Disability is seen as a result of an interaction between a person and that person's contextual factors. Viewing disability in the context of the built environment, a better design of this environment helps to reduce the disability faced by an individual. In spite of significant research in Universal Design (UD), the existing methods provide insufficient guidance for designers: designers demand more specific examples of, and methods for, good universal design. Within the overarching goal of improving universal product design, the specific goal of this research is to determine if the ADA guidelines for architectural design can be adapted to product design. A methodology that foresees the accessibility issues while designing a product would be constructive. The new technique should be built on the pre-existing principles and guidelines. A user activity and product function framework is proposed for this translation using actionfunction diagrams. Specific goals include determining if the function-based approach is able to anticipate a functional change that improves product accessibility. Further, generate user activity and product function association rules that can be applied to the universal design of products. Proposed research activities are to identify thirty existing universal products and compare with its typical version to identify the function that introduces an accessibility feature. Next, categorize the observed changes in a product function systematically and extract trends from accessible architectural systems to generate rules for universal design of consumer products. For validation, the task is to select around fifteen consumer product pairs for validation of the generated rules to determine if the ADA guidelines can be adapted for universal product design using the proposed framework. The results of this research show promise in using the International Classification of Functioning, Disability and Health (ICF) lexicon to model user limitation. The actionfunction diagram provides a structured way to approach a problem in the early stage of design. The rules generated in this research translate to products having similar user-product interface.