Obligations for Manufacturers.

According to the European Accessibility Act, a manufacturer is any person or company who:

• Makes a product, or has someone design or make a product for them.
• Sells that product under their own name or brand.

This includes companies that:

• Make physical products covered by the EAA.
• Design products but have others make them.
• Sell products made by others under their own brand.
• Make major changes to products already on the market.

Manufacturers have the most responsibility for making sure products follow the EAA rules. Here are their main duties:

• Making sure products are designed and made according to accessibility requirements.
• Creating and keeping technical documents.
• Testing products to make sure they follow the rules.
• Creating an EU Declaration of Conformity.
• Adding the CE marking to products that meet the requirements.
• Keeping records of products that don't meet requirements and any product recalls.
• Making sure all products in a series stay compliant.
• Providing information about product accessibility in formats everyone can use.

Manufacturers must design and make products that follow the accessibility requirements in Section I of Annex I of the EAA. These requirements include:

• Providing information about how to use the product in formats everyone can access.
• Making user interfaces and functions accessible to people with disabilities.
• Making sure products work with assistive technologies.
• Designing packaging and instructions that everyone can use.

Manufacturers should include accessibility features from the very beginning of product design, following "universal design" principles.

Before placing a product on the market, manufacturers must follow these steps to check that it meets accessibility requirements:

1. Make sure the product design meets the accessibility requirements.
2. Check the product against the requirements using the procedures in Annex IV.
3. Fix any issues found during testing.
4. Create technical documentation showing how the product meets the requirements.
5. Create and sign the EU Declaration of Conformity.
6. Add the CE marking to the product.

Manufacturers must create and maintain technical documentation for each product. This documentation must include:

• A general description of the product.
• A list of the standards and technical specifications used in the design.
• Information about how the product meets the accessibility requirements.
• Results of any tests or assessments done to check compliance.

Manufacturers must keep this documentation for at least 5 years after the product is placed on the market. National authorities can request to see this documentation at any time.

The EU Declaration of Conformity is a legal document stating that a product meets the accessibility requirements of the EAA. This document must:

• Include the manufacturer's name and address.
• Identify the product by type, batch, or serial number.
• State that the product meets the accessibility requirements in Directive (EU) 2019/882.
• List any standards or technical specifications that were followed.
• Be signed by an authorized person at the company.
• Be updated if the product design changes in ways that affect accessibility.

A copy of this declaration must be kept for at least 5 years after the product is placed on the market.

Manufacturers must add the following information to their products:

• The CE marking, which shows the product meets EU requirements.
• The manufacturer's name, registered trade name, or trademark.
• The manufacturer's postal address for contact.
• A type, batch, or serial number to identify the product.

This information must be:

• Visible and easy to read.
• Placed directly on the product if possible.
• If that's not possible, placed on the packaging or in documents that come with the product.

If a manufacturer discovers that a product doesn't meet the accessibility requirements, they must:

• Take immediate action to make the product comply, or withdraw it from the market if necessary.
• Inform national authorities in EU countries where the product is available.
• Give details about the non-compliance and any actions taken to fix it.
• Work with authorities to make sure the product is brought into compliance or withdrawn.

Even after a product has been placed on the market, manufacturers remain responsible for monitoring its compliance with accessibility requirements.

Manufacturers must keep records of:

• Complaints about products not meeting accessibility requirements.
• Products that don't comply with the requirements.
• Product recalls.
• Actions taken to address accessibility problems in their products.

These records help manufacturers improve their products and can be requested by authorities if there are concerns about compliance.

Manufacturers must cooperate with national authorities when requested. This includes:

• Providing all information and documentation necessary to prove that a product meets accessibility requirements.
• Giving authorities access to their premises if needed for inspections.
• Explaining steps taken to ensure products meet the requirements.
• Taking corrective actions when requested by authorities.

This information must be provided in a language that is easy for the authorities to understand.