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Why Deposit Return Scheme machines must now meet accessibility standards

A Deposit Return Scheme machine in use. The new law aims to ensure that people with disabilities can access everyday digital services independently, including bottle and can return machines.
A Deposit Return Scheme machine in use. The new law aims to ensure that people with disabilities can access everyday digital services independently, including bottle and can return machines.

Analysis: A new European law aims to ensure people with disabilities can use everyday digital services independently, including recycling cans and bottles

By Dympna O'Sullivan, Damian Gordon, TU Dublin and Siobhán Long, Enable Ireland

The machines used in Ireland’s Deposit Return Scheme (DRS), the ones that accept your empty bottles and cans and give you a receipt for money back, will need to meet clear accessibility requirements under a major new European law.

It's all part of the European Accessibility Act (EAA) which is now in force across the EU. The new law aims to ensure that people with disabilities can access everyday digital services independently, whether that's using a website, buying a bus ticket, using a self-checkout at the supermarket or recycling a drinks container.

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From RTÉ News, new EU rules on digital accessibility come into force

Many of us don’t think twice about using these machines. But for people who are blind, use a wheelchair or live with a cognitive impairment, something as basic as returning a bottle can be difficult or even impossible without help.

What Is the European Accessibility Act?

The EAA is designed to change that and sets common rules for accessibility across the EU. From June 2025, any new product or service that falls under the law, such as websites, apps, ATMs and self-service kiosks, must be designed to be accessible from the start. That includes things like clear screen text, good colour contrast, buttons you can feel or hear and working with screen readers or other assistive technologies. Existing products and services must follow the rules by 2027.

The EEA is designed to create a fairer, more inclusive society while also benefiting businesses by expanding their potential customer base to people who couldn't use their products and services previously. It also supports an ageing European population who will ultimately face accessibility challenges, so future-proofing these products and services now creates long-term value for users and reduces costly redesigns later.

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From RTÉ Radio 1's Drivetime, solictor Dermot McGirr on the new EU regulations on digital accessibility

So are businesses ready?

There's the problem: most Irish businesses are not prepared, Surveys show that over 60% of small and medium enterprises (SMEs) haven’t carried out an accessibility audit. Last week, Digital Business Ireland expressed concern that not enough has been done to support and raise awareness for Irish businesses to comply with EEA. Many are simply unaware of the new law, while others assume it applies only to large tech firms or public institutions.

Cost is also cited as a factor. Some businesses worry that making services accessible will be too expensive or technically complex. But our research shows that small changes, like improving colour contrast or adding audio prompts, can significantly enhance accessibility and often benefit all users, not just those with disabilities.

Everyday barriers in plain sight

For the one in four people in Ireland who live with a disability or long-term health condition, the new rules could open up everyday services that have been out of reach. Take the bottle return machines. While they help the environment, many users have found them difficult to use. If you use a wheelchair or are blind, the control screens on these machines might be too high or the instructions might rely too much on visual information.

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From RTÉ Brainstorm, 5 things Ireland's deposit return scheme can learn from other countries

The burden of carrying bags of bottles and cans is physically demanding for many disabled people, which means some people simply can't reclaim their 15c or 25c deposit. That’s not just frustrating, it’s unfair. People with disabilities already face higher living costs and being excluded from schemes like this adds another barrier.

What this means for consumers

The EAA gives consumers more power. If you come across a service or product that isn’t accessible, whether that’s a bank app you can’t navigate with a screen reader, a vending machine with no audio or a touchscreen with poor contrast, you have the right to complain.

Start by contacting the service provider directly to explain the accessibility issue. If their response isn’t satisfactory, you can escalate the complaint to the relevant authority. For many products and services covered by the EEA, this will be the Competition and Consumer Protection Commission (CCPC) – you can reach them at ask@ccpc.ie. If your issue relates to something more specific, like telecoms or broadcasting, the CCPC can direct you to the appropriate body, such as ComReg for communications services or Coimisiún na Meán for broadcasting.

For accessibility to improve across the board, people need to speak up

If organisations are found to be in breach of this Act, in most cases, they face fines of up to €5,000 and/or up to 6 months in prison. And in very serious cases, fines of up to €60,000 and/or up to 18 months' imprisonment.

What needs to change?

For accessibility to improve across the board, people need to speak up. Whether you’re a consumer, a carer or an advocate, highlighting problems is the first step. If you can’t use a public machine, app or website because of a design issue, make a complaint to the business and to the relevant regulator. The more feedback they receive, the more likely they are to act.

Equally, when you come across services that are accessible - a well-designed ticket machine, a clear and easy-to-navigate website or a shop with an audio-enabled checkout - it’s worth acknowledging that too. Positive examples help raise the bar.

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Dr Dympna O’Sullivan leads the Digital Futures Research Hub at TU Dublin. She is the Principal Investigator of two Research Ireland funded projects, Smart Self Care for Dementia and Co-Design for Dementia. Damian Gordon is a lecturer in Computer Science at TU Dublin. Siobhán Long manages Enable Ireland’s National Assistive Technology Training Service.


The views expressed here are those of the author and do not represent or reflect the views of RTÉ