Fwd: EN 301 549 | Incomplete requirement for EAA "alternative to biometrics" (#480)

good comment in relation to our proposed use as a term in WCAG 3 ….

g


> Begin forwarded message:
> 
> From: "jeffreym (@jeffreym)" <gitlab@labs.etsi.org>
> Subject: Re: EN 301 549 | Incomplete requirement for EAA "alternative to biometrics" (#480)
> Date: March 2, 2025 at 1:58:14 AM PST
> To: gregg@raisingthefloor.org
> Reply-To: Human Factor TC / EN 301 549 <labs_incoming+b344b4d6dc9b725c9b295061a8424872@forge.etsi.org>
> 
> jeffreym <https://labs.etsi.org/rep/jeffreym> commented on a discussion <https://labs.etsi.org/rep/HF/en301549/-/issues/480#note_19473>:
> 
> Be careful about the word "product". A lot of ICTs are apps tied to services, and that doesn't fit the European rules around products. For example, in Europe products have to carry the CE mark either on their own casing or on the packaging in which they were sold. You just can't do that for an app or any other downloaded software since neither exists. Yes, this is an artefact of evolving technology that the law did not anticipate, but the law hasn't completely caught up and using the word "product" can imply things that really don't apply. I'm not saying you are wrong, just that we have to be VERY careful with how we use words that carry other implications. CEN/CENELEC JTC25 are currently trying to determine what a "data product" means, and that is more tied to a data object that carries a digital licence that describes how it can be used and who by. Also running into "product" implications. So just be careful. Probably better to avoid the term unless we really need it, or be VERY clear on it.
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> Reply to this email directly or view it on GitLab <https://labs.etsi.org/rep/HF/en301549/-/issues/480#note_19473>.
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