Warranty Notice Obligation: Shopware Setup

With the date of application on 27 September 2026, an online shop selling goods to consumers has to show the official harmonized notice on the legal guarantee in a prominent manner – unchanged, in the language of the market and before the order. In Shopware, a large part of this has been a core feature since version 6.7.14: a setting, a link in the checkout, the notice in 24 official EU languages and the GARAN label for manufacturer guarantees. This guide shows what the law requires, what Shopware already covers and which additions to the theme, mail template and product data make sense. For e-commerce with Shopware it is mainly a matter of clean configuration and thorough testing.

What exactly is required

The basis is the EmpCo Directive (EU) 2024/825, which amends the Consumer Rights Directive 2011/83/EU (Official Journal of the EU). The design is laid down in Implementing Regulation (EU) 2025/1960: Annex I contains the harmonized notice on the legal guarantee, Annex II the harmonized label for the commercial guarantee of durability, known as the GARAN label. Germany transposed the rules with the Act of 3 February 2026 (BGBl. 2026 I No. 28) in Art. 246a § 1 (1) sentence 1 EGBGB. Under No. 11, the trader has to inform about the existence of the legal guarantee of conformity for goods and its main elements, including its minimum duration of two years, in a prominent manner using the harmonized notice. How the notice and the label differ is explained in our article on the warranty and guarantee label.

The date of application for the EGBGB amendments and the change to § 312j BGB is 27 September 2026 (BGBl. 2026 I No. 28). The obligation concerns distance sales of goods to consumers; what counts is the consumer sale, not the size of the business. For digital content and digital services, No. 11b only requires a simple reminder of the existence of the legal guarantee – the harmonized notice is not prescribed there. A checklist for adapting your shop is included in our article on the EU warranty label.

Where the notice should be visible in the shop

The law does not prescribe a fixed place, but it does require two things: the information has to be available in a prominent manner and before the consumer places the order. For online shops, the European Commission guidelines give examples of a general reminder on the website: a sentence such as Your legal guarantee rights on the product catalog page, in the website header or on the checkout page, showing the full notice on the first mouse click or roll-over (European Commission). The notice should also be included in the confirmation email.

Since version 6.7.14, Shopware covers one of these places: the checkout, next to the terms checkbox. For shops with long product pages and many mobile purchases, we recommend showing the general reminder near the buy box as well – where the purchase decision is made. An inconspicuous link in the footer alone is hard to justify as prominent. Doing this properly builds trust right at the most important moment of the customer journey – much like the trust signals in your shop.

On a smartphone, visible space is tight. The top bar of the default theme is hidden on small screens, so it only works as a place for the reminder on desktop. A line directly below the buy box that opens the full notice in a dialog is the better choice: the page stays calm, and the official version is one step away. This form follows the Commission examples, where the full notice appears on the first click.

In a digital environment, the harmonised notice should be displayed in a prominent manner, for example placed as a general reminder on the website of the seller.

European Commission, practical guidelines on the harmonised notice and label

Scope, exemptions and special cases

Before getting to the technical side, it is worth looking at the scope. It covers the sale of goods to consumers; pure B2B shops are generally not affected as long as they sell exclusively to business customers (Shopware). Shops selling to both consumers and business customers control the display in Shopware via the setting per sales channel.

• Goods sold to consumers: harmonized notice in a prominent manner (No. 11), online in color and in the language of the market.
• Second-hand goods: the notice obligation applies here too. Whether and how an agreed shorter limitation period should be explained next to the unchanged notice should be checked with legal advice.
• Digital content and digital services: a simple reminder of the legal guarantee (No. 11b), without the harmonized notice.
• Manufacturer guarantee of more than two years: additionally the GARAN label where the conditions of No. 11a are met; under § 312j (2) BGB this information also belongs immediately before the order.
• Pure B2B shops: generally not covered; in mixed shops the obligation applies to sales to consumers.

With mixed product ranges and several sales channels, the advantage of the core feature shows: the setting can be overridden per sales channel, so a B2C and a B2B channel in one Shopware instance can behave differently. Your own reminder below the buy box should query the same setting so that both places are switched on and off together.

Step-by-step setup in Shopware

Since Shopware 6.7.14, the core includes both markings, in every plan including the Community Edition; Shopware has also announced the features for Shopware 6.6 (Shopware). The notice is available in the official design in all 24 official EU languages. Shopware picks the version matching the storefront language; for other languages the English version is used. We usually set it up in four steps.

1. Update and setting: Update the shop to 6.7.14 or later and enable the notice under Settings > Cart settings > Checkout (key core.cart.showLegalGuaranteeNotice), with a different value per sales channel if needed.
2. Check the checkout: A link to the legal guarantee rights appears next to the terms checkbox. It opens the full notice in a dialog, which links on to the EU information page in the matching language.
3. Maintain GARAN data: Only for products with a manufacturer guarantee of more than two years, set the duration in months in the Guarantee (GARAN label) card (from 30, in six-month steps) and enable showing the label in the storefront. Manufacturer and manufacturer product number have to be maintained, otherwise the label does not appear.
4. Test theme and mail: Go through product page, cart, order completion and order confirmation on a staging environment on desktop and mobile – especially with a custom theme or a customized mail template.

Shopware does not assess whether the placement in an individual storefront is prominent enough, nor does it decide whether a product meets the GARAN conditions (Shopware). For a general reminder below the buy box, a lean Twig template override is enough; it uses the core filters and brings no wording of its own. In headless setups, the Store API delivers the notice via its own endpoint – more on how this works together in our article on the Store API and caching in headless shops.

{% sw_extends '@Storefront/storefront/component/buy-widget/buy-widget.html.twig' %}

{# Allgemeiner Hinweis unter dem Kaufbereich: öffnet die amtliche Mitteilung beim ersten Klick #}
{% block buy_widget %}
    {{ parent() }}

    {% if config('core.cart.showLegalGuaranteeNotice') %}
        {% set noticeId = 'legalGuaranteeNotice' ~ (elementId ?? '') %}
        <p class="product-legal-guarantee-reminder">
            <button type="button" class="btn btn-link-inline" aria-haspopup="dialog"
                    data-bs-toggle="modal" data-bs-target="#{{ noticeId }}">
                {{ 'legalGuarantee.reminder'|trans|striptags }}
            </button>
        </p>
        <div class="modal modal-lg fade" id="{{ noticeId }}" tabindex="-1" role="dialog"
             aria-modal="true" aria-hidden="true" aria-labelledby="{{ noticeId }}-title">
            <div class="modal-dialog modal-dialog-centered">
                <div class="modal-content">
                    <div class="modal-header">
                        <div id="{{ noticeId }}-title" class="modal-title h5">{{ 'legalGuarantee.reminder'|trans|striptags }}</div>
                        <button type="button" class="btn-close" data-bs-dismiss="modal"
                                aria-label="{{ 'global.default.close'|trans|striptags }}"></button>
                    </div>
                    <div class="modal-body">
                        <a href="{{ context.languageId|sw_legal_guarantee_notice_link }}" target="_blank" rel="noopener">
                            {{ context.languageId|sw_legal_guarantee_notice }}
                        </a>
                    </div>
                </div>
            </div>
        </div>
    {% endif %}
{% endblock %}

The snippet legalGuarantee.reminder in the theme snippet file only holds the link text, for example Your legal guarantee rights, never the content of the notice. The core supplies that in the language of the sales channel. This keeps the reminder maintainable and multilingual without creating a second version of the notice in the theme. Shopware only updates the order confirmation if the mail template is still unmodified; if you have customized it, add the two new expressions yourself (Shopware).

{# In der Schleife über die Bestellpositionen (Variable nestedItem wie in der Standardvorlage) #}
{% set garanLabel = nestedItem.productId|sw_garan_label_nested_uri(context) %}
{% if garanLabel %}<img src="{{ garanLabel }}" alt="GARAN label of the manufacturer guarantee">{% endif %}

{# Einmal in der Mail: Verweis auf die gesetzlichen Gewährleistungsrechte #}
<a href="{{ context.languageId|sw_legal_guarantee_notice_link }}">Your legal guarantee rights</a>

Multilingual shops and official graphic files

The notice has to appear in the language of the market. Shopware provides it in all 24 official EU languages and picks the version according to the storefront language; for languages outside these 24, the English version is used. If you offer a language that is not an official EU language, or have created your own language variants, check which version actually appears there.

For shops without 6.7.14, the European Commission provides the notice as graphic files in all EU languages, in color for physical shops and e-commerce and in black and white for physical shops only (European Commission). These files belong in the shop unchanged: no HTML rebuild, no recoloring to match the theme, no shortened version. A descriptive alt text and a link to the EU information page in the same language keep the notice accessible, also in terms of digital accessibility.

Even in dark themes, the notice stays in the official color version; a light surface or a dialog with a light background around the graphic is the clean solution. If you run several shops or clients in one instance, store the files once per language in a central place and reference them the same way everywhere. The separation stays clear: wording and design come from the EU or the core, placement and link text from the theme.

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 (Händlerbund). The figures underline how real the risk is: according to the Händlerbund Abmahnstudie 2025, 18% (Händlerbund Abmahnstudie 2025) of surveyed online traders received at least one warning in 2024 – a clear increase over 12% (Händlerbund Abmahnstudie 2025) the previous year.

Competition law is seen as the biggest perceived warning risk at 42% (Händlerbund Abmahnstudie 2025), followed by packaging law at 40% (Händlerbund Abmahnstudie 2025). At the same time, 27% (Händlerbund 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 is easy to check in a test purchase.

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 Händlerbund study, 41% (Händlerbund Abmahnstudie 2025) of respondents initially did not react to a warning they received, while only 17% (Händlerbund 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-placed legal guarantee notice is more than an annoying requirement. It answers a question many customers ask anyway: What happens if something breaks? The official notice names the minimum duration of two years and links to the EU information page – right where the decision is made. Like honest reviews or a fair checkout without dark patterns, a transparent notice can strengthen trust.

This shifts the perspective: the new information obligation is also an opportunity to make service quality visible. Combined with good product data, clear shipping and returns information and a well-designed product page, it forms a consistent trust signal. As part of our Shopware development, we implement it so that a legal requirement becomes a consistent building block of the customer experience.

There is design freedom only around the notice, not within it. Link text, position, a calm icon and the way the dialog opens can be adapted to the theme; text, colors and structure of the notice cannot. Combining this with a regular review of product pages keeps compliance stable – even when new obligations are added or the Commission updates its files.

Last but not least, the notice contributes to the bigger picture: the EmpCo Directive aims to encourage consumers to choose more durable, repairable products. Where producers give a commercial guarantee of durability of more than two years, the GARAN label makes this advantage visible right at the product. A shop that communicates legal guarantee and commercial guarantee openly positions itself credibly around sustainability and repairability.

• Shopware 6.7.14 or later, notice setting checked per sales channel
• Official notice unchanged, online in color and in the language of the market
• General reminder near the buy box, visible on mobile too
• GARAN data only where the conditions are met, manufacturer and manufacturer product number maintained
• Order confirmation tested with legal guarantee reminder and GARAN label
• Own theme and customized templates checked after every update

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.