Annex 6 - EAA - Criteria for assessment of disproportionate burden

Criteria to carry out and document the assessment:

1. Ratio of the net costs of compliance with accessibility requirements to the overall costs (operating and capital expenditures) of manufacturing, distributing or importing the product or providing the service for the economic operators. Elements to use to assess the net costs of compliance with accessibility requirements:
   1. (a) criteria related to one-off organisational costs to take into account in the assessment:
      1. costs related to additional human resources with accessibility expertise;
      2. costs related to training human resources and acquiring competences on accessibility;
      3. costs of development of a new process for including accessibility in the product development or service provision;
      4. costs related to development of guidance material on accessibility;
      5. one-off costs of understanding the legislation on accessibility;
   2. (b) criteria related to on-going production and development costs to take into account in the assessment:
      1. costs related to the design of the accessibility features of the product or service;
      2. costs incurred in the manufacturing processes;
      3. costs related to testing the product or service for accessibility;
      4. costs related to establishing documentation.
2. The estimated costs and benefits for the economic operators, including production processes and investments, in relation to the estimated benefit for persons with disabilities, taking into account the amount and frequency of use of the specific product or service.
3. Ratio of the net costs of compliance with accessibility requirements to the net turnover of the economic operator. Elements to use to assess the net costs of compliance with accessibility requirements:
   1. criteria related to one-off organisational costs to take into account in the assessment:
      1. costs related to additional human resources with accessibility expertise;
      2. costs related to training human resources and acquiring competences on accessibility;
      3. costs of development of a new process for including accessibility in the product development or service provision;
      4. costs related to development of guidance material on accessibility;
      5. one off costs of understanding the legislation on accessibility;
   2. criteria related to on-going production and development costs to take into account in the assessment:
      1. costs related to the design of the accessibility features of the product or service;
      2. costs incurred in the manufacturing processes;
      3. costs related to testing the product or service for accessibility;
      4. costs related to establishing documentation.