With the date of application on 27 September 2026, what online retailers have to show when selling goods to consumers changes: the harmonised EU notice on the legal guarantee has to appear in a prominent manner. Where the producer offers a durability guarantee at no additional cost for the whole good with a duration of more than two years and makes the information available to the trader, the GARAN label is added (Directive 2024/825). Design and wording of both are laid down in Annexes I and II of Implementing Regulation (EU) 2025/1960; on the GARAN label only guarantee duration, producer and model identifier are filled in (Implementing Regulation 2025/1960). This guide explains what applies, what the labels look like, where they sensibly sit in your online shop and how to set up your product pages for them.
What the New EU Labels Require
The legal basis is the so-called EmpCo Directive (EU) 2024/825, which added new information duties to European consumer law (Directive 2024/825). Graphic templates, wording and design specifications are set by Commission Implementing Regulation (EU) 2025/1960 of 25 September 2025; it applies from 27 September 2026 (Implementing Regulation 2025/1960). In Germany, the obligations follow from the Act of 3 February 2026 in Art. 246 and 246a EGBGB and also enter into force on 27 September 2026 (BGBl. 2026 I No. 28). They cover contracts for goods with consumers, in brick-and-mortar stores as well as online, with no exception by company size. For digital content and digital services, No. 11b only requires a simple reminder of the legal guarantee, not the harmonised notice (BGBl. 2026 I No. 28).
The obligation follows a consumer-policy goal: buyers should be able to see, before purchase, what rights they have and how durable a product is. That strikes a chord. Around 90 percent of European consumers pay close attention to product sustainability (Oney), and 64 percent try to repair products rather than replace them (BEUC). A clear, comparable label for guarantee and durability therefore supports not only compliance with the requirements but also a buying argument that many customers value.
Regardless of any voluntary producer guarantee, the seller is liable for any lack of conformity that exists at delivery and becomes apparent within two years (Sale of Goods Directive). For second-hand goods, member states may allow an agreed shorter period that is not less than one year (Sale of Goods Directive). This minimum protection is what the harmonised notice makes visible – it does not create a new right, it informs about an existing one in a uniform way across the EU. That reduces misunderstandings in customer contact.
Two Labels With Different Purposes
It is important to keep the two labels clearly apart, because they serve different purposes and have a different scope. The harmonised notice informs in general about the legal guarantee and concerns every trader selling goods to consumers. The GARAN label, by contrast, marks a commercial guarantee of durability from the producer and only has to be shown where such a guarantee meets the conditions. In practice, customers will as a rule see the notice, while the GARAN label only appears on products with a corresponding producer guarantee. The following overview compares the features.
| Aspect | Legal guarantee notice | GARAN label |
|---|---|---|
| Basis | legal guarantee | commercial guarantee of durability from the producer |
| Obligation | when selling goods to consumers | only for a guarantee at no additional cost, for the whole good, over more than two years and with the producer providing the information to the trader |
| Content | minimum rights, no element editable | guarantee duration in years, producer, model identifier |
| Reference | general, across products | per model |
| Special feature | QR code to the Your Europe portal | QR code, language-neutral, online also nested |
The GARAN label only applies to a guarantee that meets four conditions at once: the producer offers it at no additional cost, it covers the whole good, it runs for more than two years, and the producer makes the information available to the trader (Directive 2024/825). According to the recitals of the directive, the trader does not have to actively search for this information, for example on producer websites (Directive 2024/825). The label states the guarantee duration in years, the producer and the model identifier, making it comparable which producer stands behind its product for longer. Without such a guarantee, the notice alone applies.
Unlike the general notice, the GARAN label shows at a glance that a producer stands behind the durability of its product beyond the legal minimum. Retailers carrying durable products therefore clarify with producers which guarantees meet the conditions and which information they provide – and maintain duration, producer and model identifier so that the label appears on the right product.
Design: Official Template, Three Fields on the GARAN Label
Both labels are standardised, but not equally strictly. On the notice, no element is editable (Implementing Regulation 2025/1960). On the GARAN label, three fields are filled in: the guarantee duration in years instead of "XX", the name of the producer instead of "Brand/Trademark" and the model identifier instead of "Model identifier" (Implementing Regulation 2025/1960). The typeface Inter is prescribed for these fields too (Implementing Regulation 2025/1960). The label is designed to be language-neutral and carries a statement in all official languages (Implementing Regulation 2025/1960). Online, both labels are in colour, the notice explicitly in RGB (Implementing Regulation 2025/1960), and both contain a QR code to the Your Europe portal (Implementing Regulation 2025/1960). The minimum sizes – A4 for the notice and 95 × 100 mm for the label – apply only outside online distance contracts (Implementing Regulation 2025/1960). If the label is displayed larger, it has to appear in full, without its elements being distorted, altered or separated from one another (Implementing Regulation 2025/1960).
Custom icons, other colours, a different typeface or a layout adapted to the shop theme are not provided for in the templates. Forcing the label into your corporate design means no longer showing a harmonised version. Embed the graphic files of the European Commission or the output of a shop system that reproduces the template (European Commission); on the GARAN label only the three editable fields are added.
There is leeway only for the GARAN label and only online: for distance contracts concluded via an online interface, it may appear in a nested format, i.e. as a compact short form according to the figure in Annex II (Implementing Regulation 2025/1960). On the first mouse click, the first mouse roll-over or the first touch on a touchscreen, the full label then has to appear (Implementing Regulation 2025/1960). Annex I provides no nested format for the notice. If you use the short form, place it so that it is recognisable as part of the product information and does not disappear into footnotes or nested menus.
Placement: Prominent and Before the Order
Neither the directive nor the implementing regulation prescribes a fixed spot on the page; what is required is a display in a prominent manner. The recitals of the directive give examples for online sales: the GARAN label directly next to the image of the good and the notice as a general reminder on the website of the trader (Directive 2024/825). For the GARAN label, § 312j (2) BGB adds a German requirement: the information under Art. 246a § 1 (1) sentence 1 No. 11a EGBGB has to be provided clearly, comprehensibly and in a prominent manner immediately before the consumer places the order (BGBl. 2026 I No. 28). This requirement does not apply to the notice under No. 11. On smartphones, mandatory information quickly slips down the page; a good product page therefore arranges price, shipping, availability and labels deliberately instead of squeezing the labels in afterwards.
- Close to the product: we recommend showing the GARAN label within sight of the product image, price and add-to-cart button – the directive names the spot next to the image of the good as an example, not as a fixed rule.
- Optimised for mobile: visible and tappable on small displays too, without losing the prescribed colour rendering.
- Accessibly embedded: with an alternative text naming guarantee duration and producer, and a keyboard-accessible trigger for the nested display.
- Linguistically fitting: the notice in the language of the shop; the GARAN label is language-neutral and carries its statement in all official languages.
Because the label sits exactly where accessibility is checked too, it pays to look at both topics together. How automated checks scrutinise the product page is shown in our article on automated BFSG authority scans; the underlying implementation is covered by our accessibility service. And if you are reworking the product page anyway, optimise it at the same time for AI answers and shopping searches so that structured product data and mandatory disclosures fit together.
Enforcement: Warning Letters and Fines
In Germany, the notice and the GARAN label are statutory information duties under Art. 246 and 246a EGBGB. If they are missing or deviate from the template, competitors and associations can send warning letters under general competition law; how courts will assess individual presentation questions is still open. A fine under Art. 246e EGBGB, by contrast, can only be imposed within a coordinated enforcement action under Art. 21 of Regulation (EU) 2017/2394 (BGBl. 2026 I No. 28). What remains particularly sensitive: a missing or visibly altered label is easy to spot from outside – simply by opening the page, without any insight into internal processes.
Whether a label is present and matches the template can be seen on a shop page at once. That is exactly what makes the new obligation an obvious target for serial checks. A check across categories, variants, languages and devices uncovers missing or altered labels before third parties find them.
Implementation in the Shop, Step by Step
Technically, the task is manageable if approached in a structured way. The notice is a general building block: a reminder in a clearly visible place on the website that makes the full notice accessible. The GARAN label, by contrast, is rendered conditionally – only for products with a matching producer guarantee stored with duration, producer name and model identifier. This logic belongs cleanly in the data model and the template, so that no label appears on a product without a matching guarantee and none is missing where the conditions are met.
- Inventory: review product pages, cart and checkout and define where the notice and the GARAN label appear.
- Data maintenance: per model, record the guarantee duration in years, the name of the producer (Brand/Trademark) and the model identifier (Model identifier) – and note whether the four conditions are met.
- Template integration: embed the official templates in colour – the notice generally, the GARAN label conditionally, online optionally nested.
- Accessibility and mobile: check alternative texts, keyboard operation and display on small screens.
- Test and approval: check the display across categories, variants, languages and devices before it goes live.
The platform you work on decides only the path, not the destination. In Shopware, the core has included both labels since version 6.7.14: a product field for the guarantee duration (empty, or a half-year value above 24 months), both labels in the buy box, in the cart line items and on the checkout confirmation page, and the notice in all 24 official languages, switchable via core.cart.showLegalGuaranteeNotice (Shopware). As producer, Shopware uses the manufacturer of the product, as model identifier the manufacturer product number; below the buy box the label first appears as a compact preview, and a click opens the full label (Shopware). In other CMS systems the integration works via the respective product template; individual requirements we solve through tailored development. If you are working on an outdated base anyway, it makes sense to combine the switch with a move to a maintained version – see our article on the migration from Shopware 5, which has received no security updates since its end of life. Setup and the reminder near the buy box are described in the article on setting up the warranty notice in Shopware. The following example uses the core filters for a custom location in the theme; the call form matches the one Shopware documents for the mail template.
{# Custom location outside the buy box, e.g. a comparison view:
compact form as the trigger, full label on the first click or tap #}
{% set garanNested = product.id|sw_garan_label_nested_uri(context) %}
{% if garanNested %}
<details class="product-garan">
<summary>
<img src="{{ garanNested }}" alt="{{ 'product.garanLabel'|trans|striptags }}">
</summary>
<img src="{{ product.id|sw_garan_label_data_uri(context) }}"
alt="{{ 'product.garanLabelFull'|trans|striptags }}">
</details>
{% endif %}Check Your Product Pages Now
The specifications are fully published: the implementing regulation applies from 27 September 2026 (Implementing Regulation 2025/1960), and the German provisions enter into force on the same day. When embedding the labels, it is best to organise the data maintenance for GARAN guarantees at the same time and to test the display on desktop and smartphone. XICTRON supports this step from analysing the product pages to the tested rollout in live operation. A checklist for adapting the shop is included in the article on the EU warranty label.
Analysis of your product pages
We review templates and layout and define where the notice and the GARAN label appear in a prominent and clearly visible way.
Clean technical integration
The official templates are integrated in colour and accessibly – generally for the notice, conditionally per product for the GARAN label.
Display as per the template
Unchanged templates, nested display only for the GARAN label and tested behaviour on desktop and smartphone – aligned with your accessibility.
Data maintenance for GARAN
We set up fields and logic for guarantee duration, producer and model identifier so that the label only appears where the conditions are met.
Whether the notice and the GARAN label sit correctly can easily be checked from outside – which makes a clean, tested implementation all the more important. Talk to our team if you want to set up your product pages for the new EU labels; together we will bring the notice and the GARAN label into your online shop as per the official template.
This article draws on Directive (EU) 2024/825 (EmpCo Directive), Commission Implementing Regulation (EU) 2025/1960 on the design, content and date of application of the harmonised labels, the Act of 3 February 2026 (BGBl. 2026 I No. 28) transposing the rules into the BGB and EGBGB, the Sale of Goods Directive (EU) 2019/771 on the liability period, the graphic files and guidelines of the European Commission, and the release notes for Shopware 6.7.14 together with Shopware's information on the GARAN label. Consumer figures come from Oney and BEUC. Figures may change over time; this article is no substitute for individual legal advice. As of September 2026.
The labels apply from 27 September 2026: from that day Implementing Regulation (EU) 2025/1960 applies (Implementing Regulation 2025/1960), and on the same day the amended provisions of the BGB and EGBGB enter into force in Germany (BGBl. 2026 I No. 28). The legal basis is the EmpCo Directive (EU) 2024/825, the design is set by the implementing regulation. The German act was promulgated on 5 February 2026.
The harmonised notice informs in general about the legal guarantee: the seller is liable for any lack of conformity that becomes apparent within two years of delivery (Sale of Goods Directive). The GARAN label, by contrast, marks a commercial guarantee of durability from the producer and only has to be shown where it is offered at no additional cost, covers the whole good, runs for more than two years and the producer makes the information available to the trader (Directive 2024/825). It states the guarantee duration in years, the producer and the model identifier.
No. On the notice, no element is editable (Implementing Regulation 2025/1960). On the GARAN label, only three fields are filled in – guarantee duration, producer and model identifier – set in the typeface Inter (Implementing Regulation 2025/1960). Online, both labels are in colour; the regulation sets no fixed minimum size there, but the QR code must remain readable with a standard mobile device. Online, the GARAN label may appear nested if the full label opens on the first click, roll-over or tap (Implementing Regulation 2025/1960).
The notice concerns every trader selling goods to consumers, online and in stores; in Germany, the obligations are set out in Art. 246 and 246a EGBGB. There is no exception by company size. Pure B2B shops are generally not affected, provided they sell exclusively to business customers (Shopware). For digital content and digital services, a simple reminder of the legal guarantee is sufficient (BGBl. 2026 I No. 28). The GARAN label is only added for a producer guarantee that meets the conditions.
The notice and the GARAN label are statutory information duties; if they are missing or deviate from the template, competitors and associations can send warning letters. A fine under Art. 246e EGBGB can only be imposed within a coordinated enforcement action under Art. 21 of Regulation (EU) 2017/2394 (BGBl. 2026 I No. 28). Because an error can be spotted simply by opening the page, a tested implementation pays off.
We analyse your product pages, define a prominent placement and embed the official templates in colour and accessibly – the notice generally, the GARAN label conditionally per product. In addition, we set up the data maintenance for guarantee duration, producer and model identifier and test the display across categories, languages and devices. This turns the switch into a plannable, documented project.