1. European Accessibility Act:
Comments and Suggestions by the Mobile Manufacturers Forum

2. The MMF
The Mobile Manufacturers Forum (MMF) is an international association with scientific purpose of telecommunications equipment manufacturers with an interest in mobile or wireless communications.
Participants in GARI: Alcatel Mobile Phones, Apple, BlackBerry, Cisco, Coolpad Americas, HP Inc., HTC, Huawei, Kyocera, Lenovo, LG, Microsoft (Nokia), Motorola Mobility, Samsung, Sony, Telstra, ZTE

3. GARI GARI.... Global Accessibility Reporting Initiative
1,100+ mobile phone models for all world regions
centralised source of information
300+ accessibility related apps
consumer guidance & reporting tool
16+ languages

4. Goals We Share PROMOTE accessibility EMPOWER consumers
as an attitude in design and production of products and services
EMPOWER consumers
with up-to-date information about accessibility features of products and services
IMPROVE accessibility
of products and services continuously through competition

5. Functional Approach: Manufacturers Serve Needs!
Device A has …
Device B has …
screen magnifier
web browser zoom
adjustable font size
high contrast mode
voice recognition for dialing or accessing features
voice output caller ID from contacts list
audible and tactile key feedback
BUT does not have
Braille Display Support
pre-installed screen reader
optimized two-way video communication (for sign language users)
text phone/TTY compatibility
adjustable vibrating alerts
supports closed captioning for web video or streaming
visual alerts
BUT does not have …
improved call quality (for hard of hearing persons)
hearing-aid settings

6. Under Proposed European Accessibility Act:
Beware of ‚all-or-nothing‘ approach!
Device A
Device B

7. Adopt Functional Requirements: e.g. ‘Usage without Colour Perception’
Prescriptive:
Functional:
Provide for an alternative colour to convey information.
(Draft European Accessibility Act)
Where ICT provides visual modes of operation, the ICT shall provide at least one mode of operation that does not require user perception of colour.
(EN )

8. How To Maximise Accessibility?
Empower consumers
oblige all economic operators to inform about accessibility of products and services
Functional Approach
re-write Annex I along EN
Focus on a11y reporting, not CE-mark
e.g. Global Accessibility Reporting Initiative

9. CE-mark advancing a11y? PROMOTE accessibility? EMPOWER consumers?
based on the current formulation neither Device A nor B would be allowed on the market
fewer products on the market place
EMPOWER consumers?
one label cannot answer if a device is accessible yes or no
unlikely as the level of knowledge about labels among consumers is very limited
what would it mean to the consumer if Device A or Device B would get the CE-mark?
IMPROVE accessibility?
compliance focused versus innovation driven

10. How To Maximise Accessibility?
Empower consumers
Functional Approach
Focus on a11y reporting, not CE-mark

11. More Information
Michael Milligan Secretary General Thomas Barmueller Director EMEA Sabine Lobnig Deputy Director Comms & Regulatory