The European Commission issue a call for evidence for the evaluation of the Creative Europe programme, to which we will respond to put again our message across about promoting audio description and audio subtitling in the funding to the film industry, and to use the opportunity of the mid-term review of the Creative Europe regulation 2021-2027, to bring some benchmarking on how MEDIA funding is used to promote inclusion.
We responded to a European Commission call for evidence on the effectiveness of the EU’s legislative framework for the implementation of the Marrakesh Treaty. Besides stressing the elements already contained in our interview by the consultancy carrying out the evaluation study for the Commission, we expanded with concrete elements on the negative impact of compensation schemes put in place in some countries, building on the feedback from BSVÖ, DBSV and ONCE. We also sent our response, in the form of a position paper, to the Commission’s competent unit (DG CNECT Unit I2 Copyright), which informed us that the next step will be a targeted stakeholder consultation, end of May, during which some of our members will be directly approached, including ONCE.
At the EU Disability Platform’s sub-group Employment Package meeting of 11 May, we provided our comments on the draft guide on reasonable accommodation at work being prepared for the European Commission, and we followed this up with comments in writing. This guide will feed into our own work from the perspective of the visually impaired.
On 2 May we responded to the public consultation by the European Commission on the future European Disability Card. Meanwhile:
- The European Economic and Social Committee adopted its opinion on the matter, which largely supports our views, namely that the card should be implemented by a regulation, but not including on transitional recognition of the disability status when moving one’s residence to another EU country.
- The European Parliament’s Policy Department for Citizens’ Rights and Constitutional Affairs published a study for the Petitions Committee on “Disability assessment, mutual recognition and the EU Disability Card”. This study indicates how common European principles could be applied for CRPD-compliant disability assessment, and how the principle of mutual recognition could be applied to determinations of disability status between Member States and across the EU.
Nothing of special interest came out of the European Parliament’s Interparliamentary Committee Meeting on Reform of the European Electoral System, on 26 April, regarding the proposed new EU electoral law that takes into account the needs of visually impaired voters and candidates, except that the rapporteur is pressing the EU Council to take up this issue without further delay.
On 2 May, we submitted to the EBU Commission for Liaison with the EU a draft EBU statement for the European Parliament elections 2024. Members are invited to an ad hoc meeting (online) on 7 June, to collect reactions on this draft with a view to finalising it before the summer break. On 23 May, EBU was represented, through various national delegations, at the European Disability Forum’s 5th European Parliament of Persons with Disabilities, resulting in the adoption of their own Manifesto for the elections.
On direct request from ANEC—the European consumers’ voice in standardisation—we prepared and published an EBU statement on the need for both embossed characters and Braille marking for operating buttons of lifts. This is in the perspective of a meeting in June of the relevant working group of CEN reviewing the Accessibility to Lifts standard, where the matter of Braille will be specifically discussed. We will also possibly be represented there, also on ANEC’s request.
On 27 April, in response to the European Commission’s public consultation about a draft act for update of requirements on noise emissions from motorcycles, we responded that, while we appreciate the need to reduce the level of noise generated by thermal motorcycles, considering that the proportion of vehicles with predominantly high noise levels is progressively reversing to predominantly low-noise vehicles, we ask the European Commission to consider extending the AVAS obligation under Regulation (EU) 540/2014 to electric motorcycles, as a matter of ensuring the safety of pedestrians, specifically visually impaired pedestrians.
The European Commission published its response to the UN CRPD Committee’s questions prior to reporting, in the context of its review of the EU. While the issues we had been directly vocal about in our exchanges with the rapporteur were relatively well reflected in the CRPD’s questions, the Commission replies don’t seem to tell us anything new. Particularly disappointing is the very generic reply on how the Creative Europe programme aims to foster social inclusion. We did not expect much on the implementation of the Marrakesh Treaty in the EU given that the committees’ question on this was too open. Interesting instead is the element of response about statistics and data collection (art. 31) and disaggregating data by type of impairment: “The Washington Group short set of questions are included in the EU-SILC rolling module on health, which is conducted every three years, starting from 2022. Once data is available, the Commission will investigate the feasibility of disaggregating data by type of impairment.” The Commission however does not really address moving away from the health approach to a human rights-based approach.
After our audition in April, the rapporteur European Parliament’s CULT committee has published his draft report on 'the future of the European book sector'. The draft rather well addresses accessible books, with explicit reference to the Creative Europe programme and the Marrakesh Treaty (although without being competent to enter into considerations of author rights). The draft will be discussed by the committee on 24 May, and voted on in July.
On 24 May we circulated to our members in the EU the questions relevant to us of a questionnaire by a consultant acting for the European Commission, in view of a fact-finding study on passenger rights in bus and coach transport. The background to this is the ongoing review of the Regulation (EU) 181/2011, and the feedback from our members will provide the EBU input to this survey.