EIFL welcomed the opportunity to submit comments on Brazil’s implementation of the Marrakesh Treaty for persons with print disabilities. The comments focused on Article 4(4) of the treaty, an optional provision that allows a country to confine exceptions to works that are not available on the commercial market under reasonable terms, the so-called ‘commercial availability test’.

EIFL opposes the introduction of a commercial availability test because it would undermine the overarching objective of the Marrakesh Treaty to expand the availability of accessible format works to persons with print disabilities. It would especially hamper cross-border exchange of accessible format works, widely recognized as key to ending the global ‘book famine’ for persons with print disabillities, and fundamental to the treaty’s success.