Online shops in the EU must use a uniform notice to remind consumers of their legal guarantee rights – often simply called the warranty label. The date of application is September 27, 2026. Directive (EU) 2024/825 applies to every trader selling goods to consumers in the EU – regardless of size or sector. Design and content are set by Commission Implementing Regulation (EU) 2025/1960: it covers the mandatory notice on the legal guarantee of conformity and the GARAN label, which is added only for certain producer guarantees. Those who do not display the notice risk cease-and-desist warnings.
What Is Behind the Warranty Label
The harmonised notice on the legal guarantee of conformity is a uniform notice that reminds consumers of their legal guarantee rights, in the shop as well as when buying online. The EU Commission is responding to a fundamental problem: 35% of EU consumers have only limited knowledge of their consumer rights (EU Consumer Scoreboard 2025). At the same time, 74% of consumers want the warranty period to reflect the expected lifespan of the product (forsa/vzbv).
Directive (EU) 2024/825 introduces two uniform formats: the harmonised notice on the legal guarantee of conformity, which every merchant must display, and the harmonised label titled 'GARAN' for certain producer guarantees of durability of more than two years. Color does not tell them apart: both use the same four reference colors. Design, font and minimum sizes are set by Commission Implementing Regulation (EU) 2025/1960. For e-commerce merchants, this means concrete adjustments to product pages, templates and data management.
The background: The EU e-commerce market reached a turnover of EUR 842 billion with growth of 7% in 2024 (EuroCommerce Report 2025). At the same time, the probability of problems with online purchases is 60% higher than in physical retail (EU Consumer Scoreboard 2025). The label is intended to reduce this trust deficit and strengthen cross-border trade – 35% of EU consumers already purchased in another EU country in 2024 (EU Consumer Scoreboard 2025).
Timeline and Legal Framework
Directive (EU) 2024/825 (Empowering Consumers Directive) defines clear deadlines for national transposition and the application obligation for merchants.
- 2024: Adoption of Directive (EU) 2024/825
- September 25, 2025: The Commission adopts Implementing Regulation (EU) 2025/1960 on design and content
- February 3, 2026: Germany transposes the directive with the Act amending consumer contract and insurance contract law (BGBl. 2026 I No. 28)
- March 27, 2026: End of the transposition period for the member states
- September 27, 2026: Start of application – the national rules and Implementing Regulation (EU) 2025/1960 apply from this date
The transposition period (March 27, 2026) was addressed to the member states. Merchants are bound from the date of application, September 27, 2026: the notice on the legal guarantee must be displayed in a prominent manner, in the shop as well as online; for goods with a qualifying guarantee of durability, the GARAN label is added. Because the notice and the label affect the templates and product data of the shop, implementation deserves its own work step including testing.
Implementing Regulation (EU) 2025/1960 applies directly in all EU member states and sets out the design and content of both formats. The obligation to use them, however, follows from the national laws transposing the directive. German merchants selling to other EU countries may need to provide the notice in the respective language version; the GARAN label is language-neutral and already carries the words 'producer guarantee in years' in all official languages. In Germany, the transposing act has been promulgated: the Act of 3 February 2026 (BGBl. 2026 I No. 28) adds the notice and the GARAN label to Art. 246 EGBGB for in-store sales and to Art. 246a § 1 EGBGB for distance contracts. Entry into force of these parts: September 27, 2026.
The Notice and the GARAN Label in Detail
Implementing Regulation (EU) 2025/1960 sets out two formats with clearly distinct functions: the notice in Annex I and the label in Annex II. Both use the same four reference colors; the regulation expressly prescribes the Inter font (Regular, SemiBold, ExtraBold) for the label.
| Property | Notice on the legal guarantee | GARAN label (guarantee of durability) |
|---|---|---|
| Mandatory | Always – when selling goods to consumers | Only with a producer guarantee of durability: more than 2 years, entire good, no additional cost |
| Reference colors | Pantone Reflex Blue C (#003399), Pantone Yellow C (#FFED00), black, white | The same four colors |
| Editable fields | None – no element can be edited | Guarantee duration in years, producer name, model identifier |
| Content | At least two years of legal guarantee, remedies for lack of conformity, QR code to the Your Europe portal | Title 'GARAN', guarantee duration, reminder of the legal guarantee, QR code |
| Minimum size (physical) | A4 | 95 × 100 mm |
| Online display | In color (RGB); e.g. as a general reminder on the website | In color; e.g. directly next to the product image, nested display allowed |
The notice on the legal guarantee is mandatory for every merchant selling goods to consumers – regardless of product range or company size. Its text is fixed and cannot be edited: it states the minimum duration of two years and the remedies for lack of conformity, and links via QR code to the Your Europe portal. The notice has no fields for the individual seller or the duration of the burden of proof reversal.
The GARAN label is only required when the producer grants a guarantee of durability covering the entire good, at no additional cost and for more than two years, and makes this information available to the trader. The GARAN label is designed to create transparency here, because voluntary guarantees are currently presented in very different ways. For Shopware shops and WooCommerce shops, this means product data must be extended with guarantee fields. Further details on the conditions are summarised in the article on the warranty and guarantee label.
Technical Implementation in the Online Shop
Integrating the notice and the GARAN label requires adjustments on multiple levels. With an online shopper share of 76% in the EU (EU Consumer Scoreboard 2025), the display must function flawlessly on all devices and in all common browsers.
Template Integration
Place the GARAN label directly next to the product image and the notice as a clearly visible general reminder on the website – not hidden in a tab
Extend Data Model
Create product attributes for the GARAN label fields: guarantee duration in years, producer name and model identifier – the notice itself needs no product data
Multilingual Support
Provide the notice in the language version of each sales country – relevant for shops with international shipping within the EU; the GARAN label is language-neutral
Responsive Design
Label must be readable on desktop, tablet and smartphone – maintain minimum font sizes and contrast ratios
Performance
Embed the label as a vector graphic or reproduce it faithfully in HTML/CSS – colors, font and layout must not deviate from the template
Structured Data
Add Schema.org markup for warranty and guarantee – supports Google Rich Snippets
The technical implementation depends on the shop system. With Shopware 6 (Community Edition), the label can be realized through a custom plugin or template overrides. With WooCommerce, custom fields or a dedicated plugin are suitable options. The key requirement is that label data can be maintained per product – as whether a producer guarantee exists and how long it runs may vary by product. Online shops that have already optimized their technical SEO and Core Web Vitals will find it easier to implement additional compliance requirements. For Shopware, the article on setting up the warranty notice in Shopware describes the route via Shopping Experiences and language snippets.
Online display has its own rules: the notice and the label must be in color, and the label may use a nested display, provided it appears in its entirety on the first mouse click, mouse roll-over or tactile screen expansion. The minimum sizes apply only to contracts not concluded through an online interface. The Inter font is freely available as an open-source font. No conversion of the Pantone colors is needed: the regulation itself states the HEX values, #003399 for blue, #000000 for black and #FFFFFF for white. For yellow, the Official Journal reads #FFEDOO with the letter O; the stated RGB value (255, 237, 0) corresponds to #FFED00. Neither has to be rebuilt: the European Commission provides the notice in all official languages and the GARAN label, for e-commerce also in the nested display, as graphic files with guidelines.
Warning Risks and Common Mistakes
Experience with previous regulations shows: New obligations in e-commerce are monitored intensively. 18% of online retailers received a warning in 2024, after 12% in 2023 (Händlerbund 2025). If the notice is missing or not displayed prominently, the shop breaches a statutory information duty, which can be subject to a cease-and-desist warning.
- Missing notice: The notice on the legal guarantee is missing from the website or hard to find – an obvious breach when the deadline is underestimated
- Wrong colors or font: Deviations from the prescribed reference colors or, for the label, a font other than Inter
- Altered template: Own texts or fields in the notice, although none of its elements can be edited; for the label, missing guarantee duration, producer name or model identifier
- Missing GARAN label despite producer guarantee: If the producer grants a guarantee of durability of more than two years for the entire good at no additional cost and provides the information to the trader, the GARAN label is mandatory
- Hidden instead of prominent: The notice only appears in the terms or on a hard-to-find subpage – the notice and the label must be displayed in a prominent manner
- Missing accessibility: Labels as non-scalable images without alt text – may additionally violate the accessibility requirements
- Outdated guarantee data: If the producer changes the duration or scope of its guarantee, the label data must be updated promptly
Additionally: 45% of consumers have already encountered online fraud (EU Consumer Scoreboard 2025). The absence of the official notice could be interpreted by consumers as a warning sign and further undermine trust in the shop. Professional consulting helps avoid typical pitfalls.
Checklist for Shop Adaptation
For implementation in the shop, we recommend the following sequence. 74% of consumers want durability-based warranty coverage (forsa/vzbv) – showing how closely this topic is being followed.
Analysis: Review product range for warranty and guarantee data · Evaluate shop system compatibility · Schedule a consultation Data model: Create product attributes for the GARAN fields (guarantee duration, producer name, model identifier) · Migrate existing product data · Set up CSV/API import for bulk maintenance Template integration: Embed the Commission's official graphic files unchanged · Output the GARAN information from the product data and show it immediately before the order · Perform responsive tests on all devices · Ensure accessibility compliance Quality assurance: Spot checks across items with and without a producer guarantee · Automated tests for the display · Legal review by specialized attorney Go-live: Activate the notice and labels in production · Set up monitoring · Train staff
Those who have already implemented the withdrawal button know the process: plan early, implement cleanly, test thoroughly. The notice and the GARAN label require the same structured approach – with the difference that not just a single button is affected, but the notice on the website and, for producer guarantees, the product data as well. The connection to the right to repair also shows that the EU is consistently pushing for more consumer transparency in e-commerce. The BFSG accessibility requirement also belongs on the same implementation roadmap. Those simultaneously working on SEO recovery after the Google Core Update March 2026 can bundle the technical shop adjustments.
This article is based on: Directive (EU) 2024/825, Commission Implementing Regulation (EU) 2025/1960, the German Act of 3 February 2026 (BGBl. 2026 I No. 28), the European Commission's guidelines and graphic files, the EU Consumer Scoreboard 2025, the European E-commerce Report 2025 (EuroCommerce), the forsa/vzbv warranty survey and the Händlerbund Abmahnstudie 2025. The figures mentioned may vary depending on the time of collection. Status: September 2026.
Frequently Asked Questions About the Notice and the GARAN Label
Yes, Directive (EU) 2024/825 makes no exceptions based on company size. All merchants selling goods to consumers in the EU must, from September 27, 2026, remind consumers of the legal guarantee in a prominent manner using the harmonised notice – regardless of turnover or number of employees.
No, the GARAN label is only mandatory when the producer grants a guarantee of durability covering the entire good, at no additional cost and for more than two years, and makes this information available to the trader. Without such a guarantee, the notice on the legal guarantee is sufficient.
Neither the directive nor the implementing regulation prescribes an exact position; what is required is display in a prominent manner. For online sales, the recitals of the directive give as examples the GARAN label directly next to the picture of the good and the notice as a general reminder on the website of the trader. For goods with a GARAN label, the information on the guarantee of durability must also be provided clearly and prominently immediately before the customer places the order (Art. 8(2) of Directive 2011/83/EU as amended by Directive (EU) 2024/825). In Germany, this follows from section 312j(2) BGB, which the Act of 3 February 2026 extends to the GARAN information under Art. 246a § 1(1) sentence 1 no. 11a EGBGB.
Each EU member state sets the sanctions. In Germany, the notice and the GARAN label are statutory information duties under Art. 246 and 246a EGBGB; infringements can be subject to cease-and-desist warnings from competitors and associations. A fine under Art. 246e EGBGB requires a widespread infringement and can only be imposed within a coordinated enforcement action of the EU consumer protection authorities.
Three points decide whether a plugin is enough: it embeds the Commission's official graphic files unchanged, it reads the guarantee duration for the GARAN label from the product data instead of free text, and it shows the GARAN information immediately before the order. If one of them is missing, it can usually be added through a template adjustment or a custom extension.
The notice and the GARAN label relate to goods. For digital content and digital services, the directive requires a separate reminder of the legal guarantee, for which the regulation does not set a uniform template. Merchants selling both physical and digital products should clearly distinguish between them in their shop system.