1. Overview
The European Accessibility Act (EAA) is Directive (EU) 2019/882. Article 35 addresses it to the Member States. But its working parts are duties on "economic operators". Article 3(21) defines them as "the manufacturer, the authorised representative, the importer, the distributor or the service provider". Which of the five you are decides what you must do.
Manufacturers, importers and distributors deal with products. Their duties are in Chapter III. That chapter uses three tools from EU product law: the conformity assessment, the EU declaration of conformity and the CE marking. Service providers are in Chapter IV. It is a single Article. Its core is a public explanation of how the service meets the requirements.
Three more chapters sit around both. Chapter VIII covers market surveillance of products. Chapter IX covers compliance of services. In Chapter XI, Articles 29 and 30 cover enforcement and penalties.
This lesson follows that order:
- Article 4, which attaches the Annex I sections to products and services
- the product chain
- the service provider
- what happens when something goes wrong.
The next lesson covers the requirements themselves. Here the question is only who must do what.
Article numbers here are those of the Directive as published. A national transposing law will use its own numbering. But it keeps the same structure of manufacturer, importer, distributor and service provider. So the Chapter headings quoted below are the quickest way to find the matching provision.
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Sources
- Directive (EU) 2019/882 (the European Accessibility Act), Articles 4 to 13, 15 to 23, 29 and 30, Annexes IV and V, and recital 20.
- ETSI, CEN and CENELEC, EN 301 549 V4.1.1 (2026-09), clause A.2 and Annex ZB, available from the ETSI standards server.
- W3C, Web Content Accessibility Guidelines (WCAG) 2.2, carried into Annex I Section III(c) by EN 301 549 clauses 9, 10 and 11.
- Regulation (EC) No 765/2008 on accreditation and market surveillance, and Decision No 768/2008/EC on a common framework for the marketing of products, which Articles 16 to 19 of the Directive apply to CE marking and surveillance.
- Accessibility Checker user guides: reports and statements on iPhone and iPad and the Reports Hub on the Mac, for what the statement generator does and does not produce.
