Accessibility Statement

1. Scope and provider

This statement applies to the www.subtel.de online shop in its English version, including product search, customer account, shopping cart, checkout, payment, shipping information, returns handling and customer service. Our shops in other countries are each covered by the statement published there.

The provider of the service is:

subtel GmbH
Mainzer Str. 3
10247 Berlin
Germany

Commercial register number: HRB 135199 B
Registered at: Amtsgericht Berlin Charlottenburg
VAT identification number: DE240712418
Managing Directors: Christopher Stein, Paul Karma

Language of this statement: English. A German version is available at www.subtel.de/barrierefreiheit.

2. Description of the service

subtel.de is an online shop for replacement batteries, standard batteries, chargers, power supplies, cables, adapters and accessories for devices such as cameras, smartphones, laptops, power tools and household appliances.

Through the shop you can search and filter products, check whether a part fits your device, add items to your cart, order as a guest or with a customer account, pay, track your shipment, return goods and contact our customer service team.

3. How the service works

An order runs through the following steps:

• You find a product using the search, the category navigation, or the device and compatibility finder.
• The product page shows the description, price, availability, delivery time and the list of compatible devices.
• You add the item to your cart and start checkout — either as a guest or with a customer account.
• You enter your delivery and billing address and choose a shipping and payment method.
• Payment is handled through embedded components provided by our payment service providers.
• You receive an order confirmation by email, followed by shipping and tracking information.
• Returns and withdrawals can be started using the withdrawal form or by email.

Parts of the service are presented in embedded third-party components — in particular the payment forms of our payment service providers and your cookie preference selection. These components are part of our service; we treat their accessibility as our responsibility and assess them separately.

4. Applicable requirements

The governing rules are the German Accessibility Strengthening Act (Barrierefreiheitsstärkungsgesetz, BFSG) and its implementing regulation (BFSGV), with the accessibility requirements they set out for services in electronic commerce.

As a technical reference we use the EN 301 549 standard together with the Web Content Accessibility Guidelines (WCAG) 2.1 at conformance level AA. We align our implementation with the principles perceivable, operable, understandable and robust.

Note on the legal position: at the time of this statement, no harmonised standard has been published in the Official Journal of the European Union under the BFSG. No presumption of conformity therefore arises from applying a standard. The information under section 5 describes the state we have actually established, not a presumption of conformity.

5. Current state of accessibility

This website is currently partially accessible. A full external audit against EN 301 549 has not yet been completed. We deliberately make no conformance claim here that we cannot support with an audit.

Last internal review: 31 August 2026. The review covered manual inspection of the source code and the delivered pages, automated browser-based testing, and operation without a mouse. A full assessment against EN 301 549, including testing with screen readers and with users with disabilities, is planned and still outstanding. We will update this statement once it is complete.

We are currently aware of the following barriers:

• Not all form fields have a permanently and programmatically associated label. This affects checkout, registration, login, search, newsletter and the contact form, among others.
• In checkout and payment, error messages are not yet consistently linked to the field concerned and do not always name a concrete correction.
• The visibility of the keyboard focus is in places too low in contrast.
• Status messages — for example when an item is added to the cart — are not reliably announced to screen readers.
• At a window width of 320 pixels and with increased text spacing, some pages show overlapping content or horizontal scrolling.
• The heading hierarchy is not consistent across all pages.
• Interactive controls such as the quantity selector, variant selection, accordions and tabs are not consistently exposed with the correct role.
• Form fields for name, address, email and telephone are in places missing autocomplete support.
• The accessibility of the embedded payment forms and of the cookie preference selection has not yet been conclusively assessed.

We are working through these points in order of priority, starting with the ordering and payment process.

6. Reporting barriers and contact

Have you found a barrier on this website, or do you need information in a form that is accessible to you? Please get in touch — your feedback helps us directly.

Email: info@subtel.de
Telephone: 030 802089950
Available: Monday to Friday, 10:00 to 21:00

We normally confirm receipt of your report within five working days and tell you how and by when we will deal with it.

On request we will provide this statement, and the information you need in order to place an order, in another form — for example in plain language, in large print, as an accessible document, or verbally over the telephone.

7. Accessibility aids on this website

At the bottom left of every page you will find a menu of accessibility aids. It lets you switch display and navigation aids on and off, such as pausing animations, hiding images, showing a reading guide, enlarging the mouse pointer, highlighting the keyboard focus, or activating a reading mode.

In addition, a rule-based script makes small corrections to the page structure as the page loads — for example it supplies labels for individual controls and makes scrollable areas reachable by keyboard.

No artificial intelligence and no third-party service is involved. Your settings are stored only in your browser and are not transmitted to us.

These aids improve usability in specific places. They are not a substitute for accessible design and do not by themselves establish conformity with the requirements named under section 4.

8. Market surveillance and conciliation

If you are not satisfied with our response, or receive no response, you can contact the competent market surveillance authority:

Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen (MLBF AöR)
Carl-Miller-Straße 6
39112 Magdeburg
Germany
Telephone: +49 391 289 230 23
Email: kontakt@mlbf-barrierefrei.de
Website: www.mlbf-barrierefrei.de

Independently of this, as a consumer you may apply for conciliation proceedings:

Schlichtungsstelle nach dem Behindertengleichstellungsgesetz (Schlichtungsstelle BGG)
at the Federal Government Commissioner for Matters relating to Persons with Disabilities
Mauerstraße 53
10117 Berlin
Germany
Telephone: +49 30 18 527-2805
Email: info@schlichtungsstelle-bgg.de
Website: www.schlichtungsstelle-bgg.de

The conciliation procedure is free of charge for you. You are not required to contact us first — but we would ask you to, so that we can fix the problem ourselves as quickly as possible.

9. Status of this statement

Created on: 27 August 2026
Last updated on: 31 August 2026
Responsible for the content: subtel GmbH, Mainzer Str. 3, 10247 Berlin

This statement is reviewed and updated when the service changes materially, after the external audit is complete, and otherwise at regular intervals.