Law / France

Code de la consommation, accessibility requirements for products: duties of manufacturers, authorised representatives, importers and distributors (transposition of Directive (EU) 2019/882)

Code de la consommation art. L. 412-13, D. 412-49 et D. 412-51 à D. 412-56, D. 412-59 à D. 412-62 et R. 451-4; arrêté du 9 octobre 2023, chapitres Ier et II

In force since 28 Jun 2025.

An accessibility requirements rule binding public and private bodies.

Instrument type: a regulation made under an act

What it requires

If you place on the market in France after 28 June 2025 a consumer general purpose computer hardware system or its operating system, a payment terminal, an automated teller machine, ticketing machine, check-in machine or interactive self-service information terminal (other than one installed as an integral part of a vehicle, aircraft, ship or rolling stock), consumer terminal equipment with interactive computing capability used for electronic communications services or for accessing audiovisual media services, or an e-reader, design and make it to meet the accessibility requirements of chapters I and II of the Arrêté of 9 October 2023 (Code de la consommation, Art. L. 412-13, I and D. 412-49).
Give the product accessible information on its operation and accessibility features, on the product itself where possible, with labelling, instructions and warnings available through more than one sensory channel (Arrêté of 9 October 2023, Art. 1 and 2).
Give the product, including its user interface, features, elements and functions that let persons with disabilities access, perceive, operate, understand and control it, including alternatives to sight, hearing, speech and touch where it communicates, uses speech, visual elements, colour or sound (Arrêté of 9 October 2023, Art. 3).
Make the support services for the product (help desks, call centres, technical support, relay and training services) give information on its accessibility and its compatibility with assistive technologies through accessible modes of communication (Arrêté of 9 October 2023, Art. 4).
Unless the product is a self-service terminal, make its packaging, and the installation, maintenance, storage and disposal instructions that are not supplied on the product, accessible (Arrêté of 9 October 2023, Art. 5 to 7).
Where the arrêté does not address a function, make that function accessible by meeting the functional performance criteria (Arrêté of 9 October 2023, Art. 13 and 14).
As manufacturer, place on the market only appliances designed and made to meet the requirements, draw up the technical documentation, apply the conformity assessment procedure of the annex, and once conformity is shown draw up the EU declaration of conformity and affix the CE marking (Code de la consommation, Art. D. 412-51, 1° and 2°, D. 412-61 and D. 412-62).
As manufacturer, keep the technical documentation and the EU declaration of conformity for five years after the product is placed on the market (Art. D. 412-51, 3°).
As manufacturer, put procedures in place so that series production stays conforming, taking account of changes to the design or characteristics of the product and to the harmonised standards or technical specifications against which conformity is declared (Art. D. 412-51, 4°).
As manufacturer, mark the product with a type, batch or serial number, with your name or trademark and a single postal address, and supply instructions and safety information in French for products made available in France (Art. D. 412-51, 5° to 7°).
As manufacturer, take corrective action at once if you consider a product you placed on the market non-compliant, inform the national authorities of the Member States where it was made available, and keep a register of non-compliant products and of the related complaints (Art. D. 412-51, 8°).
As manufacturer, on a reasoned request of the market surveillance authorities give them all the information and documents needed to show that the product conforms, in a language they readily understand, and cooperate in any measure to remove the non-conformity (Art. D. 412-51, 9°).
As authorised representative, hold a written mandate that lets you at least keep the EU declaration of conformity and the technical documentation available to the authorities for five years, supply information and documents on a reasoned request, and cooperate with them; the manufacturer cannot assign to you its design and production duty or the drawing up of the technical documentation (Art. D. 412-52).
As importer, place on the market only conforming products, and check before doing so that the manufacturer applied the conformity assessment and drew up the technical documentation, that the product bears the CE marking and comes with the required documents, and that the manufacturer marked it with its identification and details; do not place on the market a product you consider non-compliant until it is brought into conformity, and inform the manufacturer and the market surveillance authorities (Art. D. 412-53, 1° to 3°).
As importer, mark the product with your name or trademark and address, check that the instructions and safety information are in French, keep storage and transport conditions that do not compromise conformity, keep a copy of the EU declaration of conformity available to the authorities for five years and make sure the documentation can be supplied to them on request (Art. D. 412-53, 4° to 7°).
As importer, take corrective action and inform the national authorities and keep a register of non-compliant products and complaints, and on a reasoned request give the authorities the information and documents needed, which they make available to consumers on request in an accessible format unless confidentiality under Article 17 of Regulation (EU) 2019/1020 prevents it (Art. D. 412-53, 8° and 9°).
As distributor, act with due care, check before making a product available that it bears the CE marking and comes with the required documents and with instructions and safety information in French, and that the manufacturer and importer marked it and gave their details; do not make available a product you consider non-compliant until it is brought into conformity, and inform the manufacturer or importer and the authorities (Art. D. 412-54, 1° to 3°).
As distributor, keep storage and transport conditions that do not compromise conformity, take corrective action or withdraw a product you placed on the market that you consider non-compliant and inform the national authorities, and on a reasoned request give the authorities the information and documents needed and cooperate (Art. D. 412-54, 4° to 6°).
If you place a product on the market under your own name or trademark, or modify a product already placed on the market so that conformity may be compromised, you carry the manufacturer's duties (Art. D. 412-55).
On request of the market surveillance authorities, identify any economic operator that supplied you with a product and any to which you supplied one, for five years from the supply (Art. D. 412-56).
The accessibility requirements apply only to the extent that compliance does not require a significant change amounting to a fundamental alteration of the nature of the product and does not impose a disproportionate burden; if you receive funding from sources other than your own resources to improve the accessibility of a product, you cannot rely on the disproportionate burden for it (Art. L. 412-13, II).
If you rely on either defence, assess it on the criteria of the annex to Article D. 412-60, keep the results for five years from the last making available of the product, give the authorities a copy on request, state the requirements concerned in the EU declaration of conformity, and inform the market surveillance authorities of the Member State where the product is placed on the market (Art. D. 412-60, I and IV, and D. 412-61, I).
Enterprises of fewer than ten persons in the field of products whose annual turnover or balance sheet total does not exceed EUR 2 million need not provide the evidence of the assessment or the notification, but must give the authorities the facts relevant to the assessment if they ask and have chosen to rely on the defence (Art. D. 412-60, II and IV).
Products that conform to harmonised standards or technical specifications, or parts of them, are presumed to meet the accessibility requirements those standards or specifications cover (Art. D. 412-59).

These lines are LexLint's reading of the law's text.

If you get it wrong

Criminal exposureYes

Criminal exposure note

Article R. 451-4 punishes the acts it lists with the fine for contraventions of the fifth class. Article 131-13 of the Code pénal sets that fine at EUR 1,500 at most, raised to EUR 3,000 for a repeat offence where the regulation so provides. Article 131-41 makes the maximum for a legal person five times the natural-person rate, which is EUR 7,500, and Article 132-15 makes it ten times for a legal person that repeats the same contravention within a year, which is EUR 15,000.

Penalty structure

Tiers under Article R. 451-4, a fifth-class contravention with no daily amount: a natural person up to EUR 1,500, and up to EUR 3,000 on repeat (Code pénal, Art. 131-13 and 132-11); a legal person up to EUR 7,500 (Art. 131-41), and up to EUR 15,000 on repeat within a year (Art. 132-15). Beside the fine, Article L. 521-1 of the Code de la consommation lets the agents enjoin compliance with a daily periodic penalty of at most EUR 3,000 and a liquidated total of at most EUR 300,000. Article 132-7 of the Code pénal makes fines for contraventions accumulate with each other, so several contraventions found together are each fined.

Rule: Fixed only
As of: 9 November 2026
Currency: EUR
Fixed cap: 7,500

Who enforces it

Enforcement body

The agents of competition, consumer affairs and fraud control (the DGCCRF, Direction générale de la concurrence, de la consommation et de la répression des fraudes) under Article L. 511-25-1 of the Code de la consommation

What this law does

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Research summary

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Article 4(1) of Directive (EU) 2019/882 requires Member States to ensure that economic operators place on the market only products, and provide only services, that comply with the accessibility requirements of its Annex I. Article L412-13 of the Code de la consommation requires economic operators to place on the market products, and provide services, that meet the accessibility requirements set by a joint order of the ministers for the economy and for persons with disabilities.

Article 16 of the Act of 9 March 2023, which inserted Article L412-13, applies it to products placed on the market after 28 June 2025.

Article D412-49 applies the section to consumer general purpose computer hardware systems and their operating systems, payment terminals, automated teller machines, ticketing machines, check-in machines, interactive self-service information terminals (excluding terminals installed as integrated parts of vehicles, aircraft, ships or rolling stock), consumer terminal equipment with interactive computing capability used for electronic communications services or for accessing audiovisual media services, and e-readers.

Article 1 of the Arrêté of 9 October 2023 requires products to be designed and made so as to maximise their foreseeable use by persons with disabilities, and to come with accessible information on their operation and accessibility features. The chapter of the arrêté on packaging and installation instructions does not apply to self-service terminals.

Article D412-59 presumes products that conform to harmonised standards, or parts of them, whose references are published in the Official Journal of the European Union to meet the accessibility requirements, to the extent those standards cover them.

A manufacturer must place on the market only appliances designed and made to meet the requirements of the arrêté, draw up the technical documentation, apply the conformity assessment procedure of the annex, and, once conformity is shown, draw up an EU declaration of conformity and affix the CE marking. A manufacturer keeps the technical documentation and the EU declaration of conformity for five years after the product is placed on the market.

A manufacturer that considers a product it placed on the market non-compliant takes the corrective measures needed at once, informs the national authorities of the Member States where the product was made available, and keeps a register of non-compliant products and of the related complaints.

On a reasoned request of the market surveillance authorities the manufacturer supplies the information and documents showing conformity, and those authorities make them available to consumers on request in an accessible format unless confidentiality under Article 17 of Regulation (EU) 2019/1020 prevents it. Décret 2026-883 of 23 September 2026, published on 24 September 2026, strengthened the application of the accessibility provisions of the Code de la consommation.

Article D412-51 as amended is in force from 25 September 2026. The decree also inserted Article D412-50-1 after Article D412-50. A manufacturer may appoint an authorised representative by written mandate, but cannot assign to the representative the design and production duty of point 1 of Article D412-51 or the drawing up of the technical documentation.

An importer places on the market only compliant products, checks before doing so that the manufacturer carried out the conformity assessment and drew up the technical documentation and that the product bears the CE marking, and does not place a product it considers non-compliant on the market until it has been brought into conformity. An importer keeps a copy of the EU declaration of conformity at the disposal of the authorities for five years.

A distributor acts with due care, checks before making a product available that it bears the CE marking and comes with the required documents and with instructions in French, and does not make available a product it considers non-compliant until it has been brought into conformity.

An importer or distributor is treated as a manufacturer, with the duties of Article D412-51, if it places a product on the market under its own name or trademark or modifies a product already placed on the market so that conformity may be compromised. Each economic operator identifies, on request of the market surveillance authorities, the operator that supplied it with a product and any operator it supplied, and can do so for five years from the supply.

The accessibility requirements apply only to the extent that compliance does not require a significant change amounting to a fundamental alteration of the nature of the product, and does not impose a disproportionate burden on the economic operators concerned. An operator that receives public or private funding from sources other than its own resources to improve the accessibility of a product cannot rely on the disproportionate-burden defence for that product.

Operators keep the evidence for the assessment of the defence for five years from the last making available of a product, and give a copy of the assessment to the market surveillance authorities on request. An operator relying on the fundamental-alteration or disproportionate-burden defence informs the market surveillance authorities of the Member State where the product is placed on the market.

Enterprises of fewer than ten persons in the field of products whose annual turnover or balance sheet total does not exceed EUR 2 million need not provide the evidence of the assessment, but must give the authorities the relevant facts on request if they rely on the defence. Where an operator relies on the defence, the EU declaration of conformity states the accessibility requirements concerned.

Article L511-25-1 names the agents of competition, consumer affairs and fraud control among those empowered to investigate and record infringements of Article L412-13. Where it is established that products do not comply with the regulation in force or present a danger, the administrative authority may order by arrêté the suspension of marketing, the withdrawal, the recall and the destruction of the products.

Where products do not comply, the agents may order them brought into conformity at the operator's cost within a period they set. After adversarial proceedings the agents may enjoin a professional to comply within a reasonable period and attach a daily periodic penalty of at most EUR 3,000, the total liquidated being at most EUR 300,000.

Article R451-4 punishes with the fine for contraventions of the fifth class, among other acts, importing or placing on the market a product that has not undergone the EU conformity assessment. It also punishes the failures of manufacturers, importers and distributors that it lists under the duties of Articles D412-51, D412-53 and D412-54 (point 4° prints the references to Article D412-51 as D. 451-51).

Article R451-4 provides that repeat offending is punished under Articles 132-11 and 132-15 of the Code pénal. The fine for contraventions of the fifth class is at most EUR 1,500, a ceiling that Article 131-13 of the Code pénal raises to EUR 3,000 for a repeat offence where the regulation so provides. For a legal person already finally convicted of the same fifth-class contravention within a year, the maximum rate is ten times the natural-person rate, which gives EUR 15,000.

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Page updated 9 November 2026.