What Article 7 Means for Manufacturers: Technical Docs, Declaration, and CE Marking
If you make e-readers, smartphones, payment terminals, self-service terminals or other products listed in Article 2(1) of Directive (EU) 2019/882, the European Accessibility Act applies to you from 28 June 2025. This article walks through exactly what Article 7 requires: the technical documentation, the conformity assessment, the EU declaration of conformity, the CE marking, and how long you must keep every record.
What Article 7 Requires and in What Order
Article 7 of the EAA sets out the obligations that sit with the manufacturer. Before a covered product can be placed on the market, you must:
- Draw up the technical documentation under Annex IV.
- Carry out the conformity assessment procedure.
- Draw up the EU declaration of conformity.
- Affix the CE marking.
- Keep the technical documentation and the EU declaration of conformity available for 5 years after the product was placed on the market.
These steps are not optional and they are not one-time actions. The declaration must be continuously updated, and if you later find a product is not in conformity you must act immediately.
The Technical Documentation (Annex IV)
The technical documentation is your evidence file. It shows how you assessed your product against the accessibility requirements in Annex I, Sections I and II. Article 14 requires you to assess your product against those requirements and to document the assessment.
Annex IV sets out what the documentation must cover: a description of the product and its intended use, a list of the harmonised standards or other technical specifications applied, details of any accessibility solutions adopted where a requirement could not be met, and the results of any tests or checks carried out.
One point to note: Article 14(4) gives microenterprises dealing with products an exemption from the documentation requirement. If your company employs fewer than 10 persons and your annual turnover or balance sheet total does not exceed EUR 2,000,000, you do not have to produce the full documentation file, but you must give the market surveillance authority the relevant facts if it requests them.
The Conformity Assessment Procedure
Article 7(2) refers to the internal production control procedure. This is the manufacturer's sole responsibility: you assess your own product against the accessibility requirements and you document the findings. There is no external notified body required for most products. The route is essentially: apply the relevant harmonised standards, test or check your product, and keep the records.
Under Article 15(1), if you apply harmonised standards — currently EN 301 549 v3.2.1 (2021), which is based on WCAG 2.1 Level AA — and those standards or parts of them have been published in the Official Journal of the European Union, you are presumed to conform to the accessibility requirements covered by those standards. That presumption can be rebutted, but following the cited standard is the practical route most manufacturers take.
The EU Declaration of Conformity
Article 16 sets out what the declaration must state. It must confirm that fulfilment of the applicable accessibility requirements has been demonstrated. It must follow the model structure of Annex III to Decision No 768/2008/EC. It must be continuously updated — not a one-time document that goes stale. And by drawing it up, the manufacturer assumes responsibility for the compliance of the product.
If you have used Article 14 to claim that certain accessibility requirements create a disproportionate burden, the declaration must state which requirements are subject to that exception.
The declaration does not need to be lodged with any EU body. It must simply be in place, available, and kept up to date.
CE Marking
Article 18 governs the CE marking. It must be affixed visibly, legibly and indelibly to the product itself or to its data plate. Where that is not possible — for example, because the product is too small — it goes on the packaging and the accompanying documents. The marking must be affixed before the product is placed on the market.
The CE marking for EAA products is the same marking used for other product directives. It declares that the product conforms to all applicable requirements, including the accessibility requirements. Do not affix it before you have completed the conformity assessment and drawn up the declaration.
What Happens if You Get it Wrong
Article 22 lists the findings of formal non-compliance that market surveillance authorities look for: the CE marking affixed in violation of the rules, the EU declaration of conformity not drawn up or not drawn up correctly, technical documentation not available or not complete, and manufacturer or importer contact information absent, false or incomplete.
If a non-compliance is found and the company does not remedy it, the Member State must restrict or prohibit the product being made available or ensure it is withdrawn.
Article 7(8) also places a direct obligation on you: if you have reason to believe that a product is not in conformity, you must immediately take corrective measures or withdraw it, immediately inform the competent national authorities of the Member States where the product was made available, and keep a register of non-compliant products and of related complaints.
Article 30 confirms that each Member State sets its own penalties. The Directive only says they must be effective, proportionate and dissuasive, accompanied by effective remedial action, and take into account the extent and seriousness of the non-compliance, the number of non-complying units and the number of persons affected. No specific fine amounts are written into the Directive itself.
What to Do Now
If you make covered hardware products and have not yet worked through Article 7, here is a practical sequence:
- Confirm which of your products fall within Article 2(1) — general purpose computer hardware systems and their operating systems, payment terminals, self-service terminals, consumer terminal equipment for electronic communications or audiovisual services, and e-readers.
- Map each covered product against Annex I Sections I and II requirements.
- Apply EN 301 549 v3.2.1 (2021) as your cited standard and document where you meet it.
- Draw up the technical documentation under Annex IV.
- Complete the internal production control conformity assessment and record the results.
- Draft the EU declaration of conformity following the Annex III model, ensure it covers all applicable requirements, and set a process to keep it updated.
- Affix the CE marking before first placement on the market.
- Set a 5-year retention trigger in your document management system for the technical documentation and declaration.
- Establish an internal process to detect non-conformances and act under Article 7(8).
For a fuller overview of which companies and products the EAA covers, see our practical guide at /blog-eaa-guide.html. If you are uncertain whether your company qualifies as a microenterprise and what that means for your documentation obligations, our piece on who must comply explains the thresholds.
The EAA does not require any body to issue an official certificate, and no regulator runs a certification programme for manufacturers. What the Directive requires is your own documentation and declaration — not a badge, a widget or a third-party label.