European Association of Service Providers for Persons with Disabilities: EASPD releases a report on the Accessibility Act

Following several years of internal discussion, the European Commission (EC) launched in December 2015 the “Accessibility Act”. The European Association of Service Providers for Persons with Disabilities (EASPD) welcomes the initiative and has developed a comprehensive analysis from the perspective of support services for persons with disabilities.

The reference made in the EC proposal to Article 9 of the United Nations Convention on the Rights of Persons with Disabilities (UN CRPD) clearly recognizes that accessibility is a human right. The initiative helps the EU to comply with its obligations under article 9 of the UN CRPD but also to support Member States and complement their efforts at national level.

EASPD acknowledges the importance of this initiative for the disability movement and for society as a whole and therefore wishes to contribute to its improvement by giving advice to policy makers on the main concerns for support services.

Overall, EASPD considers that having a clear focus on a specific range of products and services might bring real change for people with disabilities. Luk Zelderloo, EASPD Secretary General, wishes to highlight that “this is a very important step forwards. We sincerely hope that more legal initiatives will follow. Besides, the Directive provides guidance to Member States on accessibility requirements but does not impose detailed technical solutions on ‘how’ to make products and services accessible.”

Recommendations to EU institutions

  • Manufacturers, importers, distributors and service providers should be able to provide at any moment information on the accessibility features of the products and services.
  • There is a risk that the economic logic and the cost-benefit analysis could act as a barrier in the design, development and implementation of products and services.
  • The requirements for compliance with the proposed Directive are too limited and not clear enough for Microenterprises. Even though Microenterprises are exempted from notifying the authority on fundamental alteration and disproportionate burdens, they should be incentivised to adopt accessibility requirements.
  • Market surveillance should be carried out in cooperation with persons with disabilities and the Directive should contain clear requirements about the role and resources of the market surveillance authority.
  • The accessibility requirements for persons with intellectual disabilities should be extended to all products and services and complemented with tools and methods such as Easy To Read materials.

Together with these recommendations, EU policy makers should bear in mind during the negotiations other essential elements such as the need to involve persons with disabilities in all stages of production to test the accessibility of products and services and take full advantage of the know-how and expertise of social and health support services for persons with disabilities.

Besides, EASPD believes that all economic operators should become acquainted with the principles of “Universal Design” and apply safety and security guarantees to its products and services. In that sense, an ombudsman for users could be set up by authorities at the national level to cope with users’ complaints.

Full article.