European Blind Union (EBU)

EBU would like to echo the concerns and recommendations expressed by its umbrella group the European Disability Forum. The Public Procurement Directive has enormous potential to foster inclusion for persons with disabilities (PWD) but it does not currently reach its full potential. The directive underserves PWD in a number of areas, particularly when it comes to support services.

The current proposal places a strong emphasis on strengthening cybersecurity and resilience, which is of course important, but risks creating new barriers for persons with disabilities -- specifically visually impaired people -- if accessibility is not structurally embedded in these measures, especially in the design and implementation of authentication and verification processes, such as captchas, multi-factor…

The European Blind Union (EBU) welcomes the revision of the Standardisation Regulation as an opportunity to remedy the current lack of meaningful participation of civil society in the standardisation system, including of persons representing persons with disabilities (PWD).

Audio description and audio subtitling are effective measures to implement accessibility for visually impaired persons. Despite the slow and challenging transposition, the revised Audiovisual Media Services Directive (AVMSD) brought positive points in terms of accessibility.

Despite growing attention to inclusion in EU sport policy, blind and partially sighted people continue to face structural barriers to accessing mainstream sport. These include inaccessible venues, a lack of adapted sport materials, and the digital inaccessibility of club websites, registration systems, and sport finders.

STRONG POINTS OF THE PROPOSAL: The proposed legal instrument is a directive, i.e., a legally binding instrument, which is necessary given that the 1998 EU Council recommendation on the parking card and the pilot project on the disability card have had limited scope and results.

The European Blind Union (EBU) strongly supports the European Commissions initiative of a legislative proposal for EU-wide Disability Card (hereafter the Card) in 2023 to ensure the free movement of people with disabilities in the EU.

EBU would like to take this opportunity to make the case for accessible tourism in the EU for blind and partially sighted travellers, building on the principle of design for all in legislation, public policies, and tourism industry.

The European Blind Union sees a potential for the ESPASS initiative to address the following indirect barrier to the mobility in the European Union of persons with disabilities: when they move their residence to another Member State, in can take a long time before they have their disability status re-assessed in the host country, which results in a period of legal limbo between the moment you stop residing a member…

We refer to our position paper of September 2021, "MEDIA funding to European film industry: Promote Equal Access to Culture for Persons with Visual Impairments in the EU" (https://www.euroblind.org/sites/default/files/documents/ebu_position_paper_on_media_funding_sept2020_final.pdf) and attach our statement of July 2022, "Creative Europe 2021-2027: where are the incentives for audio description and subtitling in…

To make the European statistical system “fit for the future” from the point of view of EBU, it is necessary to ensure that it enable the EU and Member States to deliver on their obligations under the UN Convention on the Rights of Persons with Disabilities (CRPD).