Separate product checks from service checks
For products, prepare the file a market surveillance authority would need to evaluate the product against the EAA: product identification, role in the supply chain, applicable accessibility requirements, conformity assessment, EU declaration of conformity where relevant, CE-marking evidence where relevant, technical documentation, and any Article 14 assessment relied on.
For services, prepare the information required to assess service compliance: the covered service, the accessibility requirements applied, the information made available to users about how the service meets those requirements, complaint or report handling, corrective action status, and the authority contact owner.
- Route product requests to the owner of the technical file, conformity assessment, EU declaration of conformity, and accessibility test evidence.
- Route service requests to the owner of the service description, user-facing accessibility information, support process, complaint log, and remediation plan.
- If the same journey includes a product and a service, answer both parts separately so the authority can see which evidence belongs to which obligation.
Articles 19 and 23 distinguish product market surveillance from procedures for checking service compliance, complaints, reports, and corrective action.
Commission overview confirming that the EAA covers selected products and services and aims to remove barriers caused by divergent Member State rules.
ETSI overview for the ICT accessibility standard often used to structure technical evidence for digital products and services.