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Update to the EPUB Accessibility - EU Accessibility Act Mapping #2590

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Mar 19, 2024
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Update to the EPUB Accessibility - EU Accessibility Act Mapping #2590

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Update to the EPUB Accessibility - EU Accessibility Act Mapping
gregoriopellegrino Nov 5, 2023
385ee27
Updates to EAA mapping
gregoriopellegrino Feb 12, 2024
a15dce7
mostly editorial copy-editing
nitedog Mar 18, 2024
a489d09
Update epub33/epub-a11y-eaa-mapping/index.html
gregoriopellegrino Mar 18, 2024
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Update epub33/epub-a11y-eaa-mapping/index.html
gregoriopellegrino Mar 18, 2024
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gregoriopellegrino Mar 18, 2024
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gregoriopellegrino Mar 18, 2024
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gregoriopellegrino Mar 18, 2024
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gregoriopellegrino Mar 18, 2024
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gregoriopellegrino Mar 18, 2024
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Update epub33/epub-a11y-eaa-mapping/index.html
gregoriopellegrino Mar 18, 2024
dd0c87b
Revision after Ivan and Matt comments
gregoriopellegrino Mar 18, 2024
017cc1f
Merge branch 'fxl-a11y-eaa-revision' into patch-1
gregoriopellegrino Mar 18, 2024
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Merge pull request #2609 from nitedog/patch-1
gregoriopellegrino Mar 18, 2024
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gregoriopellegrino Mar 18, 2024
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80 changes: 60 additions & 20 deletions epub33/epub-a11y-eaa-mapping/index.html
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Original file line number Diff line number Diff line change
Expand Up @@ -8,8 +8,8 @@
<script src="../common/js/css-inline.js" class="remove"></script>
<script class="remove">
var respecConfig = {
group: "epub",
wgPublicList: "public-epub-wg",
group: "pm",
wgPublicList: "public-pm-wg",
specStatus: "ED",
noRecTrack: true,
shortName: "epub-a11y-eaa-mapping",
Expand Down Expand Up @@ -58,8 +58,7 @@
disabilities to access goods and services, including ebooks, dedicated reading software, ereading
devices, and ecommerce.</p>

<p>The EAA has been approved on 27 June 2019, should be implemented by EU Member States within 28 June 2022
and will enter in force from 28 June 2025.</p>
<p>The EAA has been approved on 27 June 2019 and will come into force from 28 June 2025. The directive has already been implemented at national level in many member states and is being implemented in the remaining.</p>
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Suggested change
<p>The EAA has been approved on 27 June 2019 and will come into force from 28 June 2025. The directive has already been implemented at national level in many member states and is being implemented in the remaining.</p>
<p>The EAA was approved on 27 June 2019 and will come into force from 28 June 2025. Many member states have already implemented the directive at the national level, with the remaining states currently in the process of implementing it.</p>

"has been" suggests a continuous state from the past (e.g., "has been approved since..." but I don't think that's what you want here). The second sentence doesn't need to be passive.


<p>This note aims to demonstrate that the technical requirements of the European Accessibility Act related
to ebooks are met by the EPUB® standard.</p>
Expand All @@ -75,8 +74,8 @@ <h2>How EPUB conforming to EPUB accessibility guidelines cover European Accessib
trade sector.</p>

<p>The specifications of the EPUB standard are based on the <a
href="https://www.w3.org/wiki/Open_Web_Platform">Open Web Platform</a>: HTML, CSS, JavaScript and
SVG are the core technologies used for content creation. The use of the latter means that EPUB
href="https://www.w3.org/wiki/Open_Web_Platform">Open Web Platform</a>: HTML, CSS, JavaScript, MathML and
SVG are the core technologies used for content creation. This means that EPUB
publications can be written with a high degree of accessibility simply through the proper application of
established web accessibility techniques, namely the <a
href="https://www.w3.org/WAI/standards-guidelines/wcag/">Web Content Accessibility Guidelines</a>
Expand All @@ -88,21 +87,30 @@ <h2>How EPUB conforming to EPUB accessibility guidelines cover European Accessib

<ul>
<li>discoverability of accessibility features of publications;</li>
<li>evaluation and certification of accessible EPUB publications.</li>
<li>conformance to Web Content Accessibility Guidelines;</li>
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You're referring to WCAG here, at least by using caps, so there should be a reference.

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Sorry, what does it mean?

<li>specific EPUB requirements for accessibility;</li>
<li>evaluation and conformance reporting of accessible EPUB publications.</li>
</ul>

<p>Providing accessibility metadata facilitates informed decisions about the usability of an EPUB
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Does this paragraph belong in this document? It also comes from the Accessibility standard's intro.

publication. Consumers can examine the characteristics of the content and decide whether an EPUB
publication is appropriate for each need.</p>

<p>While it has always been possible to create EPUB publications with a high degree of accessibility, this
document also establishes formal requirements for contents to be certified as accessible. These
<p>While it has always been possible to create EPUB publications with a high degree of accessibility,
this document establishes the formal accessibility requirements that content must meet to be declared
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This paragraph also looks like a copy. It's talking about "this document" establishing the requirements for the EPUB Accessibility standard.

I think this whole section needs some rewriting to focus more on how the EPUB Accessibility standard matches the requirements of the EAA. Otherwise, maybe the title needs changing as I don't get a connection from this text to the EAA.

as conformant with the EPUB Accessibility. These
requirements provide EPUB creators with a clear set of guidelines for evaluating their content with
respect to quality certification and enable it.</p>
respect to quality assurance and enable it.</p>

<p>The EPUB Accessibility does not target a single version of EPUB (most commercially available publications
are in EPUB 3 or EPUB 2 format). It is designed to be applicable to all EPUB publications conforming to
any version or profile, including future versions of the standard.</p>

<p>The EPUB format provides the ability to create reflowable publications (whose content adapts to the user's viewport,
depending also on the user's chosen graphical characteristics, such as font size, line spacing, etc.), but it also
allows the creation of EPUB Fixed Layout in which each element is positioned absolutely on the page (mainly used
for publications such as comics, illustrated children’s books and art books). Specific features of Fixed Layout EPUBs
should be considered in the light of all applicable accessibility requirements.</p>
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This is a long sentence. Maybe break it up like this (also offering a possible rewrite for the last sentence, but not sure if that's exactly what you're after, or if it should be in a note, so feel free to ignore!):

Suggested change
<p>The EPUB format provides the ability to create reflowable publications (whose content adapts to the user's viewport,
depending also on the user's chosen graphical characteristics, such as font size, line spacing, etc.), but it also
allows the creation of EPUB Fixed Layout in which each element is positioned absolutely on the page (mainly used
for publications such as comics, illustrated children’s books and art books). Specific features of Fixed Layout EPUBs
should be considered in the light of all applicable accessibility requirements.</p>
<p>The EPUB format provides the ability to create reflowable publications whose content adapts to the user's viewport, including the user's chosen graphical characteristics, such as font size, line spacing, etc. It also
allows the creation of fixed layout content in which each element is positioned absolutely on the page (mainly used
for publications such as comics, illustrated children’s books and art books). Specific features of fixed layouts (e.g., zooming of text) present challenges for accessibility, however. Authors need to consider these challenges and how best they can mitigate them before employing fixed layouts. Refer to the EPUB Fixed Layout Guidelines for more information.</p>

</section>
<section id="mappings">
<h2>Mappings</h2>
Expand Down Expand Up @@ -203,11 +211,15 @@ <h6>(v)</h6>
spacing between letters, lines and paragraphs</p>
</blockquote>

<p>This requirement is satisfied by WCAG requirement <a
href="https://www.w3.org/TR/WCAG2/#resize-text">1.4.4 Resize text</a> (level AA) and
by WCAG requirement Contrast 1.4.3 <a
href="https://www.w3.org/TR/WCAG2/#contrast-minimum">1.4.3 Contrast (Minimum)</a>
(level AA).</p>
<p>This requirement is satisfied by WCAG Success Criterion <a
href="https://www.w3.org/TR/WCAG2/#resize-text">1.4.4 Resize text</a> (level AA), WCAG Success Criterion
<a href="https://www.w3.org/TR/WCAG2/#contrast-minimum">1.4.3 Contrast (Minimum)</a> (level AA)
and WCAG Success Criterion <a href="https://www.w3.org/TR/WCAG2/#text-spacing">1.4.12 Text Spacing</a> (level AA).</p>

<div class="note">
<p>Specific features (like adjustable spacing between letters, lines and paragraphs) of Fixed Layout EPUBs should
be considered in the light of all applicable accessibility requirements.</p>
</div>
</section>

<section id="annex-I-section-III-b-vi">
Expand All @@ -218,9 +230,11 @@ <h6>(vi)</h6>
content and</p>
</blockquote>

<p>This requirement is satisfied by WCAG requirement <a
<p>This requirement is satisfied by WCAG Success Criterion <a
href="https://www.w3.org/TR/WCAG2/#non-text-content">1.1.1 Non-text Content</a>
(level A).</p>
(level A), WCAG Success Criterion <a href="https://www.w3.org/TR/WCAG2/#audio-only-and-video-only-prerecorded">1.2.1
Audio-only and Video-only (Prerecorded)</a> (level A) and WCAG Success Criterion
<a href="https://www.w3.org/TR/WCAG2/#captions-prerecorded">1.2.2 Captions (Prerecorded)</a> (level A).</p>
</section>

<section id="annex-I-section-III-b-vii">
Expand Down Expand Up @@ -306,7 +320,7 @@ <h6>(ii)</h6>
Accessibility-Supported Ways of Using Technologies</a>;</li>
<li>WCAG conformance requirement <a href="https://www.w3.org/TR/WCAG2/#cc5">
Non-Interference</a>;</li>
<li>WCAG principle <a href="https://www.w3.org/TR/WCAG2/#robust">4 Robust</a> (level
<li>WCAG Principle <a href="https://www.w3.org/TR/WCAG2/#robust">4 Robust</a> (level
A);</li>
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These references are kind of confusing. Principles contain all levels of success criteria. Do you mean only the level A requirements of Robust principle here? Or can the level reference just be deleted as unnecessary?

<li>WCAG Guideline <a href="https://www.w3.org/TR/WCAG2/#keyboard-accessible">2.1
Keyboard Accessible</a> (level A).</li>
Expand All @@ -328,9 +342,15 @@ <h6>(iii)</h6>
<li>EPUB specifications section <a data-cite="epub-33#sec-nav-toc">TOC nav</a>;</li>
<li>EPUB Accessibility <a data-cite="epub-a11y-11#sec-page-nav">Page Navigation</a>
requirement;</li>
<li>WCAG Principle <a href="https://www.w3.org/TR/WCAG2/#adaptable">1.3 Adaptable</a>
(level A).</li>
<li>WCAG Guideline <a href="https://www.w3.org/TR/WCAG2/#adaptable">1.3 Adaptable</a>
(level A);</li>
<li>WCAG Success Criterion <a href="https://www.w3.org/TR/WCAG2/#reflow">1.4.10 Reflow</a> (level AA).</li>
</ul>

<div class="note">
<p>Specific features (like flexibility and choice in the presentation of the content) of Fixed Layout EPUBs
should be considered in the light of all applicable accessibility requirements.</p>
</div>
</section>

<section id="annex-I-section-IV-f-iv">
Expand Down Expand Up @@ -379,5 +399,25 @@ <h6>(vi)</h6>
</section>
</section>
</section>
<section id="exemptions">
<h2>Metadata to describe possible exemptions</h2>

<p>The European Accessibility Act foresee three possible exemptions to meeting its requirements:</p>
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Suggested change
<p>The European Accessibility Act foresee three possible exemptions to meeting its requirements:</p>
<p>The European Accessibility Act foresees three possible exemptions to meeting its requirements:</p>


<ul>
<li>to microenterprises providing services that employ fewer than ten people and have an annual turnover not exceeding
EUR 2 million or an annual balance sheet total not exceeding EUR 2 million;</li>
<li>when compliance with accessibility requirements would impose a disproportionate burden on economic operators as
defined in Annex VI of the Directive;</li>
<li>when the compliance with accessibility requirements require a significant change in a product or service
that results in the fundamental alteration of its basic nature as described in article 4 of the Directive.</li>
</ul>

<p>Metadata standards for digital publishing ONIX (via <a href="https://ns.editeur.org/onix/en/196">Code List 196</a>)
and EPUB metadata (via <a href="https://www.w3.org/TR/epub-a11y-exemption/">The EPUB Accessibility exemption property</a>)
provide specific codes for communicating to the digital publishing supply chain (and the end user) any exceptions related
to specific publications. In any case economic operators will be responsible to provide the necessary documentation to
support the exception they invoke.</p>
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I do not know about the politics here, but from a usual W3C style perspective it may be better to put here a formal reference to the exemption note, so that it would also appear in the references' section below.

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em dashes might also help the sentence here, as the references to onix and epub don't flow with the rest: "Metadata standards for digital publishing — ... — provide specific codes..."

The specific standards might also be better written into a note after the paragraph. For example: "NOTE: Refer to ONIX Code List 196 [onix] and The EPUB Accessibility exemption property [epub-a11y-exemption] for more information on expressing these codes."

</section>
</body>
</html>