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In this third installment in our blog series on Sections 204 and 205 of the Twenty-First Century Communications and Video Accessibility Act (CVAA) we’ll take a high-level look at the requirements of Section 204. Section 204 of the CVAA requires that digital apparatus manufacturers who make or import apparatuses for the recording and playback of video programming for sale in the United States make digital apparatuses that designed to receive, play, and display video programming accessible to people who are blind and to people with visual impairments. Section 204 also applies to apparatuses not covered by Section 205.

This requirement applies to manufacturers of hardware and includes the software installed on the hardware by the manufacturer or directed for installation by the manufacturer. However, it does not cover software that is not provided with hardware. Thus, web-based video players or software-based media players that are provided without accompanying hardware are not covered by this section.

Section 204 also covers devices such as DVD players and portable and mobile devices with features that are used for video programming. However, only the features that are required for video programming, any controls, and user interface features used to access the programming are covered.  For example, on-screen menus must provide audio output for people who are blind or visually impaired, and any physical buttons must be accessible to a person who is blind or visually impaired.  A feature such as a key, button, or icon must be provided on all devices to all users who are deaf or hard of hearing to enable closed captions, and a feature such as a key, button, or icon must be provided to enable audio description for people who are blind or visually impaired.

In order to make digital apparatuses accessible, manufacturers who make or import apparatuses must provide audio output for covered features of the device that contain on-screen menus or visual indicators. Audio can be integrated into the device, or can be a peripheral to the device.  However, it must be available for real time access.

In next week’s post,  CVAA Sections 204 and 205 – Complying with Section 204, we’ll delve more deeply into who must comply with Section 204, what is and is not covered and how to achieve accessibility.