Warranty Notice Obligation: Shopware Setup

From 27 September 2026, every online shop that sells to consumers must display a standardized notice on the statutory warranty - right where the buying decision is made: on the product page. The notice informs about the minimum two-year liability for defects and the rights to repair, replacement and refund. This guide shows not only what is required, but above all how to implement the mandatory notice cleanly in the Shopware page builder - as a reusable block, bilingual and without the risk of a warning letter. For the implementation in e-commerce with Shopware it is above all a question of the right placement and clean maintenance.

What is required from 27 September 2026

The basis is the so-called EmpCo Directive (EU) 2024/825 (Empowering Consumers for the Green Transition), which inserts a new Article 22a into the Consumer Rights Directive 2011/83/EU (EU Official Journal). It obliges traders to inform consumers clearly about the statutory warranty before purchase. The exact graphic and textual design of the notice is set out in the accompanying Implementing Regulation (EU) 2025/1960 (IT-Recht-Kanzlei) - including rules on colours and the structure of a harmonised EU label.

The deadline across Europe is 27 September 2026 (IT-Recht-Kanzlei). From that day the notice must be displayed in the shop. The rule applies to all companies selling goods to consumers - from niche shops to large mail-order businesses, with no exception for micro-enterprises (Haendlerbund). The only decisive factor is that it is a B2C sale of goods; pure B2B shops, services and digital content are treated differently.

Why the product page is the decisive place

The crux of the new rule is the placement. The information must not be hidden away in the terms and conditions or on a separate subpage. It must appear clearly visible on the product page - or in a comparably prominent place - and before the order is completed (Haendlerbund). This puts the notice where the buying decision is actually made.

For the technical implementation in Shopware this means: the notice belongs in the product page layout, ideally close to the price and the buy button. A text snippet placed once in the footer or on a CMS page does not reliably meet the requirement, because it is not in the immediate decision context. Working cleanly here avoids warning letters and, much like trust signals in the shop, strengthens confidence at the most important moment of the customer journey.

In practice this also means designing the display for mobile devices. On a smartphone the visible area above the fold is tight; a notice that only appears after a long scroll below reviews and cross-selling is arguably no longer in the decision context. In Shopware the order of blocks in the product page layout can be controlled deliberately, so the warranty notice stays reasonably close to the buy button on all devices. A short, clear wording with an expandable detail is often better here than a long body text that overloads the page.

The details must not be accessible only in the general terms and conditions or only after purchase - they belong visibly on the product page before the order.

Summary of the requirements (Haendlerbund)

Scope, exemptions and special cases

Before getting into the technology, it is worth taking a clear look at the scope - because it decides which product pages need a notice at all. In principle, all B2C sales of goods to consumers in the EU are covered, regardless of company size or sales channel (Haendlerbund). So anyone selling to both consumers and business customers should define exactly in which sales channel the notice appears - in Shopware this can be controlled cleanly via separate sales channels and customer groups.

• New goods to consumers: the notice on the minimum two-year statutory warranty is mandatory.
• Used goods: the notice obligation applies here too; with clear labelling the warranty may be shortened to at least one year (IT-Recht-Kanzlei).
• Pure B2B shops: are not covered by the new consumer notice obligation, as there is no B2C transaction (Haendlerbund).
• Services and purely digital content: are subject to their own rules and must be separated from the goods warranty label.
• Mixed assortments: product pages with consumer relevance need the notice - a blanket solution via the layout usually covers this reliably.

Especially with mixed assortments, the advantage of a layout-based setup becomes clear: instead of checking every product page individually, you define a product page layout with the notice block and assign it to the consumer-relevant categories. This leaves no gap and keeps maintenance manageable. Anyone running several sales channels - for example a B2C and a B2B channel - in one Shopware instance can output the notice exactly where it is needed.

Step-by-step setup in the Shopware page builder

Shopware (CE) comes with a flexible page builder via Shopping Experiences. For the product page there is an assignable CMS layout of the type product page. That is exactly where the warranty notice can be inserted as its own block, which then appears automatically on all assigned products. We usually proceed in four steps.

1. Open the product page layout: In the admin under Content - Shopping Experiences, choose the product page layout or create a new one set as default for the affected products.
2. Place the block: Below the buy area, add a new section with a text or custom block that holds the standardized notice including the EU label.
3. Maintain content: Store the prescribed wording on the statutory warranty and the harmonised label - language-dependent via snippets, so DE and EN are output correctly and automatically.
4. Assign and test the layout: Assign the layout to products or categories and check in a live preview that the notice is visible before order completion - on desktop and mobile.

For shops with a custom theme, instead of a plain text block a dedicated CMS element or a Twig template override is advisable. This embeds the notice firmly and consistently into the storefront layout, styles it cleanly and protects it against accidental deletion in editing. The same principle applies via the API in headless setups - more on this in our article on the Store API and caching in the headless shop.

{% sw_extends '@Storefront/storefront/page/product-detail/index.html.twig' %}

{# Statutory warranty notice - visible before the order #}
{% block page_product_detail_buy_container %}
    {{ parent() }}

    <div class="product-legal-guarantee" role="note">
        <img src="{{ asset('bundles/theme/assets/eu-warranty-label.svg') }}"
             alt="{{ 'product.legalGuaranteeLabel'|trans }}" width="56" height="56">
        <div class="legal-guarantee-text">
            <strong>{{ 'product.legalGuaranteeTitle'|trans }}</strong>
            <p>{{ 'product.legalGuaranteeText'|trans }}</p>
        </div>
    </div>
{% endblock %}

The texts themselves belong in language snippets rather than hard-coded in the template. This keeps the notice maintainable and multilingual - and the prescribed wording can be updated centrally without touching the theme.

{
  "product": {
    "legalGuaranteeTitle": "Statutory legal guarantee",
    "legalGuaranteeText": "This product is covered by the statutory legal guarantee of at least 2 years. In case of a defect you are entitled to repair or replacement; if that is impossible, to a price reduction or refund.",
    "legalGuaranteeLabel": "EU notice on the statutory legal guarantee"
  }
}

Embedding multilingual content and the EU label correctly

The notice must appear in the language of the market in which the sale takes place (IT-Recht-Kanzlei). Anyone serving DE and EN therefore needs the wording in both languages - cleanly separated via Shopware snippets and tied to the respective sales channel language. The most common source of error here is a wrong or missing language version, which practice texts explicitly name as a warning risk (snafu).

For the harmonised label, Implementing Regulation (EU) 2025/1960 specifies the design but does not provide a ready-made graphic file (IT-Recht-Kanzlei). The label must therefore be created from the official specification and embedded as an asset in the theme - with descriptive alt text, so it is also accessible in the spirit of accessibility legislation. Central maintenance via theme assets and snippets keeps the effort small.

In practice it has proven useful to embed the label as a scalable SVG graphic and to keep two variants - one for light and one for dark surfaces - so it appears sharp and high-contrast in any theme context. Anyone running several shops or tenants in one Shopware instance stores the asset once centrally and references it the same way everywhere. That way, when the specification is adjusted later, only one file needs swapping and all sales channels follow automatically. This separation of content (snippet), presentation (theme) and graphic (asset) is the core of a low-maintenance, audit-proof implementation.

Warning-letter risk: what failures can cost

Missing, insufficient or poorly visible mandatory information is a classic ground for warning letters - by competitors and consumer protection associations alike (Haendlerbund). The figures underline how real the risk is: according to the Haendlerbund Abmahnstudie 2025, 18% (Haendlerbund Abmahnstudie 2025) of surveyed online traders received at least one warning in 2024 - a clear increase over 12% (Haendlerbund Abmahnstudie 2025) the previous year.

Competition law is seen as the biggest perceived warning risk at 42% (Haendlerbund Abmahnstudie 2025), followed by packaging law at 40% (Haendlerbund Abmahnstudie 2025). At the same time, 27% (Haendlerbund Abmahnstudie 2025) of traders perceive an increasing frequency of warnings. A new information obligation such as the warranty notice fits exactly into this competition-law environment - and tends to become a target of test purchases quickly.

On top of that, a warning letter ties up far more than just the amount demanded. It costs time for internal discussion, legal review and short-notice technical corrections - often under time pressure and with the risk of contractual penalties on repetition. It is telling that, according to the Haendlerbund study, 41% (Haendlerbund Abmahnstudie 2025) of respondents initially did not react to a warning they received, while only 17% (Haendlerbund Abmahnstudie 2025) paid the amount demanded. This shows how much uncertainty the topic causes - and how much calmer it is to work with a clean implementation from the start.

A conversion opportunity, not just a duty

A well-designed warranty notice is more than a tiresome requirement. It answers a question many customers ask anyway: what happens if something breaks? Clearly worded rights to repair, replacement and refund reduce perceived buying uncertainty - exactly where the decision is made. A transparent notice can thus strengthen trust, much like honest reviews or a fair checkout without dark patterns.

This shifts the perspective: the duty for 27 September 2026 is at the same time an opportunity to make service quality visible. Combined with good product data, clear shipping and return information and a well-thought-out product page, a coherent trust signal emerges. As part of our Shopware development we implement this so that a legal requirement becomes a consistent building block of the customer experience.

The wording of the notice should stay understandable. Instead of legalese, concise, clear language that makes the three core rights - repair, replacement and refund - tangible helps. This removes uncertainty from the buying decision without sacrificing legal accuracy. In addition, the notice can be designed discreetly: a calm icon, the EU label and one or two sentences are enough. That way it works as a service promise rather than a warning sign. Combining this with a regular review of the product pages keeps compliance stable over time - even when new duties are added or the prescribed text changes later.

Finally, the notice contributes to the bigger picture: the EmpCo Directive aims to encourage consumers towards more durable, repairable products. A shop that communicates the warranty openly signals confidence in its own goods - and positions itself credibly in the context of sustainability and repairability. The mandatory detail thus becomes a small but effective part of brand communication.

• Notice visible on the product page before order completion
• Standardized text and EU label embedded to spec
• Bilingual maintenance via snippets (DE/EN)
• Centrally in the product page layout instead of per product
• Displayed responsively and accessibly
• Tested and documented before 27 September 2026

It is important not to treat the notice as an isolated island. It unfolds its effect in interplay with the other mandatory details and trust elements of a product page - from the correct unit price through shipping and delivery information to the cancellation policy. A well-thought-out information architecture ensures that all these building blocks do not compete with each other but keep the page calm and clear. That is exactly part of a good Shopware setup: legally complete and yet tidy.