The European Accessibility Act, Directive (EU) 2019/882, applies from 28 June 2025 and covers e-commerce services. Online shops must meet the four accessibility principles of perceivability, operability, understandability and robustness, and must provide information on the accessibility of the products and services they sell when the responsible economic operator supplies it. Product content therefore needs alt text, accessible documents and accessibility attributes.
The European Accessibility Act (EAA), Directive (EU) 2019/882, has applied since 28 June 2025 through national transposition laws, and e-commerce services are within its scope. For product content, the EAA creates two kinds of work: making product pages, images and documents accessible to people with disabilities, and displaying accessibility information about the products sold. Both depend on structured data and asset metadata held in PIM (product information management) and DAM (digital asset management) systems.
This article describes the obligations factually; it does not constitute legal advice.
What does the EAA require from e-commerce services?
Article 2(2)(f) brings e-commerce services into scope, defined in Article 3(30) as services provided at a distance through websites and mobile device-based services, by electronic means, to conclude a consumer contract. Recital 43 confirms that the e-commerce obligations apply to the online sale of any product or service. Member States had to transpose the directive by 28 June 2022 and apply the measures from 28 June 2025 (Article 31).
Annex I sets the requirements most relevant to product content:
| Annex I reference | Requirement | Product content implication |
|---|---|---|
| Section III(c) | Websites and mobile applications accessible in a consistent and adequate way, applying the four principles | Alt text for product images, captions for video, accessible tables and documents |
| Section IV(g)(i) | Provide information concerning the accessibility of the products and services being sold, when provided by the responsible economic operator | Accessibility attributes in the PIM, displayed on product pages |
| Section IV(g)(ii) | Accessible identification, security and payment functionality | Checkout and account flows (outside PIM scope) |
| Section IV(g)(iii) | Identification methods, electronic signatures and payment services that apply the four principles | Checkout and identity providers |
The directive expresses the four principles as perceivability, operability, understandability and robustness. They are the same principles that structure WCAG, the Web Content Accessibility Guidelines, which is why accessibility audits of product pages usually test against WCAG success criteria. For product content teams, perceivability carries most weight: a product image without a text alternative, or a specification shown only as an image, cannot be perceived by a screen reader user.
Who is exempt, and what transition applies?
Article 4(5) exempts microenterprises providing services from the accessibility requirements. A microenterprise employs fewer than 10 people and has annual turnover or a balance sheet total not exceeding EUR 2 million. Article 32 lets Member States set a transitional period ending on 28 June 2030 for services provided with products lawfully used before 28 June 2025, and allows service contracts agreed before that date to run until expiry, for at most five years.
What do manufacturers have to provide?
Products covered by the EAA, such as computers, smartphones, e-readers and self-service terminals, carry their own requirements. Annex I Section I requires information on the use of the product, including labelling, instructions and warnings, to be made available via more than one sensory channel, presented in fonts of adequate size and suitable shape, with sufficient contrast. Instructions must describe the product's accessibility functions, how to activate them and their compatibility with assistive technologies. This content usually originates in the PIM and must reach retailers through syndication, since retailers display it under Section IV(g)(i).
How should PIM and DAM support accessible product content?
Accessibility becomes a set of attributes, asset fields and quality rules:
- Alt text per image and per language, stored in the DAM or PIM with the asset, following product image standards and DAM metadata design.
- Accessibility attributes for products that have them: features, supported assistive technologies, compliance statements.
- Accessible documents: tagged PDFs or HTML versions of manuals and safety sheets.
- Video assets with captions and transcripts.
- Readable text: structured specifications in tables with headers, avoiding information embedded only in images.
- Completeness rules that flag missing alt text before publication, with named owners under product data governance.
Generative AI can draft alt text at scale, but review rules apply, as outlined in the guide to generative AI for product descriptions. Product images showing text, such as packaging, need descriptions that convey that text.
Key takeaways
- Directive (EU) 2019/882 has applied since 28 June 2025 and covers e-commerce services offered to consumers.
- Online shops must meet the principles of perceivability, operability, understandability and robustness, which affects images, video and documents.
- Shops must show accessibility information about products when the responsible economic operator provides it.
- Microenterprises providing services are exempt; transitional provisions run to 28 June 2030 in defined cases.
- Treat alt text, accessible documents and accessibility attributes as governed PIM and DAM data.
Frequently asked questions
Does the European Accessibility Act apply to all online shops?
Directive (EU) 2019/882 applies to e-commerce services offered to consumers in the EU from 28 June 2025, as transposed into each Member State's law. Microenterprises providing services, meaning those with fewer than 10 employees and annual turnover or balance sheet not exceeding EUR 2 million, are exempt from the service accessibility requirements. National laws may differ in detail.
What accessibility information must a webshop show about products?
Annex I, Section IV(g)(i) requires e-commerce services to provide the information concerning accessibility of the products and services being sold when this information is provided by the responsible economic operator. In practice, the shop must display accessibility information that manufacturers or suppliers supply, such as accessibility features or compatibility with assistive technologies.
Is there a transition period under the European Accessibility Act?
Article 32 allows Member States to provide a transitional period ending on 28 June 2030 for services using products lawfully used before 28 June 2025. Service contracts agreed before that date may continue until they expire, for at most five years. Self-service terminals may remain in use until the end of their economically useful life, up to 20 years.
For coverage of PXM, PLM and product compliance, including PPWR and DPP, see the independent resource PXM Atlas.