Why EU law reaches a company in Shenzhen
The European Accessibility Act is Directive (EU) 2019/882. Its scope rule is the one you already know from every other EU product regulation you've filed: the obligation attaches to the point where the product or service reaches the EU consumer, not to where the company is registered. If you place a covered product on the EU market, or if you provide a covered digital service to EU consumers, you are an "economic operator" under the directive. Your address is irrelevant.
This is not new legal thinking. It is the same principle that forced Chinese factories to put CE marks on toys, EPR numbers on packaging, LUCID registrations on Germany, Triman on France, and GPSR responsible-person data on every Amazon EU listing in 2024. The EAA uses the same machinery and the same enforcement chain.
The micro-enterprise exemption — and why it probably doesn't save you
The directive exempts micro-enterprises that provide services, but only when the company has fewer than 10 employees and annual turnover or balance sheet below €2 million. Two conditions at once. If you break either one — 10 or more employees, or more than €2 million in annual turnover — you are not a micro-enterprise and you are obliged.
Two additional traps to know before you celebrate:
The service exemption does not apply to product manufacturers
If your factory produces hardware covered by the EAA — computing equipment, smartphones, tablets, e-readers, self-service terminals, payment terminals, ticket machines — you are obliged regardless of company size.
Your EU importer or distributor will ask for the file anyway
If you're part of a larger supply chain, your EU importer or distributor will demand your technical documentation to meet their own obligations. Even a genuinely small Chinese manufacturer will be asked to produce the file.
This is the next CE marking — same machinery, different technical annex
Products covered by the EAA must carry the CE mark, be accompanied by a Declaration of Conformity, and be supported by technical documentation that an EU market surveillance authority can request at any time. The harmonised technical standard used to presume conformity is EN 301 549 V3.2.1, which incorporates WCAG 2.1 Level AA.
If you already run CE compliance, you already know the shape of the paperwork: assessment, documentation, declaration, market surveillance. The EAA plugs into the exact same chain. The only thing that changes is the technical annex — instead of electrical safety or chemical substance thresholds, it's 17 accessibility criteria grouped under four principles: Perceivable, Operable, Understandable, Robust.
What European regulators actually want on file
Not marketing copy. Not a one-page website statement. A structured self-assessment following the official European harmonised model — Commission Implementing Decision (EU) 2018/1523, adapted to the scope of Directive (EU) 2019/882. EAA-Report generates that document as a 9-page PDF:
Cover page
Global compliance score, country-specific enforcement data, unique verification reference.
Service owner identification
Scope and evaluation method under the European harmonised model.
Compliance status by WCAG principle
Perceivable, Operable, Understandable, Robust — with criterion-by-criterion Yes / Partial / No / N/A for all 17 WCAG 2.1 AA criteria.
W3C remediation guidance
Official W3C guidance for each failed or partial criterion, extracted from "Understanding WCAG 2.1" — real fixes your developers can implement today.
Non-accessible content declaration
Under Annex V of Directive 2019/882.
Feedback mechanism and enforcement procedure
Competent national authority, applicable national transposition law, exact fine range for your service country.
Legal basis
References Directive (EU) 2019/882, the European harmonised model of Decision (EU) 2018/1523 (adapted to the scope of Directive 2019/882) and EN 301 549 V3.2.1.
Country-specific enforcement data for Germany (BFSG / MLBF / BFIT-Bund), Spain (Ley 11/2023), France (Loi n° 2023-171), Italy (Stanca Act + D.Lgs. 82/2022) and the Netherlands (Wet toegankelijkheid). One PDF covers all 27 Member States.
Enforcement is real, and it has started
Fine for an inaccessible website, upheld by the Audiencia Nacional Contentious-Administrative Chamber Section 8 in February 2024 (sanction originally imposed October 2020), plus a six-month ban on concurring in proceedings for the granting of official aid. The infringement persisted after a previous 2016 sanction for the same matter.
Fine for accessibility failures on endesaclientes.com after a CERMI complaint with CENTAC and OADI technical reports confirming failure to meet WCAG Level AA.
Four supermarket giants summoned before the Tribunal Judiciaire de Paris by ApiDV and Droit Pluriel over inaccessible online grocery services. Prior formal notice issued 7 July 2025.
Civil penalty for deceptive overlay claims. UsableNet documented 119 defendants with accessibility widgets sued in May 2025 alone. Overlays are not a legal defence in the US or in the EU. Don't install one.
"There are free accessibility statement generators. Why pay €149?"
Free generators hand you a blank one-page template. You type in your company name and they produce a generic paragraph. That is not an assessment. It does not evaluate your website against the 17 WCAG 2.1 AA criteria. It does not cite the W3C's official remediation guidance for your specific failures. It does not include country-specific enforcement data. It does not follow the structure of Commission Implementing Decision (EU) 2018/1523. It does not identify the competent authority for your service country.
EAA-Report does all of that. 9 pages, 15 minutes, €149 one-time. Yours to keep. No subscription, no cloud, no account. Your data never leaves your browser.
| Alternative | Cost | What you actually get |
|---|---|---|
| Manual accessibility audit by a consultancy | €2,000 – €5,000 | Thorough, but weeks of lead time |
| Annual SaaS compliance subscription | €500 – €2,000 / year | Recurring cost, often US-focused |
| Accessibility overlay (legally discredited) | €490 – €1,990 / year | Not a defence in the EU or the US. FTC penalised accessiBe $1M. |
| EAA-Report | €149, one-time | 9-page PDF, 15 minutes, European harmonised model adapted to Directive 2019/882, yours forever |
Need multiple reports? One PDF per brand, per listing, per country.
Compliance managers often need 10, 20 or 30 reports at once — one per brand, one per ASIN family, or one per EU marketplace. We offer volume pricing on packs of 10 or more reports. Tell us how many you need and we'll send a pack quote within one business day.
Request Volume PricingFrequently asked questions
Our headquarters is in China. Why does an EU directive apply to us?
We only sell through Amazon, AliExpress and Temu. We don't have our own website. Are we still in scope?
What's the difference between being a "service provider" and a "manufacturer" under the EAA?
Do we need a different report for each EU country or is one enough?
What happens if we just ignore this?
Is this report legal advice or a certified audit?
⚠️ Important notice: All enforcement cases cited are sourced from identified public documentation. EAA-Report is a structured self-assessment tool, not legal advice and not an overlay.