Conformity Assessment Procedure.

Conformity assessment is the process used to demonstrate that a product or service meets the accessibility requirements set out in the European Accessibility Act. The EAA establishes specific procedures that manufacturers, importers, distributors, and service providers must follow.

For products, the EAA requires the use of the "internal production control" procedure (known as Module A), where manufacturers take full responsibility for ensuring and declaring conformity.

For services, a similar but distinct assessment process is required, focusing on how services meet the accessibility requirements in Annex I.

Internal production control (Module A) is the conformity assessment procedure where the manufacturer:

• Takes sole responsibility for ensuring their products meet EAA requirements
• Creates technical documentation showing how requirements are met
• Carries out production controls to maintain consistent accessibility
• Draws up an EU Declaration of Conformity
• Applies the CE marking to compliant products

This procedure does not require the involvement of a notified body or third-party certification, which reduces costs and administrative burdens for businesses.

The manufacturer must follow these steps to complete the Module A procedure:

1. Product assessment: Analyze the product against the accessibility requirements in Annex I of the EAA.
2. Technical documentation: Create detailed documentation that includes:
   • General description of the product
   • List of applied harmonized standards or technical specifications
   • Design and manufacturing drawings where relevant
   • Explanations necessary to understand those drawings
   • Results of design calculations and examinations
   • Test reports demonstrating conformity
3. Production control: Implement measures to ensure all manufactured products comply with requirements.
4. Conformity marking: Apply the CE marking to each product.
5. Declaration of Conformity: Draw up a written EU Declaration of Conformity for the product model.
6. Documentation storage: Keep technical documentation and Declaration of Conformity for 5 years after the product is placed on the market.

The technical documentation for accessibility conformity assessment must include:

• An assessment of which accessibility requirements apply to the product
• Details of how the product meets each applicable requirement
• Evidence of accessibility testing and results
• Documentation of any exemptions claimed under "disproportionate burden" or "fundamental alteration"
• Information on how users will be informed about accessibility features
• User instructions related to accessibility features

This documentation serves as the basis for the EU Declaration of Conformity and should be made available to market surveillance authorities upon request.

For services, the assessment procedure is similar but with key differences:

• No CE marking is required for services
• No formal Declaration of Conformity is required, but documentation must be maintained
• Service providers must maintain documentation demonstrating how the service meets accessibility requirements
• Documentation must be kept for as long as the service is offered
• The assessment must include how the service meets requirements in Annex I, Section III of the EAA

Service providers must also publish information about how their services meet accessibility requirements, typically through accessibility statements on their websites or in other user-facing documentation.