The legal guarantee notice is based on Directive (EU) 2024/825, which inserted new obligations into the Consumer Rights Directive 2011/83/EU (Articles 5, 6, 8 and 22a). Its design and content are laid down in Implementing Regulation (EU) 2025/1960. The obligation has applied since 27 September 2026 through the national law of each Member State; the regulation applies directly.
To understand why an online shop has had to show a specific graphic since autumn 2026, you do not need to know every legal act in detail. It is enough to know the chain: who creates the obligation, who decides what the graphic looks like, who turns it into national law, and who enforces it. This page sorts the sources and links to the official texts.
Which laws govern the EU legal guarantee notice?
The legal guarantee notice (officially the “harmonised notice on the legal guarantee of conformity”) and the GARAN label (officially the “harmonised label for the commercial guarantee of durability”) rest on five levels that build on each other.
- Directive (EU) 2024/825 (“EmpCo Directive”)
The directive of 28 February 2024 amends the Consumer Rights Directive 2011/83/EU and the Unfair Commercial Practices Directive 2005/29/EC. This is where the obligation originates. More on the page EmpCo Directive explained. - Consumer Rights Directive 2011/83/EU, Articles 5, 6, 8 and 22a
This is where the obligations are worded: Art. 5(1)(e) and (ea) for in-store sales, Art. 6(1)(l) and (la) for distance selling and online shops, Art. 8(2) for showing the GARAN information directly before the order, and Art. 22a for the requirement to use a harmonised notice and a harmonised label. - Implementing Regulation (EU) 2025/1960
The Commission regulation of 25 September 2025 sets out what the notice (Annex I) and the GARAN label (Annex II) look like and what can be edited. It applies directly in every Member State. For a plain-English guide, see Regulation 2025/1960 explained. - National transposition in each Member State
Member States had to adopt and publish their transposing measures by 27 March 2026 and apply them from 27 September 2026 (Art. 4(1) Directive (EU) 2024/825). The exact provisions differ from country to country. Example Germany: the Act of 3 February 2026 (BGBl. 2026 I No. 28) amended Art. 246 and 246a of the Introductory Act to the Civil Code (EGBGB) and § 312j of the Civil Code (BGB). - Enforcement under national law
Member States must ensure adequate and effective means to enforce the rules, including action by public bodies, consumer organisations and professional organisations (Art. 23 Consumer Rights Directive), and lay down effective, proportionate and dissuasive penalties (Art. 24). Where penalties are imposed in a coordinated 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. Example Germany: competitors and associations can also demand an injunction under the Unfair Competition Act (UWG); details on our page Abmahnung und Bußgeld (in German).
In short: the directive creates the obligation, the regulation fixes the graphics, and national law in each Member State makes both binding on traders.
Which legal act governs what?
Each act has a clearly defined job. The table shows where to look up which question.
| Question | Where to look |
|---|---|
| Who must show the notice, and by when? | Art. 5(1)(e), Art. 6(1)(l) Consumer Rights Directive |
| When is the GARAN label mandatory? | Art. 5(1)(ea), Art. 6(1)(la) Consumer Rights Directive |
| Must the GARAN label appear directly before the order button? | Art. 8(2) Consumer Rights Directive |
| What do the notice and the label look like, and what may be changed? | Art. 1 and 2 with Annexes I and II, Regulation 2025/1960 |
| What applies to digital content and digital services? | Art. 5(1)(eb), Art. 6(1)(lb) Consumer Rights Directive |
| What does the legal guarantee of conformity itself cover? | Sale of Goods Directive (EU) 2019/771, in particular Art. 10 (liability period) and Art. 13 (remedies) |
| What must a commercial guarantee statement contain? | Art. 17(2) Sale of Goods Directive |
| What happens in case of infringements? | Art. 23 and 24 Consumer Rights Directive and national law |
Each Member State implements these points in its own law. In Germany, for example, they are found in Art. 246 and 246a EGBGB and § 312j BGB, the legal guarantee in §§ 434 ff. BGB and the guarantee statement in § 479 BGB.
The obligations themselves are explained in our guide to the legal guarantee notice, the conditions for the producer’s guarantee on the GARAN label page. For the difference between the two, see legal guarantee vs commercial guarantee.
Since when does the obligation apply? The timeline
The obligation has applied since 27 September 2026. On that date the national transposing measures of all Member States and the Implementing Regulation became applicable.
| Date | Event | Reference |
|---|---|---|
| 20 May 2019 | Sale of Goods Directive (EU) 2019/771 adopted (OJ of 22 May 2019) | SGD |
| 1 January 2022 | Sale of Goods Directive applies; transposition deadline 1 July 2021 | Art. 24 SGD |
| 28 February 2024 | Directive (EU) 2024/825 adopted | Directive 2024/825 |
| 6 March 2024 | Published in the Official Journal; entry into force on the 20th day after publication (26 March 2024) | Art. 5 Directive 2024/825 |
| 25 September 2025 | Implementing Regulation (EU) 2025/1960 adopted | Regulation |
| 27 September 2025 | Deadline for the Commission’s implementing acts | Art. 22a(2) and (4) CRD |
| 2 October 2025 | Regulation published in the Official Journal; entry into force on the 20th day after publication (22 October 2025) | Art. 3 Regulation |
| 3 February 2026 | Example Germany: transposition act (BGB/EGBGB), BGBl. 2026 I No. 28 of 5 February 2026 | BGBl. |
| 12 February 2026 | Example Germany: third act amending the Unfair Competition Act (UWG), BGBl. 2026 I No. 43 of 19 February 2026 | BGBl. |
| 19 March 2026 | Commission page with vector files published; guidelines followed in April 2026 | commission.europa.eu |
| 27 March 2026 | Transposition deadline for Member States | Art. 4(1) Directive 2024/825 |
| 27 September 2026 | Application: national transposing measures and Regulation 2025/1960 | Art. 4(1), second subparagraph, Directive 2024/825; Art. 3 Regulation |
| 27 September 2031 | Commission report, including on the effectiveness of the notice and the label | Art. 3 Directive 2024/825 |
The legal acts in detail
We explain two acts on separate pages because they are searched for most often and misunderstood most often.
Implementing Regulation (EU) 2025/1960
Articles 1 to 3, Annex I (notice) and Annex II (GARAN) with all design rules, colours, editable fields and the nested display.
EmpCo Directive (EU) 2024/825
What the directive means for online shops: notice and label obligation, national transposition, affected traders and key dates.
What role do the Commission’s guidelines play?
The Commission’s guidelines of April 2026 help with interpretation, but they are not law. They describe themselves as “preliminary views of the European Commission (EC) services”; only the Court of Justice of the EU can give a binding interpretation (guidelines, p. 2).
They still matter in practice. They show, for example, how the Commission understands the online display: the full notice in colour, legible at standard size, plus a clickable link to the QR code’s destination, and no changes to the graphic. Where the guidelines and the regulation diverge, we point this out on the page on Regulation 2025/1960.
How do I implement the requirements in my Shopify store?
For Shopify stores, the app EU-Gewährleistungslabel, GARAN (EU Warranty and GARAN Label) embeds the Commission’s official graphics unmodified, in all 24 official languages to match the store language: on the product page, the collection page, in the cart, in the cart drawer and in the footer. GARAN labels can be set up per producer and product, and the graphic with a PDF download goes into the order confirmation. For an overview, see legal guarantee notice for Shopify.
Where can I find the official texts?
Everything on this website is based on the official versions published in the Official Journal of the EU and, for the national examples, in the German Federal Law Gazette.
- Directive (EU) 2024/825: EUR-Lex (ELI), full text at the Publications Office
- Implementing Regulation (EU) 2025/1960: EUR-Lex (ELI), full text at the Publications Office
- Sale of Goods Directive (EU) 2019/771: EUR-Lex (ELI), full text
- Example Germany: transposition act, BGBl. 2026 I No. 28: recht.bund.de (PDF, in German)
- Example Germany: third act amending the UWG, BGBl. 2026 I No. 43: recht.bund.de (PDF, in German)
- Commission guidelines and vector files: commission.europa.eu
- Your Europe portal, guarantees: europa.eu
- Your Europe portal, commercial guarantee of durability: europa.eu
This page sorts the legal sources to the best of our knowledge (as of 7 October 2026) and is not legal advice. National transposing laws may differ in detail. For your specific case, please consult a lawyer.
Frequently asked questions
Which regulation governs the EU legal guarantee notice?
Its design and content are governed by Commission Implementing Regulation (EU) 2025/1960 of 25 September 2025. The obligation itself comes from Directive (EU) 2024/825, which amended Articles 5, 6, 8 and 22a of the Consumer Rights Directive 2011/83/EU.
Did Member States have to transpose the obligation into national law?
Yes, for the directive. Member States had to adopt their transposing measures by 27 March 2026 and apply them from 27 September 2026 (Art. 4(1) Directive (EU) 2024/825). The exact provisions differ from country to country. Germany, for example, transposed the obligation by the Act of 3 February 2026 (BGBl. 2026 I No. 28) in Art. 246 and 246a EGBGB and § 312j BGB.
Are the European Commission’s guidelines binding?
No. According to their own statement, the guidelines of April 2026 reflect preliminary views of the Commission services. Only the Court of Justice of the EU can give a binding interpretation. In practice they are still an important point of reference.
Does the Implementing Regulation apply directly, or does it need to be transposed?
The regulation applies directly in every Member State from 27 September 2026 (Art. 3 Regulation 2025/1960). National law can refer to its annexes directly; the German EGBGB, for example, refers expressly to Annexes I and II.