Mobile-ready hero images and front-of-pack images are exempt because the particular presentation of text is essential to the information being conveyed. Back-of-pack images are also probably exempt for the same reason. Every other image on a retailer's website is in scope, including secondary images with off-pack text, A-plus content, media adverts, and brand.com website pages with purchasing functionality. The expectation is that the EAA will apply retroactively to all live content.

The draft technical standard (EN 301549 v4.1) implies that text within images must have an x-height of at least 2.4 millimetres when the image is displayed at approximately 60 millimetres wide, which is typical for secondary images on both mobile and desktop. This applies regardless of device. For live HTML text on websites that can be zoomed and reflowed, the minimum is an x-height of 1.2 millimetres. On contrast, the standard references WCAG 2.2 contrast ratio of at least 3:1. However, the APCA algorithm (targeting a score of at least 45) gives more accurate results on modern screens. The safest position is to test against both methods.

The currently expected date for EN 301549 v4.1 is 22 July 2026, though this date is not set in stone and could slip. It is unlikely to come sooner.

The EAA was published in June 2025, so retailers already face legal liability. The contrast criteria based on WCAG 2.2 are already live. The publication of EN 301549 simply provides a new technical interpretation of "adequate size." The draft is already publicly available for review, so the case for a grace period is weak. The more important question is how quickly retailers will act. Given their risk averse nature, the prediction is that retailers will remove non-compliant images without any grace period once they realise those images expose them to litigation risk.

Discussions with retailers are ongoing and enforcement mechanisms are not yet confirmed. At this stage, the priority is risk management: taking actions to minimise the risk of PDP images being removed. Amazon may build their own AI to check contrast and text size. Other retailers might licence Rhino. Given how retailers generally behave, they will probably shift this burden to suppliers and demand that suppliers provide evidence of compliance. Rhino can export a compliance report as a PDF for this purpose.

Anyone can notify European regulators about instances of non-compliance. So far, complaints have come from consumer and disability rights lobby groups.

The legal requirement is for "sufficient contrast" but the EAA does not specify what this means technically. Complying with WCAG 2.2 contrast ratio greater than 3:1 gives "presumed compliance." This is a low-risk position but not a zero-risk position. You could be compliant with WCAG 2.2 and still be liable if someone proved that your text did not have sufficient contrast in practice. The classic test case is lightweight fonts with similar RGB values that pass 3:1 but are visually very difficult to read. Complying with APCA (score of 45 or above) provides a different technical interpretation of "sufficient contrast" which may be acceptable as an alternative method of compliance, but this has not yet been confirmed in court. Work is ongoing to get legal confirmation of APCA as an alternative method. Ultimately, retailers will decide what they are willing to accept. More detail is available at cedc.tools/EAAcomp.html.

Anything that "has a view to concluding a consumer contract" is in scope. It is a grey area as to how far this extends with respect to media adverts, considering both the content of the advert and where it is placed. The lowest-risk position is to make all media adverts compliant. Evidence shows that adverts with text that is easy to read at a glance perform better regardless.

For byline text in images, Level A is the suggested minimum requirement, which is equivalent to an x-height of 1.2 millimetres. This area needs further industry alignment. The intention is to discuss this at the next meeting of the Cambridge mobile-ready hero images discussion group. If you are not already part of this group, you can join at lists.cam.ac.uk.

There is no mandated requirement to include these as secondary images. If they are included, they will most likely need to be compliant, even if the same information is duplicated elsewhere. The best practice is to resize and reflow the information so that it fits and is compliant, using more than one image if necessary. Including a full back-of-pack image is likely fine, as a case can be made that the particular presentation of text is essential to the information being conveyed. However, the main question is whether the retailer would be willing to keep such an image live, and the expectation is that they would not. Better to manipulate the image so that it is compliant, or omit it.

The minimum text size is an x-height of 2.4 millimetres regardless of device screen. Secondary images are shown at a size of approximately 60 millimetres on both mobile and desktop, so the x-height needs to be 2.4 millimetres when the whole image is 60 millimetres wide. A-plus content may display differently on laptops and mobiles, so the x-height requirement needs to be checked for each screen separately.

Capture a screenshot of your mobile site. You can do this from your phone or using Chrome DevTools (press F12, click the device simulation button, click the three dots above the page, and choose "capture screenshot"). Feed the screenshot to Rhino. Any text within an image needs to pass Level AAA, equivalent to an x-height of 2.4 millimetres. If it is live HTML text that can be zoomed and reflowed, the minimum requirement is Level A, equivalent to an x-height of 1.2 millimetres. Processing of laptop sites is coming soon to Rhino, but the colours and text sizes will usually be the same, so checking the mobile site is sufficient for now.

Rhino can produce PDF documents to certify compliance, but if the image contains bylines or shows text within the confines of the front of pack, a manual step is required to exclude these from the AAA compliance assessment. Ultimately it is the retailer that decides whether an image stays live or gets taken down, so the question is what evidence retailers will require. This is a discussion that still needs to happen.

Yes. Sam and Oliver can train internal creative and design teams on EAA standards. Contact them directly for more information about training options.