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    Accessibility Statement

    Statement date: 21 April 2026 · Last reviewed: 21 April 2026 · Next review: 21 July 2026

    1. Scope

    This statement applies to the Norruva Digital Product Passport platform at app.norruva.com and its public-facing DPP viewer pages. It is published in accordance with Article 13 of the European Accessibility Act (Directive (EU) 2019/882), which became enforceable from 28 June 2025.

    2. Conformance Status

    Partially conformant with WCAG 2.1 Level AA. Some parts of the content do not yet fully conform to all WCAG 2.1 Level AA success criteria. The known non-conformances are listed in Section 4.

    This assessment was prepared through manual keyboard and screen-reader testing conducted in April 2026, together with automated axe-core checks that run in continuous integration at the component and template level. Automated scanning of complete rendered pages is notyet part of our continuous integration: it currently covers the home and sign-in pages only and runs on request rather than on every change. We list this gap in Section 4 rather than describe our automated coverage as continuous.

    3. Accessible Features

    • Keyboard navigation

      All interactive elements — buttons, links, form controls, dialogs, and menus — are reachable and operable by keyboard alone. Focus order follows the visual reading order.

    • Screen reader support

      Semantic HTML5 landmarks, ARIA roles, and descriptive labels are used throughout. The public passport viewer and QR scan flow are tested with NVDA (Windows) and VoiceOver (macOS / iOS).

    • Skip navigation link

      A "Skip to main content" link is the first focusable element on every page, allowing keyboard and screen reader users to bypass repeated navigation.

    • Colour contrast

      Text and interactive element colours meet the WCAG 2.1 Level AA minimum contrast ratio of 4.5:1 on solid backgrounds. The design token system enforces this at build time for core UI components.

    • Focus management

      When dialogs and slide-over panels open, focus moves to the first interactive element inside the overlay and is trapped within it. Focus returns to the trigger element on close.

    • Touch targets

      Interactive elements within the public DPP viewer use a minimum touch target of 44 × 44 px in accordance with WCAG 2.5.5. The design system exposes a `size="touch"` button variant for this purpose.

    4. Known Limitations

    The following barriers have been identified. We are actively working to resolve each one.

    • WCAG 1.4.11 — Non-text Contrast

      Glass morphism overlay surfaces (frosted panels, modal backdrops) do not consistently achieve the 3:1 contrast ratio required for UI components against all backgrounds. Remediation is specified per the 2026-03-04 design system update and is in progress.

    • WCAG 3.1.2 — Language of Parts

      Non-English translation coverage is approximately 40%. The i18n infrastructure supports 6 EU languages but approximately 60% of user-facing strings remain English-only. Translation work is in progress and targeted for completion in 2026-Q3.

    • WCAG 2.1.1 — Keyboard

      Approximately 12 workspace feature components use role="button" on <div> elements without a corresponding keyboard event handler, limiting keyboard activation via Enter and Space for those elements. Identified in the April 2026 audit; backlog items filed.

    • WCAG 1.4.1 — Use of Colour

      Chart visualisations (compliance score graphs, supply chain maps) currently rely on colour as the sole means of conveying data series in some views. Text labels and pattern fills are planned for a future accessibility sprint.

    • WCAG 1.4.5 — Images of Text

      Certain QR code label preview thumbnails embed text as rasterised images without alternative text. A fix to inject meaningful alt attributes is tracked in the backlog.

    • WCAG 3.3.2 — Labels or Instructions

      The DPPSearch consumer entry-point input previously used a placeholder as the only visible label. Explicit label association remediation is in progress.

    • Automated page-level testing coverage

      Our automated axe-core checks run on individual components and templates, not on complete rendered pages. Page-level scanning currently covers the home and sign-in pages only and runs on request rather than on every change, so the public passport viewer and the QR scan flow are verified by manual testing rather than by automated scans. Extending automated page scanning to the public consumer surfaces, and making it a required check, is targeted for 2026-Q3.

    Scan analytics and your privacy

    When you view a Digital Product Passport, we may collect anonymised scan data (device type, region, timestamp) to help brands improve their sustainability disclosures. You can accept or decline this in the consent banner shown on product pages. Your choice is stored in a first-party browser cookie for one year. Declining has no effect on your ability to view the passport.

    5. Feedback and Complaint Mechanism

    We welcome feedback on the accessibility of the Norruva platform. If you encounter a barrier not listed above, or if you need information in an accessible format, please contact our accessibility team:

    accessibility@norruva.com

    We aim to send an initial acknowledgement within 10 business days and provide a remediation plan or workaround within 30 business days.

    This feedback mechanism fulfils the complaint procedure required by Article 12 of the European Accessibility Act (Directive (EU) 2019/882).

    6. Enforcement Procedure

    If you are not satisfied with our response, you may contact the national authority responsible for enforcing the European Accessibility Act in your EU Member State under Article 14 of Directive (EU) 2019/882. The national enforcement body can provide guidance on your rights and the available complaints procedure.

    European Commission — national accessibility enforcement bodies

    7. Review Schedule

    This statement is reviewed quarterly or upon significant platform changes, whichever occurs first.

    • First published: 21 April 2026
    • Next scheduled review: 21 July 2026

    Assessment approach: self-assessment + automated axe-core checks in CI at component and template level (page-level scanning is not automated — see Section 2) + 2026-02-22 internal audit. Third-party audit planned for 2026-Q3.

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