By Catherine Saez, freelance writer
In late 2019, Hachette Livre, the world’s third largest publisher, became the 100th signatory of the Accessible Books Consortium (ABC) Charter, committing to making its products fully accessible to all users, and in particular to people living with blindness or visual impairment.
Hachette Livre is at the forefront of accessible e-book production. From 2018, all the novels it has published have been “born accessible,” that is, produced in accessible formats for visually impaired people.
Accessibility has been a priority for Hachette Livre over the last decade, with efforts spearheaded by Luc Audrain, Hachette Livre’s technical expert on digital accessibility standards.
The new European Union (EU) Directive 2019/882 on accessibility requirements for products and services brings new obligations for publishers and distributors in the European Union that need to be applied by 2025.
Luc Audrain hails the EU Directive as a necessary jolt for the publishing industry in Europe but warns that current standards, in particular “EPUB accessibility 1.0”, should be retained. Inventing a new standard, he suggests, would be detrimental to both visually impaired people and publishers.
Tell us about Hachette Livre and your role in the company.
Hachette Livre is a large global publisher with about 100 imprints. The group publishes general purpose books, such as novels, essays, primary, secondary, and higher education books on social science; personal development; tourism and cookery, and has large subsidiaries in Spain, the United Kingdom and the United States. Hachette Livre Group is the world’s third largest publisher.
I am a technical expert on digital accessibility standards and until the end of March this year, worked with Hachette for many years. Now, as a consultant I continue to represent Hachette Livre in various inter-professional standardization organizations on e-books at national, European and international levels.
Why is accessibility important for Hachette and why did the company join the ABC?
When we create content, we want it to be used by everyone, including people with visual impairment. When we began publishing e-books, we set up a publishing process that allows simultaneous publication of print and digital formats so our digital production channel runs parallel to print production. In this way, at Hachette Livre, access by visually impaired people to culture and knowledge through e-books is on an equal footing with that of sighted people.
Hachette already meets all the commitments set out in the ABC Charter, but we had no public recognition of our commitment to accessibility. Signing the ABC Charter gives us that recognition.
Coming back to the EU Directive, what is its main purpose and how will it support the objectives of the ABC?
The Directive is based on the principle of social inclusion and access to products and services for all people with disabilities. The main objective of the Directive with respect to publishing is to ensure that accessible e-books are available on the market. This is perfectly aligned with the born accessible policy of Hachette Livre and the ABC.
There is a huge need to raise awareness across the industry. The Directive is useful because it gives a strong signal to publishers that they need to take accessibility seriously…
The Directive encourages production of born accessible e-books and sets market surveillance principles so that meta-data on e-books are widely available. It is an extremely positive step for culture, and access to culture and education for visually impaired people.
Do you think the EU Directive will encourage more publishers to sign up to initiatives like the ABC, and can smaller publishers manage the changes is implies?
In addition to my role at Hachette, I am also a technical expert for the Federation of European Publishers, which is a strong advocate for accessible e-books. The Federation believes that the Directive provides a market incentive but also establishes a regulatory obligation. Many stakeholders need both to spring into action.
I think the Directive will shake up the European publishing sector and will push publishers who have not yet embraced accessibility to act, and to actively contribute to advancing the development of tools, processes, and mindsets in this space.
For small publishers, the implementation of the Directive is more delicate, in particular for those producing complex books with intricate and sophisticated page layout, elaborate graphic and aesthetic elements, and multiple images which are difficult to describe. Take, for example, the challenges associated with making accessible a travel book on wilderness areas. Pictures are often not very easy to describe. The same issue arises when making comics or mangas (Japanese graphic novels) accessible.
What exactly is an accessible e-book?
Accessible e-books are not fundamentally different from regular e-books. The file, the format, and the coding of an accessible e-book and a regular e-book are the same. Essentially, the inclusion in the file destined for the sighted public of various technical parameters is what makes that file an accessible e-book for visually impaired readers.
To make e-books accessible, we benefit from a great deal of work at the international level on standards. Web technology standards, in particular, ensure that Internet websites are accessible. For e-books, we use the EPUB format which is also based on Web technologies. At Hachette, we are using EPUB3, the third version of the EPUB standard, to produce born accessible e-books.
Does the EU Directive both serve people who need special formats and create new business opportunities for publishers?
Yes, I think the EU Directive is a win/win, especially if current accessibility standards for publishing e-books are adopted. If, following the Directive’s adoption, the European Commission imposes other accessibility rules or applies formats that differ from those currently in use to produce accessible e-books, both publishers and visually impaired persons will be disadvantaged.
Since 2018, all novels published by Hachette Livre have been and continue to be born accessible, according to the EPUB3 standard and international accessibility rules, in particular those established by the DAISY Consortium.
At present, no decision has been made with respect to the format and technical standards that will have to be used to implement the EU Directive. These questions and the issue of applying a harmonized European standard will arise when the Directive is transposed into the national laws of EU member states.
What impact will the EU Directive have on the work of publishers and distributors?
As it stands, the Directive does not require us to enter new territory. Open file formats and accessibility standards, as well as tutorials and training are all widely available. We simply have to embrace the principle of accessibility and include these standards and file formats into the production process.
From a strategic point of view, an important first step for publishers is to establish a dedicated “internal champion or team” for accessibility.
Will the EU Directive apply to products that are already on the market?
This is a difficult issue, especially if the expectation – as set out in the Directive – is that by June 2025, all commercially available e-books are to be accessible. E-book catalogues include millions of e-books, and as things stand, these works are not accessible. Making existing e-book catalogues accessible will be a very expensive undertaking.
Since Hachette has been publishing all of its novels in accessible formats since 2018, most of the company’s novel catalogue will be accessible by 2025, but books published prior to 2018 will not be accessible and this is a real hurdle.
The obligations set out in the Directive in relation to products and services already on the market will have a strong impact on small and medium-sized publishers in particular.
Hachette’s commitment to accessibility and our decision to publish born accessible e-books makes us a key driver of accessibility within the publishing industry. Production of our born accessible e-books is subcontracted to suppliers who also work for the rest of the publishing sector in France. If those subcontractors know how to produce born accessible e-books for us, they can do the same for other publishers.
So, to some extent, this may ease the pressure on publishers when implementing the Directive. It is clear, however, that some e-books, especially older collections, will not be made accessible by 2025. Without a doubt, EU publishers will need financial assistance if they are required to modify and make accessible all e-books that are already on the market.
Do you think the exceptions established in the Directive (Article 14) are useful and adapted to the publishing industry?
Article 14 seeks to avoid placing a disproportionate burden on the economic operators that are required to make their works accessible. This is a very useful exception, in particular for publishers who produce extraordinary books that are often extremely complex. Ensuring that these works meet accessibility standards is likely to be costly and to involve disproportionate effort compared to their very small market share.
The Directive, however, notes that exceptions will not be made on frivolous grounds. A lack of awareness of the obligations outlined in the Directive will not be accepted. Publishers need to play fair.
Is the timeline for publishers to implement the Directive realistic and feasible?
The June 2025 timeline could be feasible if the Directive is successful in creating immediate awareness about the future accessibility requirements. But a large number of European publishers have not heard about accessibility and have no knowledge of the DAISY Consortium standards or the EPUB3 format.
There is a huge need to raise awareness across the industry. The Directive is useful because it gives a strong signal to publishers that they need to take accessibility seriously and that strict requirements on accessibility will need to be respected.
Whose role is it to raise awareness about accessibility?
Raising awareness about accessibility is a responsibility that needs to be shared by governments and the publishing industry. For my part, as a pioneer in pushing accessible publishing, I feel responsible for delivering the accessibility message to publishers in France and in Europe, alerting them to their obligations and offering technical support where I can. It is really important that publishers understand that embracing accessibility and the requirements of the Directive does not involve any new standards or technical issues; they simply need to get with the program and begin working with subcontractors who have the required knowledge.
Hachette’s commitment to accessibility and our decision to publish born accessible e-books makes us a key driver of accessibility within the publishing industry.
Governments also have a role to play. For example, in France in 2018, the Ministry of Culture launched a strategic plan for born accessible publishing. Moreover, there is a genuine effort to provide all actors in the supply chain with the information they need to comply with the Directive.
In 2020, disseminating information about the implications of the Directive will be a key challenge, not least because the Directive is, in large part, the work of lawyers. Few industry actors with first-hand knowledge of production processes, technical issues and formats participated in the process.
I am also concerned about the need for an effective information campaign to reach out and inform visually impaired people about the Directive. The visually impaired community needs to know about the availability of born accessible e-books and needs to be trained on how to use them. My hope is that the Directive will also help to boost the number of people using accessible e-books.
