Commission Implementing Regulation (EU) 2025/1960 of 25 September 2025 lays down the design and content of the harmonised notice on the legal guarantee of conformity (Annex I) and of the GARAN label (Annex II). It has applied directly in all Member States since 27 September 2026. Nothing on the notice can be edited; on the GARAN label, only the guarantee duration, the producer’s name and the model identifier.
The regulation is short: three articles, two annexes, 17 recitals. What it does not cover matters just as much as what it does. It decides what the graphics look like, not who has to show them, when or where. That is set out in the Consumer Rights Directive and the national laws transposing it; see the overview of the legal basis.
What is Regulation 2025/1960 about?
The regulation governs the design and content of two official graphics. Its full title is: “Commission Implementing Regulation (EU) 2025/1960 of 25 September 2025 on the design and content of the harmonised notice on the legal guarantee of conformity and of the harmonised label for the commercial guarantee of durability”.
- The harmonised notice is the legal guarantee notice, often called the EU warranty label in everyday use. It reminds consumers of the legal guarantee of conformity, which applies to all goods.
- The harmonised label is the GARAN label. It shows a voluntary commercial guarantee of durability of more than two years offered by the producer.
The legal basis is Art. 22a(2) and (4) of the Consumer Rights Directive 2011/83/EU as amended by Directive (EU) 2024/825. Under it, the Commission had to specify the two graphics by implementing act by 27 September 2025. The regulation was published in the Official Journal on 2 October 2025 (OJ L, 2025/1960, CELEX 32025R1960), entered into force on 22 October 2025 and applies from 27 September 2026.
The recitals explain the purpose. The legal guarantee of conformity and the commercial guarantee of durability are “two independent types of guarantees”; the notice is “a mandatory notice at the point of sale”, while the label represents “a voluntary commercial guarantee of durability” (recital 2).
What do Articles 1 to 3 say?
The three articles refer to the annexes and set the dates. The actual content is in Annexes I and II.
| Article | Content | What it means for traders |
|---|---|---|
| Art. 1 | The harmonised notice under Art. 22a(1) CRD complies with the design and content in Annex I. | The legal guarantee notice is the graphic in Annex I, nothing else. |
| Art. 2 | The harmonised label complies with the design and content in Annex II. | The GARAN label is the graphic in Annex II. |
| Art. 3 | Entry into force on the 20th day after publication; applies from 27 September 2026; binding in its entirety and directly applicable in all Member States. | No national transposition needed; applicable since 27 September 2026. |
What does Annex I say about the legal guarantee notice?
Annex I shows the harmonised notice as a graphic and sets five design rules. The most important one: “None of the elements of the harmonised notice can be edited.”
Under Art. 22a(3) CRD, the notice must contain the main elements of the legal guarantee of conformity, its minimum duration of two years and a general reference to the possibility that national law provides for a longer period. Recitals 4 to 6 of the regulation add common situations, the remedies, practical steps, a source of further information and a reference to additional commercial guarantees. Accordingly, the English version contains:
- the heading “Legal guarantee” with the shield logo, a “G” and the EU stars,
- the statement: a minimum two-year legal guarantee protection for goods sold in the European Union,
- examples: the goods do not match the description or do not function as intended,
- the remedies: free repair or free replacement, in some cases a price reduction or full reimbursement,
- the reference to longer periods in some countries and a shorter period for second-hand goods, “but not less than one year”,
- what to do: contact the seller as soon as possible and provide proof of purchase,
- a cross-reference to commercial guarantees and the GARAN label,
- the QR code and the link
europa.eu/youreurope/guarantees.
Design rules for the notice
| Rule | Reference |
|---|---|
| No element can be edited. | Annex I, note 1 |
| Colours: blue Pantone Reflex Blue C (HEX #003399), yellow Pantone Yellow C (#FFED00), black, white | Annex I, note 2 |
| The QR code leads to the dedicated language section on the legal guarantee of conformity on the Your Europe portal and must be scannable with a standard mobile device. | Annex I, note 3 |
| Contracts other than distance contracts concluded through an online interface: colour (CMYK) or black and white; minimum size A4, larger formats possible (A3, A2, A1) | Annex I, note 4 |
| Distance contracts concluded through an online interface: must be in colour (RGB) | Annex I, note 5 |
For online shops this means: the colour RGB version, unmodified. The regulation sets no minimum on-screen size; the guidelines require the notice to be legible at standard display size. Where the graphic belongs in your shop is explained on the page placement of the legal guarantee notice.
What does Annex II say about the GARAN label?
Annex II shows the harmonised label for the commercial guarantee of durability. Unlike the notice, it has three editable fields, plus rules on size, font and a nested online format.
Fixed and editable elements
| Element | Editable? | Reference |
|---|---|---|
| (I) Title “GARAN” with tick mark | No | Annex II, note 1 |
| (II) Visual reminder of the legal guarantee of conformity (shield logo) | No | Annex II, note 1 |
(III) QR code leading to europa.eu/youreurope/commercial-guarantee-durability/index.htm | No | Annex II, note 1 |
| (IV) Calendar symbol representing “years” | No | Annex II, note 1 |
| (V) “Producer guarantee in years” in all official languages | No | Annex II, note 1 |
| (VI) “XX”: duration of the commercial guarantee of durability in years | Yes | Annex II, note 1 |
| (VII) “Brand/Trademark”: name of the producer offering the guarantee | Yes | Annex II, note 1 |
| (VIII) “Model identifier”: the model covered | Yes | Annex II, note 1 |
Format, size, colour and font
| Rule | Reference |
|---|---|
| Same colours as the notice: #003399, #FFED00, black, white | Annex II, note 2 |
| Outside online distance contracts at least 95 × 100 mm; at that size 7 pt (translations), 9 pt (brand, model), 80 pt (number of years). Larger only in full, undistorted and without separating its elements | Annex II, note 3 |
| Outside online distance contracts in colour or black and white | Annex II, note 4 |
| Online distance contracts: must be in colour | Annex II, note 5 |
| Font Inter (Regular, SemiBold, ExtraBold), including in the editable fields | Annex II, note 6 |
| QR code scannable with a standard mobile device; according to the guidelines never smaller than 2 × 2 cm | Annex II, note 7; guidelines p. 24 |
| Nested display online only; the full label must appear in its entirety on the first mouse click, mouse roll-over or tactile screen expansion | Annex II, “nested display” figure, note 2; recital 14 |
| Language-neutral, with one line in all official languages | Recital 15 |
When the GARAN label is mandatory is not set out in the regulation but in Art. 6(1)(la) CRD: a commercial guarantee of durability from the producer covering the entire good, at no additional cost, for more than two years, and the producer makes that information available to the trader. Details on the GARAN label page.
What may I change on the notice and the label?
Nothing on the legal guarantee notice; on the GARAN label only the three fields guarantee duration, producer name and model identifier. This follows directly from Annex I, note 1 and Annex II, note 1.
The Commission’s guidelines (pp. 10 to 13) specify what counts as a change: no changes to the frame, colours, spacing, typography or QR code, no cropping or stretching, no additional elements. Recreating the graphic in your own shop design is therefore ruled out.
The regulation does not say who fills in the three GARAN fields. The guidelines state: “They must be edited by the producer” (p. 21). Whether a trader may fill in a label with the producer’s details is unclear; the legal text does not prohibit it.
Which colour values apply, and why is there a contradiction?
According to the regulation, the colours are Pantone Reflex Blue C with HEX #003399 and Pantone Yellow C with HEX #FFED00, plus black and white (Annex I, note 2; Annex II, note 2). Incidentally, the Official Journal prints the yellow value as “#FFEDOO”, in the English and German versions alike, with the letter O instead of the digit zero.
The Commission’s downloadable original files contain different hex values from the annex, for example #0b4f9e in the English notice SVG. At the same time, the guidelines require the official files to be used without replacing colours (p. 7).
Unclear: Which colour value would prevail in a dispute, the hex value in the annex or the one in the official file, has not been settled. In practice, everything speaks for using the Commission’s official files unmodified and not adjusting any colours.
The original files in all 24 languages are in our download section.
May the label be collapsed or nested?
For the GARAN label, yes; for the legal guarantee notice, it is unclear. The regulation provides for a nested display explicitly only for the label (Annex II; recital 14). The full label must appear in its entirety on the first mouse click, mouse roll-over or tactile screen expansion.
For the notice, the regulation contains no such rule. On the one hand, the guidelines say: “In the digital space, the full harmonised notice should be displayed” (p. 15). On the other hand, their examples show a phrase such as “Your legal guarantee rights” on the catalogue page, in the page header or at checkout, with the notice appearing on the first click or roll-over (pp. 16 to 19).
Unclear: Whether a collapsible display of the legal guarantee notice is legally sufficient has not been decided. The Commission’s examples suggest it is. To be on the safe side, show the full notice in at least one place.
What do the Commission’s guidelines say, and are they binding?
The guidelines are not binding. The “Practical guidelines for sellers and producers” published by the Directorate-General for Justice in April 2026 state that they reflect “preliminary views of the European Commission (EC) services”. Only the Court of Justice of the EU can give a binding interpretation (guidelines, p. 2).
For the online display, they recommend, among other things:
- the full notice in the RGB colour version, legible at standard size (p. 15),
- always a clickable link to the same destination as the QR code, in English
europa.eu/youreurope/guarantees(pp. 15 f.), - the notice and the label also in the confirmation e-mail (p. 20, pp. 34 to 37),
- the GARAN label legible at standard size, enlargeable on product images and directly before the order on the checkout page (pp. 34 to 37).
For the notice, the directive itself gives the example of a “general reminder on the website of the trader selling goods” (recital 28 Directive 2024/825); for the GARAN label, placing it “directly next to the picture of the good in the case of online sale”. What the confirmation e-mail looks like in Shopify is shown on the page legal guarantee notice in the order confirmation.
In which language must the notice appear?
The regulation does not set a language. The Commission provides the notice in all 24 official languages; the GARAN label is language-neutral with one line in all official languages (recital 15). Which language version a shop must show is unclear. The obvious choice is the language in which the contract is offered.
What does the regulation not cover?
The regulation only governs what the two graphics look like. All other questions are answered by other legal acts:
| Question | Where it is governed |
|---|---|
| Who must show the notice? | Art. 5 and 6 CRD and the national transposing laws |
| By when must the consumer be informed? | before the consumer is bound by the contract or offer (Art. 5(1), Art. 6(1) CRD) |
| Must the GARAN label appear at the order button? | Yes directly before the order is placed (Art. 8(2) CRD) |
| What must a commercial guarantee statement contain? | Art. 17(2) Sale of Goods Directive |
| What happens in case of infringements? | national law; Art. 23 and 24 CRD |
National law can refer to the regulation expressly. In Germany, for example, Art. 246a EGBGB requires the notice “using the harmonised notice under Annex I of Implementing Regulation (EU) 2025/1960 as worded on 25 September 2025”, and refers to Annex II for the GARAN label. In addition, the GARAN label does not replace the commercial guarantee statement, which must be provided to the consumer on a durable medium at the latest at the time of delivery (Art. 17(2) Sale of Goods Directive). Under recital 15, the Commission may review and adapt the label in the light of its uptake and how consumers understand it.
How do I implement the regulation in Shopify?
The Shopify app EU-Gewährleistungslabel, GARAN shows the Commission’s original files unmodified, so nothing is recreated and no colours are replaced. The language version follows the store language automatically. The notice can be displayed in full, collapsible or as a pop-up; for the GARAN label you fill in only the three permitted fields per producer and product. More on the page legal guarantee notice for Shopify.
This plain-English guide reflects the regulation to the best of our knowledge (as of 7 October 2026). Only the text published in the Official Journal is authoritative (EUR-Lex). This page is not legal advice.
Frequently asked questions
When does Regulation (EU) 2025/1960 apply?
It entered into force on 22 October 2025 and has applied since 27 September 2026 (Art. 3 Regulation 2025/1960), the same day as the national measures transposing Directive (EU) 2024/825.
What is the difference between Annex I and Annex II?
Annex I contains the harmonised notice, the legal guarantee notice that traders must show whenever they sell goods to consumers. Annex II contains the harmonised label, the GARAN label, which is only mandatory for a producer’s commercial guarantee of durability of more than two years.
May I adapt the legal guarantee notice to my shop design?
No. None of the elements of the harmonised notice can be edited (Annex I, note 1). The guidelines also rule out changes to colours, frame, spacing and font as well as cropping and stretching.
May I use the black-and-white version online?
No. For distance contracts concluded through an online interface, the notice must be in colour (RGB) (Annex I, note 5), and so must the GARAN label (Annex II, note 5). Black and white is only allowed outside online distance selling.
Where does the QR code on the notice lead?
To the dedicated language section on the legal guarantee of conformity on the Your Europe portal (Annex I, note 3). The QR code on the GARAN label leads to europa.eu/youreurope/commercial-guarantee-durability/index.htm (Annex II, note 1).