[Home](/)/[Resources](/resources)/EU Accessibility Act Hardware EU/CECompliance guide # European Accessibility Act for Connected Hardware Products From 28 June 2025, connected hardware with interactive digital interfaces sold in the EU must meet the functional accessibility requirements of the European Accessibility Act (Directive 2019/882). Computers, smartphones, tablets, interactive consumer terminals, and self-service kiosks are all in scope — and conformance must be documented in the technical file and declaration of conformity alongside existing CE marking requirements. Copy Link[Share on WhatsApp](https://wa.me/?text=https%3A%2F%2Fkrono-labs.com%2Fguides%2Feu-accessibility-act-hardware) At a glance Directive 2019/882 (EAA) Standard EN 301 549 Deadline 28 June 2025 Mark No separate mark — DoC update ## EAA requirements for hardware ### EAA scope for hardware products The European Accessibility Act (Directive 2019/882, transposed by EU member states) covers a defined list of products and services. For hardware makers, the key in-scope products include computers and operating systems, smartphones and tablets, consumer terminal equipment with interactive computing capability, televisions with interactive digital services, and self-service terminals (ATMs, ticketing machines, check-in kiosks). The EAA applies to new products placed on the market from 28 June 2025. ### Functional accessibility requirements In-scope products must meet the functional accessibility requirements in Annex I of the Directive. These translate to: information and user interface elements must be perceivable (text alternatives, sufficient contrast), operable (keyboard-accessible, no time-only interaction), understandable, and robust enough for assistive technology. European standard EN 301 549 provides the harmonised technical specification for ICT accessibility that hardware makers use to demonstrate conformance. ### Interaction with CE marking and other directives The EAA runs alongside, not instead of, existing CE marking requirements. An in-scope product that already requires CE marking under RED, LVD, or MDR still needs CE marking — the EAA adds accessibility as an additional essential requirement to satisfy for the product to be legally placed on the EU market. The EAA does not create a separate 'accessibility mark'; conformance is documented in the technical file and declaration of conformity. ### SME and proportionality provisions The EAA includes a disproportionate burden exception: an economic operator can claim that meeting the accessibility requirements would fundamentally alter the nature of the product or impose a disproportionate burden, based on a documented assessment. Micro-enterprises (fewer than 10 employees, under €2M turnover) supplying services are exempt from the service provisions — but there is no blanket product exemption for SMEs. Hardware companies of any size placing in-scope products on the EU market must assess their exposure. ## Compliance process 01 Determine whether your product is within the EAA's defined scope — focus on whether it has an interactive digital interface and falls within the specific product categories listed in Article 2 of Directive 2019/882. 02 Map the applicable functional accessibility requirements from Annex I of the EAA to your product's interface elements: inputs, displays, audio, navigation, and any pairing or configuration interface. 03 Apply EN 301 549 as your technical standard — the relevant clauses depend on your product type; identify which clauses apply and assess conformance against each requirement. 04 Conduct a gap assessment: which interface elements, interactions, or information outputs currently fail EN 301 549 requirements, and what design or firmware changes are needed to achieve conformance. 05 Update your technical file to include the accessibility conformance documentation, including a record of how each Annex I requirement is met and which EN 301 549 clauses were applied. 06 Update your Declaration of Conformity to reference the EAA (Directive 2019/882) alongside any existing directives and include it in product documentation before placing the product on the EU market after 28 June 2025. 07 If claiming a disproportionate burden exception, prepare and retain the documented assessment — it must cover the ratio of cost to benefit, frequency of use by persons with disabilities, and the product's expected lifespan. ## Frequently asked questions ### Does the EAA apply to B2B products? The EAA applies to products placed on the EU market regardless of whether they are sold B2C or B2B — the scope is defined by product type, not the customer relationship. However, the practical focus is on products with consumer-facing interactive interfaces. A purely industrial product with no interactive digital interface for end users is unlikely to be in scope, but the analysis depends on the specific product and interface design. ### What is the compliance deadline? 28 June 2025 is the date from which in-scope products placed on the EU market must comply. Products lawfully placed on the market before that date can continue to be made available until 28 June 2030 without modification. Service providers have the same 28 June 2025 deadline. Spare parts for products placed on the market before 28 June 2025 are exempt until 2030. ### How does EN 301 549 relate to WCAG? EN 301 549 incorporates WCAG 2.1 Level AA for web-based content and user agents, and extends the same principles to non-web ICT products including hardware. For a connected device with a built-in display or web-based configuration interface, WCAG 2.1 AA compliance on the web interface plus the hardware-specific clauses in EN 301 549 Chapter 8 (hardware) covers the combined product. ### Are there notified body requirements under the EAA? The EAA does not create a new mandatory third-party conformity assessment route for products that currently use self-declaration under their existing CE marking directives. Self-assessment against EN 301 549 with internal documentation is the standard route for most in-scope products. Member states may designate market surveillance authorities to check compliance, and non-conforming products can be removed from the market. **Disclaimer:** Educational resource only. EAA transposition varies by member state and product-specific scope requires legal analysis. Consult a qualified accessibility or regulatory consultant before making EAA compliance decisions. 🇪🇺 CE Marking roadmap for your product Every standard, document, and test that applies — free, no account required. See your free roadmap[ Want an expert to take your product through 🇪🇺 CE Marking compliance for you? One consultant from Krono's compliance team takes your product from requirements to legal sale, with a fixed quote before any work starts. See compliance services](/services) Learn this properly In-depth course that teaches the full process, not just this one answer. [Start the course — $149](/courses/30-eaa-electronics-ict-ecommerce)[Prefer to read? 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