Design, Labeling, and Use Mandates


CEA supports industry-driven solutions to ensure innovative technologies and services are accessible to disabled consumers. CEA is actively engaged on implementation of the 21st Century Communication and Video Act of 2010. 

  • August 2013 - Marking the 23rd anniversary of the passage of the landmark Americans with Disabilities Act, a diverse group of industry and accessibility advocates, including CEA’s Julie Kearney, Vice President, Regulatory Affairs, met with Secretary of State John Kerry to discuss their shared commitment to international disability rights and the ratification of the Convention on Rights of Persons with Disabilities, or "The Disabilities Treaty." 

    Ratification would ensure that the highest standard of disability rights, as upheld by the ADA, would be guaranteed to these Americans as soon as they travel overseas. In addition, the Disabilities Treaty seeks to increase economic competition by fostering new international markets for American products and technologies developed specifically for the accessibility community. 

    CEA remains committed to supporting efforts that spur innovative and industry-driven products and services for those with accessibility needs.
  •  August 2013 - In May, the FCC released a Notice of Proposed Rulemaking seeking to implement the accessibility requirements for user interfaces and video programming guides and menus in Sections 204 and 205 of the Twenty-First Century Communications and Video Accessibility Act of 2010. CEA filed initial comments on July 15 focused on the scope of products covered under Sections 204 and 205, identification of device functions that must be made accessible, user control mechanisms, and the appropriate phase-in period for compliance. CEA then filed an Ex Parte further describing CEA's views on the main issues in the proceeding on August 1, and later filed reply comments reiterating industry's positions and outstanding concerns on August 7. Finally, on August 16, CEA, together with the American Foundation for the Blind (AFB), filed an Ex Parte detailing the important areas of agreement reached between industry and disability advocates.

    CEA, AFB, and the American Council of the Blind believe that the agreements reach represent a significant step forward towards resolving the complex scoping issues of Sections 204 and 205. Discussions with the FCC on enhancing accessibility to consumer electronics continue, and more meetings and filings should be expected in the weeks ahead.
  • July 23, 2013 - CEA responded to the FCC’s Further Notice of Proposed Rulemaking pertaining to apparatus requirements for accessible emergency information and video description. In its comments, CEA noted that the Communications and Video Accessibility Act ("CVAA") does not extend emergency information or video description requirements to tablets, laptops, personal computers, smartphones, or similar devices through which consumers access linear programming via Internet Protocol ("IP") or other nontraditional means, and consequently the Commission must refrain from subjecting these devices to emergency information and video description requirements.
  • July 15, 2013 - CEA filed comments in the final phase of the FCC’s implementation of the Communications and Video Accessibility Act of 2010 (“CVAA”).  In its comments, CEA urged the FCC to follow Congressional intent in crafting regulations pertaining to the accessibility of user interfaces, and video programming guides and menus for blind and low vision consumers.
  • June 14, 2013 -FCC released an Order addressing three separate petitions; submitted by CEA, TVGuardian, and a coalition of disability advocates, each calling for the reconsideration of proposed closed captioning requirements for video delivered over Internet protocol (“IP”). The Commission’s response was a hard-fought victory for CEA, which granted us many items.  These include: (1) granting narrow class waiver for devices; (2) temporarily extending compliance deadlines for removable media players, pending a Further Notice of Proposed Rulemaking; and (3) granting CEA’s request to modify the January 1, 2014 deadline applicable to apparatus to refer only to the date of manufacture, and not to the date of importation, shipment, or sale.
  • April 1, 2013 - The FCC’s Consumer Advisory Committee has been re-chartered with Julie Kearney selected to represent CEA and our members. The Committee was established in November 2000 to make recommendations to the Commission regarding consumer issues within the jurisdiction of the Commission and to facilitate the participation of consumers (including people with disabilities and underserved populations, such as Native Americans and persons living in rural areas) in proceedings before the Commission.


CEA opposes any permanent statutory ban on voice communications (including SMS and data services) on commercial flights. CEA believes that instead of an outright ban, the Federal Aviation Administration should retain rulemaking authority over this issue. .


CEA is strongly opposed to legislation mandating the inclusion of FM tuner in mobile devices, whether as a part of a compromise between broadcasters and the content industry regarding performance royalties or as a stand-alone bill. CEA believes that such a mandate would result in higher costs for consumers, less functionality, and diminished mobile device battery life. An FM tuner mandate was considered and rejected advisory group consisting of representatives from the FCC, Federal Emergency Management Agency and public safety organizations during the implementation of the Warning, Alert, and Response Network (WARN) Act (enacted as part of P.L. 109-347) in 2006.


CEA opposes cell phone labeling requirements since all phones sold legally in the U.S. already must comply with the FCC’s safety limits for radiofrequency (RF) emissions exposure. The FCC worked with federal health and safety agencies, such as the Food and Drug Administration, to set these limits. CEA is also concerned that labeling requirements could cause confusion and create an illusion that some compliant phones are in some way “safer” than other compliant phones based on RF emissions, when any phone below this objective level is considered safe.