Regulatory Product Marks & Labeling
ITI recommends that the United States and EC strive toward greater regulatory alignment on product marks and labeling for ICT products. Countries around the world are increasingly requiring regulatory marks and labels on ICT products, with more labels for energy and environmental requirements expected in the near future. Manufacturers are struggling to find the necessary space to accommodate these labels on devices that are manufactured for a global market. The problem is exacerbated for small products with limited surface areas for product marks and labels. As ICT products become overcrowded with marks and other information, customers are more likely to ignore what they perceive as clutter, and government surveillance for regulatory compliance is not well served.
Without a global body to govern or coordinate these national requirements, industry and regulators will have to work together to find a solution. ITI believes the United States and EC should take this opportunity to address the issue. There should be a joint regulatory effort to eliminate requirements for product marks and labels to display nonessential information. Manufacturers should be allowed greater flexibility to place information deemed essential on the product, in the product manual, on packaging, or on the manufacturer's website.
ITI is therefore urging in the T-TIP negotiations greater regulatory alignment between the United States and EC on ICT product marks and labeling, which will provide needed global leadership on this issue of importance to our industry.
The global ICT response to the accessibility needs of people with disabilities and age-related limitations has been accelerating in the past decade. This activity has been spurred in large part by U.S. leadership and by industry support for the World Wide Web Consortium's Web Content Accessibility Guidelines. As a result, numerous technical advancements in hardware and software have created improvements in video, data display, sound, voice and touch technologies, resulting in improved access for individuals with accessibility needs.
Governments are paying greater attention to the issue of accessibility due to a variety of factors, including the increasing role of ICT in national economies, the rapid migration of government services and data to the Internet, and the expansion of entertainment and communication services via the Internet and wireless technologies. Both the United States and Europe are in the process of identifying and updating ICT accessibility technical criteria. ITI members have supported this effort, including the commitment of both governments to work together to align their respective requirements. A common approach on accessibility will help streamline transatlantic trade in accessible ICT solutions, and create greater incentives for business to invest in new innovation. It is equally important, however, that both governments align conformity assessment requirements.
When the United States adopted ICT accessibility standards for public procurements, federal experts evaluated various approaches to helping agencies identify products and services that conform to the new standards. Ultimately, they decided to adopt the supplier's declaration of conformity (SDoC) model, which allows manufacturers to evaluate and report conformance through the use of such tools as the Voluntary Product Accessibility Template[TM] (VPAT[TM]). Under this approach, the market for accessible ICT has thrived in the United States. Given the EC's long-standing support for SDoC, we believe that adoption of a common approach on conformity assessment based on SDoC principles will magnify the benefits of US-EC alignment on accessibility, while reducing roadblocks to new accessibility technologies.
In the T-TIP context, ITI is recommending that the two governments continue to work together to achieve a harmonized approach to ICT accessibility, including alignment on the timing of implementation of the forthcoming requirements. This will help expand consumer access to the latest technology while avoiding unnecessary costs due to redundant or contradictory administrative requirements. A common approach on ICT accessibility can also serve as a model for other nations that are looking to advance opportunities for citizens with disabilities.
Mr. Chairman, Members of the Subcommittee, the opportunities and challenges presented by the T-TIP negotiations are considerable and exciting. A successful outcome is by no means assured as there are some significant differences in how we run our two economies. Nevertheless, we remain optimistic that a deal can be achieved, and look forward to working with you and other Members of Congress on finding solutions for next-generation trade issues impacting the high-tech sector, many of which we feel can be advanced in the T-TIP negotiations.
Thank you for this opportunity to provide comments on the Transatlantic Trade and Investment Partnership. I will be happy to answer any questions you may have.
Read this original document at: http://docs.house.gov/meetings/IF/IF17/20130724/101197/HHRG-113-IF17-Wstate-GarfieldD-20130724.pdf