Letter: Ensuring equal access to relevant European accessibility standards by persons with disabilities

Letter in Word: Affordable Standards – Open letter to European Commissioner for Internal Market Thierry Berton

Brussels, 20 May 2021

To:

Mr Thierry Breton

European Commissioner for Internal Market

CC: Mr Vincent Laflèche President, CEN; Mr Dany Sturtewagen President, CENELEC

Subject: Ensuring equal access to relevant European accessibility standards by persons with disabilities

Dear Commissioner Breton,

On this Global Accessibility Awareness Day (GAAD), we are writing to you to call on the European Commission to ensure equal access of persons of all ages and abilities and society at large to relevant European accessibility standards in support of EU initiatives and policies, namely by removing the costs for obtaining and disseminating these standards which have been produced thanks to the financial support of the European Commission.

Organisations such as ourselves have been actively involved in the development of European standards which support accessibility of goods and services in the Internal Market. Members of our network have likewise contributed to this process through national standardisation bodies. We invest considerable time and resources to support EU’s standardisation activities.

The European Commission funded the development of standards which, among other objectives, aim to contribute to equal access and participation of persons with disabilities in the Internal Market.

For example, there is EN 17210:2021 ‘Accessibility and usability of the built environment – Functional requirements’; Technical Report prCEN/CLC/TR 17621 on Accessibility and usability of built environment – Technical performance criteria and specifications; and Technical Report prCEN/CLC/TR 17622 on Accessibility and usability of the built environment – Conformity assessment (Mandate 420).

Another example is EN 17161:2019 ‘Design for All – Accessibility following a Design for All approach in products, goods and services – Extending the range of users’ (Mandate 473).

Future Harmonised Standards will also need to be developed to support the European Accessibility Act.

Once the text of the standard, to which we contributed, is published, it must be purchased from one of the national standardisation organisations – which can cost between €100 and €300 for one publication. This constitutes a considerable barrier. It is therefore not possible for individuals to check if a product or service they use is in conformity with the standard or not. Non-profit organisations cannot assess the quality of a standard either without having access to the full, final text.

This limits the possibility of accessing relevant standards for disability and accessibility experts, as well as efforts to promote the use of developed standards and harmonise accessibility across the EU.

Therefore, in view of European Union’s objective to support European standardisation and commitment to ensure equal right of access to goods and services by all, and noting importance of European standards in support of adopted EU accessibility legislation, particularly the European Accessibility Act, we call on the European Commission to ensure barrier-free availability of European standards on accessibility by working with the European standardisation organisations and their members to make the texts of the standards available at no costs to the European networks representing persons with disabilities, and their national member organisations, in order to allow the promotion and dissemination of relevant standards by these organisations for not-for-profit purposes.

Thank you very much for your consideration. We would welcome the opportunity to discuss our request with the European Commission and European Standardisation Organisations.

Sincerely,

Yannis Vardakastanis

President of the European Disability Forum