EmpCo Info Duties: Date of Application Sep 27, 2026

A European Commission study assessed 150 environmental claims – in 53.3% (European Commission) of cases the information on the environmental characteristics was vague, misleading or unfounded. In a separate website sweep, the Commission and consumer authorities examined 344 claims more closely and had reason to believe that in 42% (European Commission) of cases the claims could be false or misleading. Directive (EU) 2024/825 (Empowering Consumers / EmpCo), which amends the UCP Directive and the Consumer Rights Directive, responds to this. Germany transposed it in February 2026: the information duties in the EGBGB with the Act of 3 February 2026 (BGBl. 2026 I No. 28), the additional bans on environmental claims in the UWG with the Act of 12 February 2026 (BGBl. 2026 I No. 43). The date of application is 27 September 2026 (Directive 2024/825). For online shops, this concerns information on repairability, the minimum period of software updates, environmentally friendly delivery options and the legal guarantee notice and the GARAN label. Many of these items depend on a condition – for instance that an EU score exists or that the producer supplies the information. This article shows which item is needed when and how a shop delivers it cleanly from its product data.

Date of application September 27, 2026: what changes in the shop?

Directive (EU) 2024/825 amends the UCP Directive 2005/29/EC and the Consumer Rights Directive 2011/83/EU. Member states had to adopt and publish their provisions by 27 March 2026; the date of application is 27 September 2026 (Directive 2024/825). In Germany, the new information duties are laid down in Art. 246 and 246a EGBGB, amended by the Act of 3 February 2026 (BGBl. 2026 I No. 28). The additional bans on environmental claims are in the UWG and its annex, amended by the Act of 12 February 2026 (BGBl. 2026 I No. 43). For online shops, the relevant provision is Art. 246a § 1 (1) EGBGB with the information before concluding a distance contract; Art. 246 covers other consumer contracts, for instance in a brick-and-mortar store. Many of the new items are subject to a proviso such as "if available" or "if the producer makes this information available to the trader" – the shop shows them when the basis exists. The table summarizes the changes.

Repairability: score or producer information on the product page

The repairability information works in two stages. If the good has a repairability score determined on the basis of harmonized requirements established at Union level, the shop states that score under Art. 246a § 1 (1) No. 20 EGBGB (BGBl. 2026 I No. 28). If not, and if the producer makes the information available, No. 21 applies instead: information on the availability, estimated cost and ordering procedure of spare parts, on repair and maintenance instructions and on repair restrictions (BGBl. 2026 I No. 28). According to the recitals of the directive, the trader does not have to actively search for this information (Directive 2024/825). For sales in a brick-and-mortar store, Art. 246 (1) No. 9 and 10 EGBGB contain the same sequence (BGBl. 2026 I No. 28). In practice this means: the data comes from the producer, and the shop needs one field per item that is only output when it is filled. A PIM system (blog article on PIM strategy) bundles this producer data in one place.

Software updates: state the minimum period when available

For goods with digital elements, digital content and digital services, the shop states under No. 11c the minimum period for which the producer or provider supplies software updates – as a period or a date, if the producer or provider makes this information available to the trader (BGBl. 2026 I No. 28). This concerns, for instance, smartphones, connected household appliances, smartwatches or software with a term. If the producer supplies nothing, the field stays empty; an estimated period does not belong on the product page. Shops that take master data from the ERP, for instance via an integration with Business Central, create the field there and pass it on to the shop.

Environmentally friendly delivery options before the contract

Under No. 10, the payment, delivery and performance terms also include environmentally friendly delivery options, if available (BGBl. 2026 I No. 28). The directive names delivery by cargo bikes or electric delivery vehicles and bundled shipping options as examples (Directive 2024/825). This does not create a duty to offer such options; the point is transparency about what exists. Describing a delivery method as environmentally friendly is itself an environmental claim: generic environmental claims without demonstrable recognized excellent environmental performance and neutrality claims based on offsetting are prohibited (BGBl. 2026 I No. 43).

• Shipping method with description: the delivery method is named factually, for instance "delivery by cargo bike within the city", instead of being advertised generically as "green".
• Bundled shipping: the option to ship several items together is one of the directive's examples and can be set up as a separate shipping method in checkout.
• Parcel lockers and parcel shops: if they are described as environmentally friendly, the claim needs a sound basis.
• Emission figures only with a traceable calculation basis from the shipping provider, not as the shop's own estimate.
• No neutrality claim through offsetting: "climate-neutral shipping" achieved through compensation payments falls under the ban on offsetting-based claims (BGBl. 2026 I No. 43).

Harmonized legal guarantee notice (Implementing Regulation 2025/1960)

No. 11 has also been reworded: the shop informs about the existence of the statutory legal guarantee for goods and its main elements, including its minimum period of two years, in a prominent manner using the harmonized notice under Annex I of Implementing Regulation (EU) 2025/1960 (BGBl. 2026 I No. 28). None of the elements of the notice is editable (Implementing Regulation 2025/1960), and for distance contracts concluded online it has to be shown in color in RGB (Implementing Regulation 2025/1960). For online sales, the directive gives a general reminder on the trader's website as an example (Directive 2024/825). What the notice and the label look like in detail is described in the article on the EU warranty label.

GARAN label for producer durability guarantees

The GARAN label is added when the producer offers a commercial guarantee of durability at no additional cost for the whole good with a duration of more than two years and makes this information available to the trader (Directive 2024/825). Only three fields are editable: the guarantee period in years, the name of the producer and the model identifier (Implementing Regulation 2025/1960). The label contains a QR code to the Your Europe portal (Implementing Regulation 2025/1960) and, in online retail, sits for example directly next to the image of the good (Directive 2024/825). In Germany, the information under No. 11a also has to be available clearly, comprehensibly and in a prominent manner immediately before the order, as laid down in § 312j (2) BGB (BGBl. 2026 I No. 28). Online, a nested format is possible, which has to appear in full on the first click, rollover or touch (Implementing Regulation 2025/1960). Since version 6.7.14, Shopware ships a product field for the guarantee period that stays empty or holds a half-year value above 24 months (Shopware). For older versions, the example shows a conditional output via custom fields.

{# For themes before Shopware 6.7.14; from that version the core ships field and output
   for the GARAN label. Each item only appears when the producer has supplied it. #}
{% set extra = page.product.translated.customFields %}

{% if extra.product_repair_score is not empty %}
    <p class="product-repair-score">
        {{ 'product.repairScore'|trans|striptags }}: {{ extra.product_repair_score }}
    </p>
{% elseif extra.product_spare_parts is not empty %}
    <p class="product-spare-parts">{{ extra.product_spare_parts }}</p>
{% endif %}

{% if extra.product_update_period is not empty %}
    <p class="product-update-period">
        {{ 'product.updatePeriod'|trans|striptags }}: {{ extra.product_update_period }}
    </p>
{% endif %}

{% if extra.product_garan_years > 2
      and extra.product_garan_producer is not empty
      and extra.product_garan_model is not empty %}
    <details class="product-garan">
        <summary>{% sw_include '@ShopTheme/storefront/component/product/garan-short.html.twig' %}</summary>
        {% sw_include '@ShopTheme/storefront/component/product/garan-label.html.twig' %}
    </details>
{% endif %}

Greenwashing bans: what's no longer allowed

The directive extends the list of commercial practices that are in all circumstances unfair; in Germany, the new practices are listed in the annex to the UWG (BGBl. 2026 I No. 43). In addition, § 5 UWG explicitly names circularity aspects such as durability, repairability or recyclability as characteristics a commercial practice must not mislead about (BGBl. 2026 I No. 43). Claims about future environmental performance are misleading if they lack clear, objective, publicly available and verifiable commitments set out in a detailed and realistic implementation plan that is regularly verified by an independent external expert (BGBl. 2026 I No. 43). Typical pitfalls are covered in the article on greenwashing in e-commerce. Prohibited practices include:

• Sustainability labels without a certification scheme: a label that is neither based on a certification scheme nor established by public authorities (BGBl. 2026 I No. 43).
• Generic environmental claims such as "environmentally friendly" or "green" if the trader cannot demonstrate recognized excellent environmental performance relevant to the claim (BGBl. 2026 I No. 43).
• Neutrality claims through offsetting: claims that a product has a neutral, reduced or positive impact on the environment in terms of greenhouse gas emissions based on offsetting (BGBl. 2026 I No. 43).
• Legal requirements as a distinctive feature: presenting requirements imposed by law on all products in the category on the Union market as a distinctive feature of the trader's offer (BGBl. 2026 I No. 43).
• Built-in durability limitation: commercial practices relating to a good containing a feature introduced to limit its durability, although information on this feature and its effects is available to the trader (BGBl. 2026 I No. 43).

EU repairability score and national indices

The directive defines the repairability score as a score expressing the repairability of a good based on harmonized requirements established at Union level (Directive 2024/825). National schemes do not automatically meet this requirement. The French repair index currently covers five product groups: laptops, lawnmowers, dishwashers, vacuum cleaners and pressure washers (French Ministry for Ecological Transition). It is based on French law and is not a score under No. 20. Whether an EU score exists for a product group is clarified with the producer who supplies the information. The table shows what the shop outputs depending on the data available.

Fines and enforcement risk

Competitors and associations can issue warning letters and claim injunctive relief under the UWG for breaches of information duties and the new bans. In addition, Art. 246e EGBGB provides fines for certain infringements of consumer interests: up to EUR 50,000, for traders with an annual turnover of more than EUR 1.25 million up to 4% of annual turnover; where there is no basis for estimating annual turnover, the maximum is EUR 2 million (BGBl. 2026 I No. 28). Such a fine can only be imposed within a coordinated enforcement action under Article 21 of Regulation (EU) 2017/2394 (BGBl. 2026 I No. 28). § 19 UWG provides the same range of fines for infringements of § 5c UWG (BGBl. 2026 I No. 43). For unfair commercial practices, the UCP Directive requires the maximum amount of such fines to be at least 4% of annual turnover, or at least EUR 2 million where no information on annual turnover is available (UCP Directive).

Technical implementation in Shopware

In Shopware, the information can be implemented without changes to the core. Since version 6.7.14, Shopware ships a product field guaranteeMonths for the durability guarantee (Shopware) and outputs notice and label in the buy widget, the cart line items and on the checkout confirmation page (Shopware). For repairability, spare parts, instructions and update period, the shop creates its own custom fields, filled from the PIM system (blog article on PIM strategy) or the ERP. Implementation is handled by our Shopware agency; concept and data flow are supported by our e-commerce expertise, and special cases are solved by our programming department.

• Custom fields per product for repairability score, spare parts information, instruction links, repair restrictions and minimum update period.
• Conditional output: a field only appears on the product page when it is filled – empty fields do not produce placeholders such as "not available".
• Twig blocks in the product detail page, without core changes and compatible with edge caching and global performance.
• Check during import: the product import reports items with digital elements without update information, so that the producer data can be requested specifically.
• Shipping methods with a factual description of environmentally friendly delivery options in checkout.
• Search index: custom fields that feed into filters or semantic product search follow the same rules as the product page.
• Legal texts: adjust terms and mandatory information in a coordinated way – together with other changes in consumer contract law such as the withdrawal button.

Checklist for ongoing operations

1. Take stock: identify product groups with digital elements, repairable goods and producer guarantees over two years; list existing environmental claims and labels.
2. Request producer data: ask suppliers for repairability score, spare parts and instruction information, minimum update period and guarantee data.
3. Create data fields: create custom fields in the shop and in the PIM and align the import with other master data, for instance for ZUGFeRD invoices.
4. Embed templates: embed the official legal guarantee notice and – where the conditions are met – the GARAN label.
5. Describe shipping methods: name environmentally friendly delivery options factually and remove neutrality claims.
6. Update regularly: check new products, producer data and claims; our consulting is available for a technical review.

Map the information cleanly instead of patching it later

The new information duties are above all a data task: shops that take repair, update and guarantee information from the producer in structured form can output it conditionally on the product page and do not have to estimate anything. Similar data plays a role for the Digital Product Passport and the right to repair. Shops already working on product page and checkout can sensibly combine the adjustment with the withdrawal button and the invoicing process under ZUGFeRD. For a technical review of your product pages, our consulting is available; the legal assessment of individual claims belongs in the hands of a lawyer.