Electronics traders need the legal guarantee notice since 27 September 2026 for every device they sell to consumers, refurbished ones included. The GARAN label is only added for a free producer guarantee of more than two years on the entire device. Paid guarantee plans do not count.
Which labels do traders need for electronics and smartphones?
This covers smartphones, tablets, laptops, TVs, headphones, smartwatches, cameras and games consoles. There are two official EU graphics:
- Legal guarantee notice: always. Since 27 September 2026, every trader who sells goods to consumers must point out the legal guarantee of conformity, online and in physical shops. The graphic is fixed and must not be changed.
- GARAN label: only with a matching producer guarantee. The producer guarantees the entire good for more than two years at no extra cost and makes this information available to you. Then the label appears next to the product and directly before the order.
Typical guarantees for electronics and smartphones: GARAN label or not?
| Guarantee | GARAN label? |
|---|---|
| 3-year producer guarantee on the entire laptop, free of charge | Yes |
| Paid guarantee or protection plan from the producer | No not free of charge |
| Guarantee on the battery only | No not the entire good |
| Refurbisher gives 3 years on the refurbished device | Open depends on whether it counts as the producer |
| Trader gives its own 3 years on all devices | No not from the producer |
| Producer gives exactly 24 months | No not more than two years |
“Open” means: Implementing Regulation (EU) 2025/1960 and the directive do not expressly deal with the case. Legal advice is worthwhile here. The five conditions in detail: When the GARAN label is mandatory.
Software updates: one more piece of information
Smartphones, laptops and TVs are goods with digital elements. The legal guarantee notice applies to them as to any good. In addition, you state the minimum period for which the producer provides software updates, if the producer makes this available to you (Art. 6(1)(lc) and Art. 5(1)(ed) of the Consumer Rights Directive). There is no official graphic for this information. The legal guarantee also includes supplying necessary updates or making sure the customer receives them (Art. 7(3) of the Sale of Goods Directive (EU) 2019/771).
Refurbished and second-hand
Refurbished devices are second-hand goods. They need the legal guarantee notice. The period may be shorter, but not less than one year, and only where national law allows it and seller and consumer agree on it (Art. 10(6) of the Sale of Goods Directive (EU) 2019/771). If a refurbisher gives a guarantee itself, it depends on whether it counts as the producer. That has to be checked case by case.
Paid protection plans
Guarantee and protection plans that customers buy in addition do not trigger the GARAN label, because they are not free of charge. If you offer such plans, you must not give the impression that customers have no rights without them. The legal guarantee always applies and is free of charge, and that is exactly what the legal guarantee notice points out.
Example: GARAN label for a smartphone
The example above shows a GARAN label for a smartphone with a 3-year producer guarantee, created with our generator. “Example Brand” and “PX-12” are made up. Exactly three fields can be changed: years, brand and model identifier. Everything else is fixed by the regulation.
- Get the details from the producer
Guarantee period, brand and model identifier, as the producer gives them to you. - Create the label
Enter your own values in the generator with this example. Free, no sign-up, as SVG and PNG. - Add it to the product
On Shopify, the app does this per product and variant. For other shop systems there is the free widget.
How the labels get into your shop
- Shopify: the app shows the legal guarantee notice in 24 languages and the GARAN label for each product, also in the order confirmation.
- WooCommerce, Shopware, JTL and others: the free widget to embed.
- Marketplaces: what Amazon, eBay, OTTO and others show themselves.
- Check: the free shop check shows whether the labels are found on your product page.
Other industries
- Household appliances
- E-bikes and bicycles
- Furniture and mattresses
- Tools and garden
- Watches and jewellery
- Sports, outdoor and fashion
- Kitchen and cookware
All example labels at a glance: GARAN label examples.
Frequently asked questions
Must I state how long a smartphone gets updates?
Yes, if the producer gives you a minimum period for software updates. There is no official graphic for this; a clear statement next to the product is enough.
Does a paid guarantee plan count for the GARAN label?
No. The GARAN label requires a guarantee at no additional cost.
Do I need the label for refurbished devices?
The legal guarantee notice, yes, because refurbished devices are second-hand goods. A GARAN label only if there is a matching producer guarantee.
Does the label also apply to accessories such as charging cables and cases?
Yes. Accessories are goods. The legal guarantee notice applies to everything you sell to consumers.