With the European Accessibility Act (EAA) enforcement date of June 28, 2025, every cannabis or CBD brand selling to EU consumers online faces a compliance deadline affecting e-commerce websites, mobile apps, and digital services. Understanding—and meeting—these obligations is now an essential part of cannabis ecommerce compliance, with implications for market access and legal risk across all EU member states.
What Is the European Accessibility Act?
The European Accessibility Act (EAA) is an EU-wide regulation mandating that certain digital and physical products and services—including e-commerce websites and marketplaces—must be accessible to people with disabilities. The Act's goal is to create a harmonized accessibility baseline across all member states, empowering disabled consumers as full market participants and reducing market fragmentation.
Why does this matter for cannabis and CBD? Cannabis and CBD ecommerce often feature complex product filtering, downloadable content (like lab results), and age-restricted flows—all of which now fall under the EAA’s accessibility umbrella.
For background, see:
Who Must Comply—and When?
The EAA applies to private-sector organizations—including non-EU businesses—that operate websites, apps, or marketplaces offering goods or services to EU consumers. That means any cannabis or CBD website, brand, or marketplace interacting with EU customers is responsible for compliance, not just EU-based entities (see National Law Review).
Key compliance deadlines:
- June 28, 2025: All new websites, apps, and digital marketplaces must comply from day one.
- Legacy services: Existing websites/apps have until June 28, 2025, to meet requirements. Limited transitional relief may apply, but most major updates trigger immediate compliance.
- Member state variation: Local laws may impose additional nuances—always verify with the relevant EU country if your site targets specific markets.
Core EAA Accessibility Requirements for Cannabis/CBD Ecommerce
The Act aligns most digital requirements with WCAG 2.1 AA (or 2.2) guidelines and EN 301 549 standards. For cannabis and CBD ecommerce, this means:
1. Accessible Checkout and Navigation
- Menus, filters, cart, product descriptions, and search must all be navigable by keyboard and screen reader.
- Multi-step flows (such as restricted-age gates or checkout) must have clear focus indicators and avoid traps.
- "Oops" or error states—such as failing age verification—should offer accessible, understandable, and recoverable messaging.
2. Alternative Content for Media & PDFs
- Alt text is required for all non-text content, including product images, banners, icons, and infographics.
- PDFs and downloadable Certificates of Analysis (COAs) must be tagged, logical, and machine-readable—not just scans.
- Video or audio content (e.g., product explanations, education) must include subtitles or transcripts.
- All input fields (address, payment, product preferences) must be properly labeled and compatible with assistive technologies.
- Errors—such as invalid coupon codes, failed logins, or restricted-age rejections—must be communicated clearly and accessibly.
4. Age Gates and Restricted Interactions
- Cannabis/CBD sites routinely use age verification gates. These must support accessible navigation, screen readers, appropriate contrast, and error handling.
- Avoid CAPTCHA challenges that block assistive tech. If verifying age or user identity, use accessible alternatives like TTS (text-to-speech) or email/SMS verification.
5. Accessible Downloadables and Data Visualization
- Lab reports, product specifications, batch COAs, or regulatory notices must be provided in accessible formats—well-structured PDFs or HTML alternatives.
- Graphs/charts for potency, dosage, or lab results should be accompanied by text summaries or data tables.
6. Accessibility Statements and Legal Disclosure
- Publish a clear, up-to-date accessibility statement on your site, describing your conformance status and providing a channel for customer accessibility complaints (example guide).
- Update vendor service level agreements (SLAs) to require accessibility for any third-party plug-ins (e.g., loyalty, live chat, payments, or age verification providers).
Steps for Cannabis and CBD Ecommerce Operators: Action Checklist
The EAA is not simply a “tick-the-box” law, and enforcement will become increasingly consistent across the EU after June 2025. Here’s what cannabis ecommerce and CBD brands must do:
Conduct a WCAG/EN 301 549 Audit
- Use automated and human-testing to review your entire e-commerce environment—including mobile/responsive versions—against WCAG 2.1 AA or 2.2.
- Include all customer journeys: product search, age verification, educational pages, and checkout.
- Fix inaccessible navigation: menus, product filters, category trees, sorting, and search.
- Ensure pop-ups, overlays, dynamic content (e.g., product quick-views, loyalty sign-ups) are fully accessible.
- Make sure age gates and restricted-access pages are not barriers for disabled users.
- Remediate any PDFs, downloads, or lab results to meet EN 301 549 requirements.
Update Accessibility Statements and Complaints Handling
- Post a visible, plain-language accessibility statement explaining commitment, current compliance status, and offering a contact/support channel for accessibility issues.
- Implement a protocol for responding to consumer accessibility complaints, as required by law.
Review Third-Party Contracts and Plugins
- Update all developer, design, and SaaS contracts to mandate accessibility conformance for any digital services.
- Monitor plugins (including payment, chat, or loyalty providers) for compliance with accessibility standards.
Train Staff and Update Policies
- Train content, design, customer support, and web management teams on accessibility best practices.
- Incorporate accessibility reviews into ongoing site updates, A/B tests, and content pushes.
Enforcement, Risks, and Penalties
Non-compliance with the EAA exposes cannabis and CBD brands to:
- Potential fines, market bans, or civil action under national member state laws
- Complaint-driven audits, monitoring, or public enforcement campaigns by consumer advocacy groups
- Reputational risk from exclusion of disabled users
More on EAA enforcement and compliance
- Start today: Pre-June 28, 2025, is the last window for digital assessment, remediation, and training
- The EAA goes beyond basic UX—it is a robust, legal accessibility mandate: all digital customer journeys, from product search to purchase and COA download, must be accessible
- New websites/mobile apps must comply immediately; legacy stores have until the deadline but cannot delay major template changes
- Proactive compliance is not only a regulatory obligation but can boost brand trust and market inclusion
Need Help?
Ensuring your cannabis/CBD ecommerce channels are accessible for all is a market necessity in 2025. For in-depth regulatory intelligence, compliance tools, and expert support tailored to the international cannabis industry, consult CannabisRegulations.ai today.
