From 27 September 2026, what online retailers must show right on the product page will change: for every consumer product, a harmonised EU legal guarantee notice becomes mandatory, and wherever producers offer a free durability guarantee beyond two years, the new GARAN label is added as well (Implementing Regulation 2025/1960). Both labels are fixed in colour, typeface and wording and may not be altered (Directive 2024/825). This guide explains what applies, what the labels look like, where they must appear in your online shop and how to prepare your product pages in time.
What the New EU Label Requires
The legal basis is the so-called EmpCo Directive (EU) 2024/825, which added new information duties to European consumer law (Directive 2024/825). The concrete design - the graphic templates, the exact wording and all design specifications - is set by Commission Implementing Regulation (EU) 2025/1960 of 25 September 2025 (Implementing Regulation 2025/1960). The rules apply from 27 September 2026, EU-wide for all B2C commerce, with no exception by company size or sector (Implementing Regulation 2025/1960). In Germany, the corresponding transposition act was already published in the Federal Law Gazette on 5 February 2026 (Federal Law Gazette), so the legal framework has long been in place and only the practical implementation in the shop remains open.
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), roughly 73 percent call the environmental impact an important criterion in their purchase decision (Eurobarometer), and 64 percent try to repair products rather than replace them (BEUC). A clear, comparable label for guarantee and durability therefore supports not only legal certainty but also a buying argument that many customers value.
Regardless of any voluntary producer guarantee, consumers in the EU have a statutory right to a legal guarantee of at least two years (Sale of Goods Directive). This is exactly the minimum protection the new legal guarantee notice makes visible - it does not create a new right, it informs about an existing one in a uniform way. That reduces misunderstandings in customer contact and creates the same level of information everywhere in the EU.
Two Labels With Different Purposes
It is important to keep the two labels clearly apart, because they have different jobs and a different scope. The legal guarantee notice is a general mandatory reference to the statutory guarantee and generally accompanies every product. The GARAN label, by contrast, marks a voluntary commercial durability guarantee from the producer and only appears when such a guarantee actually exists. The overview below contrasts the features.
| Aspect | Legal guarantee notice | GARAN label |
|---|---|---|
| Basis | statutory legal guarantee | voluntary producer guarantee |
| Requirement | for all goods | only if a guarantee is offered |
| Content | reference to minimum rights | durability in years |
| Scope | general, across products | product-specific |
| Special feature | QR code to details | stated guarantee period |
The GARAN label only applies to a guarantee that meets three conditions at once: it is free for the customer, it covers the whole product, and it runs longer than the two-year statutory guarantee (European Commission). The label states the promised durability in years and thus makes it comparable which provider really stands behind its product for longer. If no such guarantee exists, only the legal guarantee notice remains - a GARAN label must not be shown in that case (Implementing Regulation 2025/1960). This distinction is central, because it determines which label is even permitted on which product.
Unlike the plain legal guarantee notice, the GARAN label is a genuine selling point: it shows at a glance that a producer stands behind the longevity of its product beyond the legal minimum. If you carry durable products, check whether the producer guarantees meet the GARAN criteria - and then make the advantage visible instead of hiding it in the data sheet.
Design and Language Are Strictly Prescribed
Perhaps the biggest difference from many other mandatory disclosures: both labels are standardised down to the detail. Colours, typeface, layout and text modules are fixed and may not be shortened, extended or reworded (Implementing Regulation 2025/1960). In the online shop, the colour (RGB) display is mandatory; the label may not be reduced, distorted or integrated into your own design (Händlerbund). The legal guarantee notice also includes a scannable QR code that takes customers to further information (Händlerbund). Printed versions have their own minimum sizes, but in e-commerce the correct digital embedding is what matters.
Custom icons, extra highlights, different colours or a layout adapted to the shop theme are not permitted. Anyone forcing the label into their corporate design risks the same objection as omitting it entirely: an incorrectly presented mandatory label. The label is embedded as a finished graphic, not rebuilt.
There is some leeway in how it is embedded. According to the Commission's guidelines, a nested - that is, layered - display is permitted under certain conditions, for example through a clearly labelled, expandable element near the price (IT-Recht-Kanzlei). What remains decisive is that the information is clearly visible and easy to find before the purchase is completed, and does not disappear into footnotes or deeply nested menus. If you use the nested variant, keep the labelling unambiguous so it is clear at a glance what lies behind it.
Placement: Visible Before Checkout
Both labels must appear where the buying decision is made: on the product detail page, close to the price and the add-to-cart button, and before the order is completed (Implementing Regulation 2025/1960). That sounds simple but has practical consequences for the page layout - especially on smartphones, where space is tight and mandatory details quickly slip down. A good product page integrates the labels so they are noticed without long scrolling and still do not compete with the actual product information.
- On the product detail page: in view of price, availability and the add-to-cart button - not only in the footer or on a separate subpage.
- Mobile-optimised: visible and tappable on small displays too, without losing the prescribed colour rendering.
- Accessible: with meaningful alternative text and sufficient contrast, so the label is reachable via screen reader and keyboard.
- Linguistically correct: in the shop's respective national language, as the harmonised templates require.
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.
Warning Letters: Competitors and Associations Are Watching
The new label is a mandatory disclosure relevant under competition law. If it is missing entirely, incorrectly presented or wrongly placed, a warning letter from competitors or consumer associations may follow (IHK Köln). In serious cases, fines can be imposed as well (Händlerbund). What makes it particularly sensitive: a missing or obviously wrong label is easy to prove from the outside - unlike many internal process shortcomings, it can be spotted simply by opening the product page, without any insight into internal workflows.
Whether a colour label sits in the right place is immediately visible on a product page. That is exactly what makes the new duty a convenient target for serial checks. Planning and testing the switch early typically avoids the frantic rebuild shortly before the deadline - and the mistakes that come with it.
Implementation in the Shop, Step by Step
Technically the task is manageable if you approach it in a structured way. The legal guarantee notice can be built into the product detail page as a fixed component so it appears automatically for every article. The GARAN label, by contrast, is rendered conditionally - only for products where the producer has stored a matching durability guarantee with the number of years. This logic belongs cleanly in the data model and the template, so that no label ends up in the wrong place later.
- Take stock: review product pages and templates and decide where near the add-to-cart button the labels will appear.
- Maintain data: record per product or per producer whether a GARAN-eligible guarantee exists and for how many years it runs.
- Template integration: embed the prescribed graphics in RGB - the legal guarantee notice generally, the GARAN label conditionally.
- Accessibility and mobile: check alternative texts, contrast and rendering on small displays.
- Test and release: verify the display across categories, languages and devices before the deadline is reached.
The platform you work on decides only the path, not the destination. In Shopware the notice can be integrated cleanly into the storefront templates, in other CMS systems 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.
{# Legal guarantee notice: always show #}
<div class="legal-guarantee-label">
{{ include('storefront/component/eu-legal-guarantee.html.twig') }}
</div>
{# GARAN label: only with a matching producer guarantee #}
{% if product.customFields.garanYears %}
<div class="garan-label">
{{ include('storefront/component/eu-garan.html.twig',
{ years: product.customFields.garanYears }) }}
</div>
{% endif %}Prepare Your Product Pages Now
The deadline on 27 September 2026 is set, and the specifications are already fully published (Implementing Regulation 2025/1960). So there is no reason to postpone the switch to the last moment. Anyone planning now can place the labels calmly in the right spot, organise the data maintenance for GARAN guarantees and test everything thoroughly. XICTRON supports this step from analysing the product pages to the tested rollout in live operation.
Analysis of your product pages
We review templates and layout and define where the legal guarantee notice and GARAN label are placed in a compliant and visible way.
Clean technical integration
The prescribed graphics are integrated in RGB and accessibly - generally for the notice, conditionally for the GARAN label per product.
Compliant presentation
Correct placement near the cart, unchanged specifications and tested behaviour on desktop and smartphone - aligned with your accessibility.
Data maintenance for GARAN
We set up fields and logic so guarantee years are maintained per product and the label is shown automatically only where it belongs.
The earlier the preparation starts, the calmer the switch will be - without time pressure just before the deadline and without the risk of overlooking an easily checkable mandatory disclosure. Talk to our team if you want to get your product pages ready for the new EU labels; together we will bring the legal guarantee notice and GARAN label into your online shop in good time and cleanly.
This article draws on Directive (EU) 2024/825 (EmpCo Directive) and Commission Implementing Regulation (EU) 2025/1960 on the design, content and start date of the harmonised labels, the German transposition act published in the Federal Law Gazette, information from the European Commission (Your Europe) on the legal guarantee notice and GARAN label, the Sale of Goods Directive on the two-year minimum guarantee, and practical notes from Händlerbund, IT-Recht-Kanzlei and IHK Köln. Consumer figures come from Oney, Eurobarometer and BEUC. Figures may change over time; this article is no substitute for individual legal advice. As of August 2026.
The new labels are mandatory EU-wide from 27 September 2026 (Implementing Regulation 2025/1960). The legal basis is the EmpCo Directive (EU) 2024/825, with the exact design set by Commission Implementing Regulation (EU) 2025/1960. In Germany, the transposition act was already published in the Federal Law Gazette on 5 February 2026. Since the specifications are complete, an early switch is worthwhile.
The legal guarantee notice is a general mandatory reference to the statutory guarantee of at least two years and applies to all goods (Sale of Goods Directive). The GARAN label, by contrast, marks a voluntary durability guarantee from the producer and only appears if it is free, covers the whole product and runs longer than two years (European Commission). It states the promised durability in years.
No. Colours, typeface, layout and text modules are fixed and may not be altered, shortened or extended (Implementing Regulation 2025/1960). In the online shop the colour RGB display is mandatory, and the label may not be reduced, distorted or integrated into your own design (Händlerbund). It is embedded as a finished graphic, not rebuilt.
The obligation applies EU-wide to all B2C online commerce, regardless of company size or sector (Implementing Regulation 2025/1960). So every shop selling goods to consumers is affected. The legal guarantee notice is mandatory for all goods, while the GARAN label only appears where a matching producer guarantee is offered.
A missing, incorrectly presented or wrongly placed label can trigger a warning letter under competition law from competitors or consumer associations (IHK Köln), and in serious cases fines are possible as well (Händlerbund). Because the breach can be spotted simply by opening the product page, a timely, tested implementation is the more reliable choice.
We analyse your product pages, define the correct placement near the cart and embed the prescribed graphics in RGB and accessibly - the legal guarantee notice generally, the GARAN label conditionally per product. We also set up the data maintenance for guarantee years and test the display across categories, languages and devices. This typically turns the switch into a plannable project rather than a last-minute scramble.