Since 27 September 2026, traders selling goods to consumers in the EU have had to use the official legal guarantee notice to remind them of the legal guarantee of conformity of at least two years. The obligation comes from Directive (EU) 2024/825, the graphic from Implementing Regulation (EU) 2025/1960. The GARAN label is only added for certain producer guarantees.
Here you will find 53 answers to the questions traders ask most often about the EU legal guarantee notice (officially the harmonised notice, also called the EU warranty label) and the GARAN label. Each answer starts with the result and names the legal reference. At the end there is a link to the page that covers the topic in depth.
Where the legal situation is open, we say so. Terms are explained in the glossary.
Obligation and deadlines
The EU legal guarantee notice has been mandatory since 27 September 2026. Here are the basics: what the notice is, where the obligation comes from and how Member States have implemented it.
What is the EU legal guarantee notice?
The legal guarantee notice is an official EU graphic that reminds consumers of their legal guarantee of conformity of at least two years. Its official name is the “harmonised notice on the legal guarantee of conformity”; it is sometimes also called the EU warranty label. Traders selling goods to consumers have had to show it in a prominent manner since 27 September 2026. Its design and content are laid down in Annex I of Implementing Regulation (EU) 2025/1960.
What is the harmonised notice on the legal guarantee of conformity?
The harmonised notice is the official name of the legal guarantee notice. It sums up the main elements of the legal guarantee of conformity, including its minimum duration of two years and a reference to the possibility that national law provides for a longer period (Art. 22a(3) Consumer Rights Directive). The graphic has the same layout in all 24 official languages and must not be changed.
Since when has the legal guarantee notice applied?
The legal guarantee notice has been mandatory since 27 September 2026. From that day, Member States had to apply their measures transposing Directive (EU) 2024/825 (Art. 4(1) of the directive), and Implementing Regulation (EU) 2025/1960 became applicable (Art. 3).
Which regulation governs the legal guarantee notice?
Commission Implementing Regulation (EU) 2025/1960 of 25 September 2025 governs its design and content. Annex I contains the legal guarantee notice, Annex II the GARAN label. The obligation to show the graphic, on the other hand, comes from Directive (EU) 2024/825, which amended the Consumer Rights Directive. The regulation has applied since 27 September 2026 (Art. 3).
What does the EmpCo Directive have to do with the legal guarantee notice?
The EmpCo Directive (EU) 2024/825 creates the obligation to show the legal guarantee notice. It added new information requirements to the Consumer Rights Directive (Art. 5, 6, 8 and 22a) and tasked the Commission with designing the notice and the label uniformly. Its other part amends the Unfair Commercial Practices Directive, above all with regard to environmental claims and durability claims.
How have Member States implemented the obligation?
Each Member State had to transpose Directive (EU) 2024/825 into national law by 27 March 2026 and apply it from 27 September 2026. The EU basis is the same everywhere: Art. 5(1)(e) of the Consumer Rights Directive for in-store sales and Art. 6(1)(l) for distance selling, Art. 5(1)(ea) and 6(1)(la) for the GARAN label, and Art. 8(2) for the GARAN information directly before the order. Where these provisions sit in national law differs; Germany, for example, placed them in Art. 246 and 246a EGBGB and § 312j BGB.
Is the legal guarantee notice related to the withdrawal button?
No, not in substance. The legal guarantee notice informs consumers about their legal rights if goods are faulty. It is based on Directive (EU) 2024/825 and Implementing Regulation (EU) 2025/1960 and has nothing to do with the right of withdrawal. The two topics often appear side by side in checklists. This website does not cover the withdrawal button.
What new obligations apply to online shops in 2026?
Since 27 September 2026, online traders must show the harmonised legal guarantee notice and, if the producer offers and communicates a qualifying commercial guarantee of durability, the GARAN label. For the GARAN label, Art. 8(2) of the Consumer Rights Directive also applies: the information belongs directly before the order. The amendments to the Unfair Commercial Practices Directive, which mainly concern environmental claims and durability claims, have applied since the same day.
Who is affected
Every trader who sells goods to consumers is affected. The borderline cases concern B2B, private sales, digital products and physical shops.
Who has to show the legal guarantee notice?
Every trader who sells goods to consumers has to show the legal guarantee notice, online and in physical shops. The obligation lies with the trader as seller, not with the producer; for the notice, the Commission’s guidelines only provide a role for sellers. Sales between businesses and between private individuals are not covered.
Does the legal guarantee notice also apply to small businesses?
Yes, according to the wording of the rules. The obligation applies whenever a trader sells goods to consumers. The Consumer Rights Directive contains no exemption based on size or turnover. Member States may exempt day-to-day transactions in physical shops that are performed immediately (Art. 5(3) Consumer Rights Directive); in distance selling, only regular delivery rounds of goods for current consumption in the household and automatic vending machines are excluded (Art. 3(3)(j) and (l)). So a small online shop must show the notice too.
Does the legal guarantee notice apply in B2B sales?
No. The obligations are set out in the Consumer Rights Directive and only apply to contracts between traders and consumers. If you sell exclusively to businesses, you do not have to show the notice. As soon as consumers can also buy from you, the obligation applies to those sales. How a pure B2B shop effectively excludes consumers is not governed by the rules analysed here.
Do I need the notice for second-hand goods?
Yes. Second-hand goods are goods, and the notice reminds consumers of a right that applies to all goods (recital 28 Directive 2024/825). The official graphic itself covers second-hand goods: a shorter period may apply, “but not less than one year”. Under the Sale of Goods Directive, Member States may allow seller and consumer to agree on such a shorter period (Art. 10(6) Directive (EU) 2019/771).
Does the legal guarantee notice apply to food?
The rules contain no specific exemption for food; the obligation refers to “goods”. In distance selling, the Consumer Rights Directive excludes the supply of foodstuffs, beverages or other goods for current consumption in the household delivered on frequent and regular rounds (Art. 3(3)(j)) and contracts concluded by automatic vending machines (Art. 3(3)(l)). For physical shops, Member States may exempt day-to-day transactions performed immediately (Art. 5(3)); how far this goes is unclear. For online shops selling food, the wording points towards showing the notice; this has not yet been clarified.
Do I need the notice for digital products, vouchers or services?
For digital content and digital services, the harmonised notice is not required. A reminder of the existence of the legal guarantee of conformity is enough (Art. 6(1)(lb) Consumer Rights Directive). Goods with digital elements, by contrast, are goods and need the notice. The harmonised notice refers expressly to goods. The sources do not explicitly address vouchers.
Does the obligation also apply in physical shops?
Yes. For contracts in physical shops, Art. 5(1)(e) of the Consumer Rights Directive applies. In print, the notice must be at least A4, in colour or black and white (Annex I, note 4, Regulation 2025/1960). Member States may exempt day-to-day transactions that are performed immediately (Art. 5(3) Consumer Rights Directive). How far this goes is unclear, because the Commission speaks of displaying the notice in all shops, online and offline.
Does the legal guarantee notice apply in all EU countries and in Switzerland?
In all EU Member States, yes, for example in Austria, because Directive (EU) 2024/825 binds every Member State: transposition by 27 March 2026, application from 27 September 2026. This website does not cover the individual national transposing rules in detail. Switzerland is not an EU member, so the directive does not apply there. Whether Swiss shops selling to consumers in the EU must show the notice depends on the applicable law and is not settled here.
Do private sellers (classified ads, Vinted) have to show the notice?
No. Sales between private individuals are not covered by the Consumer Rights Directive and therefore not by the notice obligation. What matters is whether you act as a trader: if you do, the obligation also applies on classified ad platforms. Where the line between private and commercial selling lies is not governed by the rules analysed here; if in doubt, have it checked.
Content, design and download
The graphic is prescribed by law and must not be changed. Online it must be in colour.
What does the legal guarantee notice say?
Under the heading “Legal guarantee”, it states that goods sold in the EU come with a minimum two-year legal guarantee. The graphic lists typical defects, the remedies (repair, replacement, in some cases a price reduction or reimbursement), longer periods in some countries and a shorter period for second-hand goods, at least one year. It also contains the steps to take, a reference to the GARAN label and a QR code.
Where does the QR code on the notice lead?
The QR code on the legal guarantee notice leads to the dedicated language section on the legal guarantee of conformity on the EU’s Your Europe portal (Annex I, note 3, Regulation 2025/1960); the English version shows the address europa.eu/youreurope/guarantees. The QR code on the GARAN label leads to the page on the commercial guarantee of durability. According to the Commission’s guidelines, online shops should also provide a clickable link to the same destination.
May I change the legal guarantee notice or adapt it to my design?
No. “None of the elements of the harmonised notice can be edited”, says Annex I, note 1 of Regulation 2025/1960. The Commission’s guidelines list as inadmissible: changing the frame, colours, spacing, font or QR code, cropping, stretching or adding elements. Use the Commission’s official files unmodified, without replacing any colours.
Where can I download the legal guarantee notice in English?
The European Commission provides the official files on its page “Practical guidelines and High Resolution Vector files”, in all 24 official languages. On our download page you will find the English version and all other languages with a preview, no sign-up needed. Use the files exactly as the Commission published them.
Which file format (SVG, PNG, PDF) should I use in my online shop?
The regulation does not prescribe a file format. Online, the notice must be in colour in RGB (Annex I, note 5, Regulation 2025/1960) and, according to the guidelines, legible at standard display size. In practice the vector file (SVG) works best because it stays sharp on every screen. PNG or WebP also work if the resolution is high enough. PDF is better suited as an attachment to the order confirmation.
May I use the black-and-white version online?
No. In online distance selling, the legal guarantee notice must appear in colour in RGB (Annex I, note 5, Regulation 2025/1960), and so must the GARAN label (Annex II, note 5). Black and white is only allowed outside online selling, for example on a poster in a physical shop, which must then be at least A4.
Placement in the shop
The law requires a prominent notice before the order, but no fixed place. Stricter rules apply to the GARAN label.
Where must the legal guarantee notice appear in an online shop?
The law does not prescribe a fixed place. The notice must appear “in a prominent manner” before the customer places the order. As an example, the directive mentions a general reminder on the trader’s website (recital 28 Directive 2024/825). The Commission’s guidelines show the catalogue page, the page header and the checkout page as examples.
Is the legal guarantee notice in the footer enough?
That has not been settled. The directive accepts a general reminder on the website as an example, but requires a prominent display. Whether an entry at the very bottom of the footer is “prominent” on its own has not yet been decided by any court. If you also show the notice on the product page or in the cart, the question does not arise.
Does the notice have to be on every product page?
No, the legal text does not require it on every product page. What is required is a prominent notice before the consumer is bound by the contract; as an example, the directive mentions a general reminder on the website. The GARAN label is different: in online sales it belongs directly next to the picture of the good covered by the guarantee (recital 28 Directive 2024/825). On the product page, however, customers are sure to see the notice before buying.
May the notice sit behind a link or a pop-up?
Probably yes, but it has not been finally settled. The Commission’s guidelines show examples where a phrase such as “Your legal guarantee rights” appears and the full notice is shown on the first click or mouse roll-over. At the same time, they say that the full notice should be displayed online. The regulation provides for a nested display only for the GARAN label.
Does the legal guarantee notice have to go into the order confirmation?
Yes, that is the recommended approach. According to the Commission’s guidelines, the notice “should” also be included in the confirmation e-mail (p. 20). Legally, this rests on Art. 8(7) of the Consumer Rights Directive: the confirmation of the contract on a durable medium includes the pre-contractual information, unless the trader has already provided it to the consumer on a durable medium (Art. 8(7)(a)). The guidelines also mention the confirmation e-mail for the GARAN label.
Does the notice have to be sent as an e-mail attachment?
That is not regulated. The guidelines only say that the notice should be included in the confirmation e-mail; neither the regulation nor the guidelines specify whether as an embedded image or an attachment. What matters is that it arrives complete, in colour and legible. Some e-mail programs only load images after approval, while a PDF attachment stays with the customer. Combining both is a pragmatic solution.
How big must the legal guarantee notice be in the shop?
For online shops there is no minimum size in pixels. The guidelines require the notice to be legible at standard display size, without cropping or distortion. In print, by contrast, the minimum is A4 for the legal guarantee notice and 95 × 100 mm for the GARAN label (Annex I, note 4, Annex II, note 3, Regulation 2025/1960). According to the guidelines, the QR code on the GARAN label should never be smaller than 2 × 2 cm.
In which language must the notice appear if I sell to several countries?
The regulation does not set a language, and the question is not expressly regulated. The obvious choice is the language in which you offer the contract: a French-language shop shows the French version. The Commission provides the notice in all 24 official languages. The GARAN label is language-neutral and contains one line in all official languages.
GARAN label
The GARAN label marks a particular kind of producer guarantee. It is only mandatory when five conditions are met together.
What is the GARAN label?
The GARAN label is the official EU label for a producer’s commercial guarantee of durability. It shows the guarantee duration in years, the producer’s name, the model identifier and a QR code. Its official name is the “harmonised label for the commercial guarantee of durability”; its design and content are governed by Annex II of Implementing Regulation (EU) 2025/1960.
When is the GARAN label mandatory?
The GARAN label is mandatory when five conditions are met together: the producer offers a commercial guarantee of durability, it comes at no additional cost, it covers the entire good, it lasts more than two years, and the producer makes the information available to the trader (Art. 6(1)(la) Consumer Rights Directive). According to the guidelines, the label must not be used for other guarantees.
Do I need a GARAN label for a producer guarantee of exactly two years?
No. The guarantee must last more than two years (recital 30 Directive 2024/825); exactly two years is not enough. The legal guarantee notice is still needed for these goods, because it applies to all goods. The Commission’s guidelines allow whole and half years on the label, so a guarantee of two and a half years would already qualify.
Do I need a GARAN label for a paid extended warranty?
No. The GARAN label only applies to a producer’s commercial guarantee of durability that runs for more than two years at no additional cost and covers the entire good (Art. 6(1)(la) Directive 2011/83/EU as amended by Directive (EU) 2024/825). For a guarantee the customer pays extra for, you continue to provide information on its existence and conditions. It must not be confusable with the GARAN label (recital 32 Directive (EU) 2024/825).
The producer only gives more than two years on one component. Do I need the GARAN label?
No. The guarantee must cover the entire good, not just the motor, for example (Art. 6(1)(la) Directive 2011/83/EU as amended by Directive (EU) 2024/825). State a guarantee on parts with its conditions, without a GARAN label. The legal guarantee notice is still needed, as it applies to all goods.
Who creates the GARAN label, the producer or the trader?
The regulation does not say who fills in the fields. The Commission’s guidelines take the view that they must be edited by the producer (“must be edited by the producer”). Whether a trader may fill in a label with the producer’s details is unclear; the legal text does not prohibit it. In any case, the trader must show the label as soon as the producer provides the guarantee information.
Which details may I change on the GARAN label?
Only three fields can be edited: the guarantee duration in years (instead of “XX”), the name of the producer offering the guarantee and the model identifier (Annex II, note 1, Regulation 2025/1960). The title “GARAN”, the shield logo, the QR code, the calendar symbol and the multilingual line “producer guarantee in years” remain unchanged. The font Inter is mandatory, including in the editable fields.
Do I have to show the GARAN label if I don’t advertise the guarantee?
Yes. The obligation does not depend on advertising, but on the producer offering such a commercial guarantee of durability and making the information available to you. If both apply, the GARAN label belongs with the product, even if you do not mention the guarantee anywhere else. You do not have to actively search for it, for example on producers’ websites (recital 26 Directive 2024/825).
May the GARAN label appear in the cart or at checkout?
Yes, that is in fact where it belongs. Under Art. 8(2) of the Consumer Rights Directive, the GARAN information must appear clearly and prominently, directly before the consumer places the order. The Commission’s guidelines mention the checkout page directly before the order and the confirmation e-mail. In addition, the label belongs directly next to the picture of the good on the product page (recital 28 Directive 2024/825).
What is a commercial guarantee of durability?
A commercial guarantee of durability is a voluntary commitment by the producer to be directly liable to the consumer for repair or replacement of the goods during the entire guarantee period (Art. 2(14a) Consumer Rights Directive; Art. 17(1) Directive (EU) 2019/771). Durability means the ability of the goods to maintain their required functions and performance through normal use (Art. 2(13) Sale of Goods Directive).
What is the difference between the legal guarantee notice and the GARAN label?
The legal guarantee notice is a reminder of the legal guarantee of conformity and is mandatory whenever goods are sold to consumers. The GARAN label marks a voluntary additional commitment by the producer and is only needed if the producer’s commercial guarantee of durability covers the entire good at no additional cost for more than two years. The regulation calls the legal guarantee and the commercial guarantee of durability “two independent types of guarantees” (recital 2 Regulation 2025/1960).
Legal guarantee and commercial guarantee
The legal guarantee is the law; a commercial guarantee is a voluntary promise. The two labels reflect exactly this difference.
What is the difference between a commercial guarantee and the legal guarantee?
The legal guarantee of conformity is a statutory right against the seller for defects that already existed at delivery; it lasts at least two years and costs nothing. A commercial guarantee is a voluntary promise by the seller, the producer or a third party, whose content is set by the guarantee statement. A commercial guarantee does not affect the legal rights; the guarantee statement must say so expressly (Art. 17(2)(a) Directive (EU) 2019/771).
How long does the legal guarantee last?
Under the Sale of Goods Directive, the seller is liable for any lack of conformity that exists at delivery and becomes apparent within two years of delivery (Art. 10(1) Directive (EU) 2019/771). Member States may keep or introduce longer periods (Art. 10(3)). For second-hand goods, they may allow seller and consumer to agree on a shorter period of at least one year (Art. 10(6)). If a lack of conformity becomes apparent within one year of delivery, it is presumed to have existed at delivery (Art. 11(1)); Member States may extend this to two years (Art. 11(2)). In Germany, for example, the period for movable goods is two years from delivery, and five years for building materials used in a building that caused its defect.
Enforcement and penalties
Enforcement is a matter for national law. There is no case law on this obligation yet.
What can happen if the legal guarantee notice is missing?
A missing notice can be challenged. Member States must ensure adequate and effective means of enforcement, including action by public bodies, consumer organisations and professional organisations (Art. 23 Consumer Rights Directive). In some countries competitors can also take action; in Germany, for example, through cease-and-desist letters (Abmahnung) under the Unfair Competition Act. There is no case law on the legal guarantee notice yet, and whether and when enforcement actions will become frequent is open.
Abmahnung und Bußgeld (in German)
Is there a fine for a missing legal guarantee notice?
The penalties are set by each Member State and must be effective, proportionate and dissuasive (Art. 24(1) Consumer Rights Directive). Where penalties are imposed in a coordinated enforcement action under Regulation (EU) 2017/2394, the maximum fine must be at least 4% of the trader’s annual turnover in the Member States concerned, or at least EUR 2 million where turnover information is not available (Art. 24(3) and (4)). Example Germany: Art. 246e EGBGB covers missing mandatory information only for widespread infringements in such a coordinated action, with fines of up to EUR 50,000, or up to 4% of annual turnover for traders with more than EUR 1.25 million; the Federal Office of Justice is responsible.
Fines in detail (in German)
My notice has been missing since 27 September. What now?
Add the notice as soon as possible: prominently in your shop and ideally also in the order confirmation. Also check whether producers have told you about commercial guarantees of durability that require a GARAN label. There is no case law yet, and how authorities, competitors and associations will act is open. If you receive a warning letter or a notice from an authority, have it checked by a lawyer before you sign anything.
Shopify and other shop systems
In Shopify, you can add the notice with an app or by hand. The legal requirements are the same in every shop system.
How do I add the legal guarantee notice to Shopify?
The easiest way is an app that embeds the official graphic; without an app, you add the file as an image to your theme and edit the order confirmation by hand. The app EU-Gewährleistungslabel, GARAN shows the original graphic unmodified on the product page, the collection page, in the cart, in the cart drawer and in the footer, automatically or by drag and drop in the theme editor.
Is there a Shopify app for the legal guarantee notice?
Yes, several. Our app EU-Gewährleistungslabel, GARAN by MMR Labs GmbH shows the official graphics of the European Commission unmodified in all 24 official languages, matching the store language. It also sets the GARAN label per producer and product and provides a block that adds the graphic with a PDF download to the order confirmation. Plans start at $4.99 a month, with a 7-day free trial.
How do I get the notice into the Shopify order confirmation?
You edit the order confirmation in Shopify under Settings, Notifications; there you can add the graphic to the template as an image. The app EU-Gewährleistungslabel, GARAN does this for you: its block adds the graphic and a download button for the official PDF to the order confirmation, plus the commercial guarantee statement. This way customers also receive the information after the purchase.
How do I show the GARAN label only on certain Shopify products?
The GARAN label may only appear on products that actually have such a producer guarantee; where several products are shown, it must not give the impression that all of them are covered (guidelines, section 3.4). In the app EU-Gewährleistungslabel, GARAN, you set up the label per producer and product and fill in only the three permitted fields: duration, producer name and model identifier.
How do I add the notice in WooCommerce, Shopware or JTL?
The legal requirements are the same in every shop system: the official graphic, unmodified, in colour, prominent before the order and ideally also in the order confirmation. How you add the file depends on the system and theme, usually via an image or HTML element in the template and the e-mail template. For WooCommerce, Shopware, Wix, Webflow, JTL-Shop, Gambio and more, there is our free widget with instructions for each system.
Do I have to add the notice myself on eBay, Etsy or Amazon?
The obligation lies with the trader who sells, including traders on a marketplace. Some platforms offer their own solutions. Check whether their display meets the requirements: the official graphic, unmodified, in colour, prominent before the order. For GARAN products, the information must appear directly before the order. eBay, Etsy and Kaufland now show the legal guarantee notice themselves and build the GARAN label from your details on brand, model and guarantee duration. What exactly applies is explained on our pages on Amazon, eBay, Etsy and Kaufland.
These answers summarise the legal situation under Directive (EU) 2024/825, Implementing Regulation (EU) 2025/1960 and Directive (EU) 2019/771 as of 7 October 2026. National transposing laws may differ in detail; references to German law are examples only. The answers are not legal advice. The Commission’s guidelines are not binding; only the Court of Justice of the EU can give a binding interpretation.