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The EN 301 549 has modifed part of Note 1 to remove "or that has no sensor to detect or change the orientation" because it inadvertently provides an "out" for content that is viewed on a displays that can change orientation manually (with user settings).
Additionally, the EN 301 549 only applies this note to non-web software - not to clause 10.1.3.4 for non-web documents.
Existing Note 1:
NOTE 1 (ADDED)
Content that is only used on hardware with a fixed display orientation or that has no sensor to detect or change the orientation is covered under the essential exception and does not need to provide support for orientation changes.
Proposed updated Note 1, and only have this be a note for non-web software:
NOTE 1 (ADDED) (FOR NON-WEB SOFTWARE)
Content that is only used on hardware with a fixed display orientation where a user cannot change the orientation is covered under the essential exception and does not need to provide support for orientation changes.