.

Why is this discriminatory?
A child using the knobs on an oven

The EN 60335 series of standard was written in the social and educational context where it was taken for granted that children and “infirm people” typically did not use the products covered by its scope without supervision. ANEC believed this to be discriminatory and asked for the deletion of this exclusion clause. Moreover, manufacturers and standards makers nowadays have the technical knowledge to review the design of products and their standards, to ensure that they are safe for use by all consumers, including children, older persons and persons with disability.

What is ANEC doing?

Since 2005, ANEC has led a campaign to revise the standards. In April 2010, the first six revised Parts 2 of EN 60335, largely based on ANEC’s proposals, were published. This was a key achievement for ANEC and for the consumer movement.

Since then, CENELEC concluded the revision of other Parts 2 to the EN 60335 series, based on ANEC’s proposal covering a particular appliance and embracing vulnerable consumers’ needs. About 60 standards have been revised to enable them take into account the safety needs of vulnerable consumers.

ANEC, with Consumers International, continues its efforts to remove the exclusion clause by proposing improvements to further Parts 2 to the EN 60335 and “parent” IEC 60335 series, as well as on lower surface temperature limits in the IEC 60335 series.

To read more about ANEC’s achievements in different sectors please visit our ‘Success stories’ web page.

Publications

To access position papers related to Accessibility please click the following link: Position papers.