In 2020 the European Commission examined 150 environmental claims across EU member states - 53.3% (European Commission 2020) were vague, misleading or unsubstantiated, and 42% (European Commission/bsaktuell) breached EU consumer law. The response: Directive (EU) 2024/825 (Empowering Consumers / EmpCo) amends the UCP Directive and Consumer Rights Directive - and from 27 September 2026 new information duties apply to distance selling, affecting an estimated 80,000+ (Listflix 2025) online shops in Germany alone. Repairability, software updates, green delivery options and the harmonised warranty and durability label must be transparently displayed. This article shows what shop operators need to implement technically, legally and editorially by September 2026.
Deadline 27 September 2026: What changes in the shop?
Directive (EU) 2024/825 was adopted on 28 February 2024 and entered into force on 26 March 2024 (EUR-Lex). Member states must transpose it by 27 March 2026, with application beginning without a transition period on 27 September 2026 (Trusted Shops). In Germany transposition takes the form of the 3rd UWG Amendment Act, a new Section 312d BGB and adjustments to the EGBGB (shopbetreiber-blog). The BMJV ministerial draft of 7 July 2025 was commented on in 38 submissions (Taylor Wessing/BDEW). The main changes affect product detail pages (PDP), checkout and legal texts - plus a ban on misleading environmental claims across the entire shop. Note: with application on 27 September 2026 no additional transition applies - all duties take effect immediately on that day. Shops that have not adapted their content at that point are instantly in a state of potentially misleading advertising that can formally be subject to warning letters. Experience with earlier EU regulations (such as the Accessibility Act, the DSA or the Omnibus Directive) shows that the final two weeks before the cut-off typically create resource bottlenecks at agencies and law firms - planning certainty is only achieved by starting implementation several months earlier.
| Area | Until 26 Sep 2026 | From 27 Sep 2026 |
|---|---|---|
| Repairability | no mandatory disclosure | score, parts, guides (Section 312d BGB) |
| Software updates | voluntary | minimum period required on PDP |
| Green delivery option | optional | pre-contract disclosure |
| Warranty label | inconsistent | harmonised EU template (2025/1960) |
| Durability label | unregulated | mandatory for warranty >2 years, with QR code |
| Climate-neutral claim | widespread | banned when based on CO2 offsetting only |
Section 312d BGB: repairability info on the product page
The new Section 312d BGB requires distance sellers to provide four new repairability disclosures before contract conclusion (IT-Recht Kanzlei). These must appear clearly, comprehensibly and product-specifically on the product detail page - a link buried in the T&Cs is not enough. Violations expose shops to warning letters from competitors, the Wettbewerbszentrale or the Federation of German Consumer Organisations (vzbv). The duty applies to all goods - but is particularly relevant for durable goods, household appliances and electronics, where it overlaps with the Right to Repair framework already active in 2026. Shops should coordinate with their manufacturers early to clarify which data points can be delivered in what structure - in many cases this information exists technically but is not yet systematically passed to the e-commerce channel. Clean data integration is the key prerequisite to fulfil the duties from September 2026 automatically per product instead of through manual editorial work.
Repairability score
Where a harmonised repairability score exists for the product category, it must be shown on the PDP (IT-Recht Kanzlei). The French repair index serves as the model.
Spare parts availability
Information on spare parts availability, minimum provision period and procurement process must be disclosed product-specifically - also relevant for the Digital Product Passport.
Repair instructions
If repair instructions exist, their availability and access path must be indicated (IT-Recht Kanzlei). PDF downloads or QR codes on the PDP are acceptable.
Repair restrictions
Any repair restrictions must be disclosed transparently - for example, binding to authorised workshops, serial-number locks or software restrictions.
Software updates: declare the minimum period
For goods with digital elements (smart TVs, appliances with apps, wearables, smartphones) a new duty applies: shops must display the minimum period during which the manufacturer provides software updates on the product page (IT-Recht Kanzlei/IHK Stuttgart). The information must be clearly visible before contract conclusion - not hidden in the data sheet. It also covers accessories with firmware, connected kitchen appliances and any product that would lose function without updates. In practice this creates a data flow from the manufacturer through PIM and import into the shop that should be designed to be as machine-readable as possible: a structured field containing a date ('updates until 12/2031') is preferable to free text because it can be reused in filters, comparison portals and structured data (Schema.org). Shops serving international markets must also consider language versions and regional legal frameworks - the minimum period may vary by country.
Software updates must not be labelled 'necessary' if they merely extend functionality (grubengold.io). Only security and function-preserving updates qualify as 'necessary'. Presenting feature updates as mandatory to harvest data or attention breaches the UCP Directive - with enforcement risk from the Wettbewerbszentrale or the vzbv.
Green delivery options before contract conclusion
A new duty is the disclosure of environmentally friendly delivery options before contract conclusion where offered (shopbetreiber-blog). This creates checkout transparency and empowers consumers to make climate-friendly decisions. The disclosure must be clear, comparable and truthful - vague labels like 'green shipping' without substance fall under the new greenwashing bans. Anyone offering a green delivery option must first audit their own logistics chain: which carriers hold which certifications, which delivery processes actually produce fewer emissions, which evidence can be demonstrated in a data-backed way? Simply reusing a carrier logo is generally not enough - shops need their own, traceable rationale for marketing an option as climate-friendly. The right approach combines a factual description, verifiable figures and a link to the carrier's methodology.
- Delivery-method labelling in the checkout: standard vs climate-friendly (e.g. GoGreen, CO2-neutral option) with factual description of the sustainability contribution
- CO2 equivalent per shipment where supportable by carrier data - no estimates without foundation
- Consolidated shipping option as a sustainable alternative to individual dispatch, especially for subscription commerce and multi-item orders
- Pick-up points / parcel lockers communicated clearly as lower-energy, lower-emission delivery routes
- Transparent sourcing of the CO2 calculation method (e.g. DHL GoGreen certification, independent verifier) - pure marketing claims are prohibited
Harmonised warranty label (EU 2025/1960)
The EU Implementing Regulation 2025/1960 of 25 September 2025 sets out the graphical templates for the harmonised warranty label (Hogan Lovells). Shops must use the EU-standard symbol visualising the two-year statutory warranty - regardless of whether additional manufacturer guarantees exist. For Shopware operators, integration as an automatic product badge on every PDP is the cleanest path. Detailed guidance is available in our article on the EU warranty and guarantee label. The label does not replace the textual notice about statutory remedies - it supplements them visually, so it must be embedded alongside existing mandatory information. For international shops, the label is uniform across the EU while the accompanying text must be in the respective local language with a national reference (in Germany: BGB). A clean template-level implementation ensures the label does not appear redundantly next to other seals and that the legal text hierarchy is preserved.
The Implementing Regulation binds colour, proportions and text elements of the label. Custom artwork is not permitted - the EU template must be adopted identically. Shops can obtain the label as an SVG directly from the European Commission. It must not be confused with existing trust seals or goodwill badges.
Durability guarantee label with QR code
Where a manufacturer offers a commercial guarantee exceeding two years and the costs are not passed on to the buyer, the shop must display a dedicated durability guarantee label - including a QR code linking to detailed conditions (Trusted Shops). Mandatory disclosures cover duration, geographic scope, conditions and manufacturer contact. Technically this can be implemented via Schema.org markup so the label also surfaces in Google rich results. In practice this means: the shop needs a detail page or PDF with the full guarantee conditions per product, a QR code generator that creates a unique code at each product import, and version control for the conditions - if the manufacturer changes the guarantee, the label on every affected PDP must update automatically. A central guarantee registry in Shopware or the PIM helps to scale these duties and keep audit trails available for later checks.
<!-- Durability guarantee with Schema.org markup -->
<div itemscope itemtype="https://schema.org/WarrantyPromise">
<meta itemprop="durationOfWarranty" content="P5Y" />
<img src="/images/eu-durability-label.svg"
alt="EU durability guarantee 5 years" />
<div>
<span itemprop="warrantyScope">Durability guarantee</span>:
<span>5 years from purchase, valid in EU/EEA</span>
</div>
<!-- QR code to guarantee conditions -->
<a href="/warranty/durability/{{ product.id }}" rel="nofollow">
<img src="/qr/warranty-{{ product.id }}.svg"
alt="Guarantee conditions via QR code" />
</a>
<meta itemprop="warrantyPromise"
content="Manufacturer durability guarantee exceeding 5 years" />
</div>Greenwashing bans: what's no longer allowed
The EmpCo Directive adds specific greenwashing offences to the UCP Directive. In Germany these are enforced under the UWG - with direct risk of warning letters. The rules operate in parallel with the Green Claims Directive and the general requirements for sustainable e-commerce communication.
- Climate-neutrality claims based purely on CO2 offsetting are prohibited (Freshfields/UWG) - only actual emission reductions may be labelled that way
- Non-certified sustainability seals are inadmissible - only official or independently verified certificates remain permitted (European Commission DE)
- Blanket environmental claims such as 'eco-friendly', 'green', 'sustainable' without specification and proof count as misleading
- Forward-looking environmental claims (e.g. 'climate-neutral by 2030') are permitted only with a clear implementation plan and independent verifier (BDEW)
- Obsolescence by design - artificial durability limits or update blocks without factual basis - is explicitly classified as an unfair commercial practice
Under the amended UWG, advertising products as 'climate-neutral' solely by purchasing CO2 certificates typically constitutes a misleading commercial practice (Freshfields). This also applies retroactively to active campaigns, landing pages and product descriptions. Immediate action: audit existing shop texts for claims like 'climate-neutral', 'CO2-free' or 'green' and refine them.
The French repair index as a model
Since 1 January 2021 France has operated a mandatory repair index for selected product categories (washing machines, smartphones, laptops). Manufacturers calculate the index based on five criteria on a 0-10 scale and display the result as a colour-coded pictogram on PDP and packaging (Germanwatch/Runder Tisch Reparatur). The European Commission is closely aligning the harmonised scores with the French model - shop operators should familiarise themselves with the five criteria now to prepare downstream PIM system integrations. After three years of application, France also identified weaknesses: many manufacturers reported overly optimistic values, self-calculation by manufacturers came under scrutiny, and enforcement was tightened. These lessons feed into the EU rules - harmonised scores will likely be introduced gradually per product category with stricter review obligations. German shops can already orient themselves on the index values delivered by French manufacturers to prepare their PIM structures.
| Criterion | Description | Weighting |
|---|---|---|
| Documentation | repair instructions, technical documents | 20% |
| Disassemblability | disassembly without special tools | 20% |
| Spare parts availability | lead time, duration of supply | 20% |
| Spare part price | ratio of spare cost to new price | 20% |
| Product-specific criteria | additional per product group | 20% |
Fines and enforcement risk
UWG violations in Germany are classically enforced by competitors, the Wettbewerbszentrale and the vzbv (Händlerbund/rdp-law). On top of that the Omnibus Directive provides for fines of up to 4% of annual turnover in the affected EU member states or at least EUR 2 million for cross-border infringements (Freshfields). For Germany's top 1,000 online shops, with combined turnover of EUR 80.4 billion (EHI/Handelsdaten), this represents substantial exposure - especially for operators expanding across the EU and for automatically generated product content from GEO-optimised content strategies. German enforcement practice is fast: typically within a few weeks of new UWG provisions entering into force, mass warning letters start to circulate, often from specialised law firms using standardised templates. For repair score, update period and green delivery, automated crawlers will readily identify indicators of non-compliance - e.g. missing keywords or absent Schema.org markup. Shops with a clean technical foundation are typically better protected than those relying on editorial backfilling.
Cross-border UCP infringements can attract fines of up to 4% of EU annual turnover or at least EUR 2 million (Freshfields). Add to that civil warning letters by competitors under UWG with cease-and-desist obligations and contractual penalties. An early PDP-level compliance audit substantially reduces this exposure.
Technical implementation in Shopware
The technical implementation in Shopware 6 CE combines custom fields, Twig templates and automatic PDP extensions. Our Shopware agency integrates the new mandatory fields directly into product imports and ensures they flow from the PIM system or from a Microsoft Dynamics 365 Business Central integration. In the Shopware admin we set up dedicated custom field sets that can be enabled per product type - an electronics category receives the 'digital-elements' set with update fields, a kitchen appliance additionally the 'repairability' set with score and spare part data. This keeps the data structure clean and extensible as further product groups fall within the scope. Our e-commerce expertise ensures the new mandatory fields are implemented alongside the existing accessibility-compliant presentation - because accessibility and information duties must be fulfilled in parallel. For individual requirements such as complex manufacturer APIs or multilingual label variants, our programming department develops tailored modules.
- Custom fields for repair score, spare-parts period, repair-guide URL and minimum update period per product
- Twig blocks in the product detail page - modular extensions without core changes, compatible with edge caching and global performance
- Automatic validation in the product import to flag missing mandatory fields before publication
- Checkout extension for green delivery options with transparent display and tooltip explanation
- Schema.org markup for warranty and durability guarantee so labels appear in Google rich results and semantic product search
- Legal text updates in T&Cs, withdrawal policy and product information - coordinated with the withdrawal button from June 2026
- Reporting & audit trail to document all changes - important for credit notes under the ZUGFeRD standard and for any later regulatory inquiry
Implementation roadmap to September 2026
- May 2026 - Inventory: audit all PDPs for existing repair, update and sustainability statements. Identify greenwashing claims, document existing texts.
- June 2026 - Data structure: create custom fields in Shopware, define PIM mapping, establish supplier processes for repair score and update period. Synchronise with ZUGFeRD master data.
- July 2026 - Template work: extend Twig blocks for the PDP, integrate the EU warranty label, set up the durability template with QR code. Extend checkout flow for the green delivery option.
- August 2026 - Legal texts: revise T&Cs, withdrawal policy and product information duties. Confirm legal review and sign-off.
- September 2026 - Test cycle: end-to-end testing on staging, Schema.org validation, rich-result check via Google Search Console, Lighthouse audit of the PDPs.
- 27 September 2026 - Go-live: production rollout with monitoring. Immediately after release, commission spot checks by an external law firm or UWG-experienced consulting partner.
This article is based on data and publications from: European Commission, EUR-Lex, German BMJV, IT-Recht Kanzlei, Trusted Shops, Händlerbund, Taylor Wessing, Freshfields Bruckhaus Deringer, Hogan Lovells, BDEW, vzbv, Germanwatch, EHI Retail Institute, Handelsdaten.com, Listflix, Runder Tisch Reparatur, IHK Stuttgart, shopbetreiber-blog, grubengold.io. The dates and mandatory disclosures reflect the status as of April 2026 and may be further specified through final transposition acts and implementing regulations.
Act early instead of waiting for enforcement
The EmpCo Directive 2024/825 is not an isolated compliance topic but part of a broader EU regulatory package that also includes PPWR, Digital Product Passport and Right to Repair. Shop operators who integrate repair score, update period, green delivery and durability label early reduce their enforcement exposure and position themselves as trustworthy providers. XICTRON supports the implementation in Shopware shops technically and editorially - from auditing existing PDPs through to the production go-live on 27 September 2026. Those who treat the duties not as a compliance burden but as a marketing opportunity can actively communicate the new transparency: customers increasingly search for durable, repairable products, and a visible repair score or extended durability guarantee can become genuine selling points. The timeline is tight - five months to application are typically a narrow window in complex shop environments. Starting now gives the best chance of a clean go-live and reduces enforcement risk as well as stress in September.
Member states must generally transpose the EmpCo Directive into national law by 27 March 2026. Actual application of the new duties begins without a transition period on 27 September 2026 (Trusted Shops). Online shops should typically plan implementation several months in advance to allow sufficient buffer for testing.
The duty to display a repair score generally applies only where a harmonised EU score exists for the product category (IT-Recht Kanzlei). Irrespective of that, information on spare parts, repair instructions and repair restrictions must be disclosed product-specifically under Section 312d BGB if available from the manufacturer.
Affected are goods with digital elements whose function would be impaired without regular updates - for example, smartphones, smart TVs, connected household appliances, wearables and IoT products (IHK Stuttgart). Experience suggests the minimum period should be clearly visible on the product detail page before contract conclusion.
Advertising a product as 'climate-neutral' solely on the basis of purchased CO2 certificates typically qualifies as a misleading commercial practice after transposition (Freshfields). As a rule, such claims are only permissible when based on actual emission reductions and verified by an independent party.
The graphical templates are binding under EU Implementing Regulation 2025/1960 (Hogan Lovells). Typically they can be obtained as SVG directly from the European Commission and integrated into the product detail page via Schema.org markup (WarrantyPromise) - further detail in our article on the EU warranty label.
For cross-border UCP infringements, fines of typically up to 4% of annual turnover in the affected member states or at least EUR 2 million can be imposed (Freshfields). In addition, civil warning letters by competitors, the Wettbewerbszentrale or the vzbv usually apply, with cease-and-desist claims and contractual penalties.