Since 27 September 2026, every trader who sells goods to consumers must show the legal guarantee notice, in an online shop as well as in a physical store. Pure B2B sales and sales between private individuals are not covered. The GARAN label is only added if the producer offers a free commercial guarantee of durability of more than two years and makes that information available.
The official name of the notice is the “harmonised notice on the legal guarantee of conformity”. It reminds buyers of their legal guarantee of at least two years. Whether you must show it depends on three questions: do you sell goods, do you sell to consumers, and is the contract within the scope of EU consumer law? What the notice is exactly is explained in the guide Legal guarantee notice.
Who is obliged to show the legal guarantee notice?
The obligation lies with the trader who sells goods to consumers. It comes from the Consumer Rights Directive as amended by Directive (EU) 2024/825 and only applies to contracts between traders and consumers.
- Online shops and other distance contracts: Art. 6(1)(l) of the Consumer Rights Directive (CRD).
- Physical shops: Art. 5(1)(e) CRD.
Each member state has transposed these provisions into its national law.
The producer has no role in the notice. The Commission’s guidelines see “only a role for traders selling goods (sellers)” (p. 2). For the GARAN label, the producer can voluntarily place the label on the goods or the packaging (recital 28 of Directive 2024/825), but the obligation to show it in the shop lies with the trader.
The notice is not about commercial guarantees. The directive refers to the legal guarantee of conformity “applicable to all goods” (recital 28). So you need it even if none of your products comes with a commercial guarantee.
Which traders are affected? All cases at a glance
The table summarises the most common situations. “Unclear” means: the legal position cannot be derived with certainty from the directive and the regulation. You should have these points checked by a lawyer.
| Case | Legal guarantee notice? | Reason |
|---|---|---|
| Online shop, sales to consumers | yes | Art. 6(1)(l) CRD; in colour, unmodified |
| Physical shop | yes, with an unclear exception | Art. 5(1)(e) CRD; member states may exempt everyday transactions performed immediately (Art. 5(3) CRD), scope unclear |
| Small business | yes, if B2C | The obligation depends on trader and consumer, not on size or turnover |
| B2B only | No | The Consumer Rights Directive does not apply to contracts between businesses |
| Private sale (private to private) | No | No trader involved |
| Second-hand goods | yes | Second-hand goods are goods; the official notice mentions them itself |
| Goods with digital elements | yes, plus software information | They are goods; in addition, the minimum period for software updates if the producer provides it |
| Digital content, digital services | simple reminder only | Art. 6(1)(lb) CRD; no official graphic |
| Food, consumables | probably yes, check with a lawyer | The notice applies to goods; only regular delivery rounds of household goods and vending machines are excluded (Art. 3(3)(j) and (l) CRD) |
| Sales via marketplaces | yes, the trader remains obliged | the obligation lies with the trader who sells |
| Dropshipping | yes | You are the consumer’s contractual partner |
| Traders outside the EU with EU customers | unclear, check with a lawyer | depends on which law applies to the contract |
Does the obligation also apply in physical shops?
Yes. For contracts in a shop, Art. 5(1)(e) CRD applies, and point (ea) for the GARAN label. In shops, Regulation (EU) 2025/1960 allows printouts in colour or black and white, at least in A4 (Annex I, note 4). The directive gives as an example a poster “in an eye-catching way on a wall in the shop, next to the checkout counter” (recital 28).
There is an exception of uncertain scope. Under Art. 5(3) CRD, “Member States shall not be required to apply paragraph 1 to contracts which involve day-to-day transactions and which are performed immediately at the time of their conclusion.” Directive 2024/825 only amended paragraph 1, so according to the wording the option also covers the notice. Whether it applies in your country depends on whether your member state has used this option; Germany, for example, has such an exception.
Unclear: how far the exception for everyday transactions reaches in practice is open. The Commission speaks of displaying the notice “in all shops (both online and offline)” (guidelines, p. 4). If you run a physical shop, have this checked by a lawyer. There is no such exception for online sales.
Does the legal guarantee notice apply to small businesses?
Yes, as long as you sell to consumers. The obligation is triggered when a trader sells goods to a consumer. Neither Art. 5 nor Art. 6 CRD contains an exception based on turnover, number of employees or legal form. In our understanding, a VAT small-business scheme does not change your status as a trader under consumer law.
A ready-made solution makes particular sense for small shops, because the graphic must not be recreated. On Shopify, the app EU-Gewährleistungslabel, GARAN does this with no coding, see legal guarantee notice for Shopify.
Does the legal guarantee notice apply in B2B trade?
No. Contracts between businesses are not covered by the Consumer Rights Directive and therefore not by the notice requirement. But this only applies to contracts actually concluded with businesses. As soon as consumers can buy from you, the obligation applies to those contracts.
Check with a lawyer: the provisions reviewed here do not say how a shop can reliably exclude orders from consumers, for example through notices or checking business status.
Do private sellers have to show the notice?
No. If you sell privately to private buyers, for example on classifieds sites, you are not a trader within the meaning of the Consumer Rights Directive. Whether a seller is still acting privately or already in the course of business is a separate question that the labelling rules do not address.
Do I need the notice for second-hand goods?
Yes. Second-hand goods are goods, and the legal guarantee of conformity applies to them too. The official notice addresses second-hand goods itself: “For second-hand goods, a shorter period may apply, but not less than one year.” Such a shorter period is only possible where national law allows it and only by agreement between seller and consumer (Art. 10(6) of the Sale of Goods Directive).
The notice stays unchanged. You must not add your own sentence about the shorter period, because none of its elements can be edited (Annex I, note 1 of Implementing Regulation 2025/1960).
What applies to digital products and goods with digital elements?
For digital content and digital services, such as downloads or software subscriptions, no harmonised notice is prescribed. There, the law only requires a reminder of the existence of the legal guarantee of conformity, without an official graphic (Art. 6(1)(lb) and Art. 5(1)(eb) CRD).
Goods with digital elements, on the other hand, are goods. The legal guarantee notice applies to them. In addition, there is the information on the minimum period for software updates (Art. 6(1)(lc) and Art. 5(1)(ed) CRD) if the producer provides it. If you sell both, you need the official notice for the goods.
Does the legal guarantee notice apply to food?
Probably yes, but you should have this checked by a lawyer. The notice requirement relates to goods, and the directive refers to the legal guarantee of conformity “applicable to all goods” (recital 28 of Directive 2024/825). The provisions reviewed here do not mention an exception for food, cosmetics or other consumables.
Question for your lawyer: whether special rules apply to food and quickly consumed goods, for example through general exceptions in distance selling law, is not covered by our review of the sources.
What applies to sales via marketplaces and dropshipping?
On marketplaces, the trader remains obliged. The obligation lies with the trader who sells the goods to the consumer, not with the platform. If a marketplace offers its own feature for the notice, check whether the official graphic appears in colour, unmodified and visible before the purchase. If not, the risk is yours.
With dropshipping, you are the consumer’s contractual partner, even if a supplier ships the goods. So you are obliged to show the notice. For the GARAN label, what matters is whether the producer makes a guarantee of durability known to you. You do not have to go looking for it (recital 26 of Directive 2024/825).
Does the obligation apply to traders outside the EU?
That depends on which law applies to the contract with the consumer. As a rule: if a trader directs its offer at consumers in the EU, their consumer law applies (Art. 6(1)(b) Rome I Regulation), and for unfair competition, the market in which it advertises counts (Art. 6(1) Rome II Regulation). Individual cases may differ. The obligation is EU law: the directive applies in all member states, and the implementing regulation directly in every member state. The official notice itself speaks of “goods sold in the European Union”.
Check with a lawyer: whether a trader based outside the EU, for example in Switzerland or the United Kingdom, must show the notice when selling to EU consumers is a question of applicable law that our sources do not answer. If you deliberately sell to consumers in the EU, have this checked before you decide not to show the notice.
When do I also need the GARAN label?
Only for a particular kind of producer guarantee. The GARAN label (officially the “harmonised label for the commercial guarantee of durability”) is mandatory when all five conditions are met together (Art. 6(1)(la) CRD):
- a commercial guarantee of durability from the producer, not the trader,
- at no additional cost,
- for the entire good, not just components,
- with a duration of more than two years; exactly two years is not enough,
- the producer makes the information available to you.
Trader guarantees and paid guarantee extensions do not get a GARAN label. In an online shop, the GARAN information must also appear directly before the order (Art. 8(2) CRD). Full details on the page GARAN label.
Checklist: must I show the notice or the GARAN label?
Go through the questions in order. As soon as an answer is “no”, the check ends for that stage.
- Do I sell goods?
Physical goods, new or second-hand, including those with digital elements. For purely digital content or digital services, a simple reminder of the legal guarantee without a graphic is enough. - Do I sell to consumers?
If private customers can buy too: yes. Pure B2B contracts and sales between private individuals are not covered. - Do I sell in the EU?
Contracts with consumers that are governed by the consumer law of an EU country. If you are based outside the EU, check with a lawyer. - Result: show the legal guarantee notice
Online in colour and unmodified, clearly visible before the purchase; in a shop as a poster of at least A4. Where exactly is explained on the page Placement. - Does the producer offer a guarantee of durability of more than two years?
A guarantee from the producer, not your own, running for more than two years. - Does it cover the entire good, and is it free of charge?
No partial guarantee for individual components, no surcharge. - Has the producer made the information available to you?
You do not have to search producer websites yourself. - Result: show the GARAN label
Next to the product picture and directly before the order, with guarantee period, producer name and model identifier.
How do I meet the obligation on Shopify?
If your checklist ends with “show the notice”, you need the official graphic in the right places in your shop. The Shopify app EU-Gewährleistungslabel, GARAN shows the Commission’s original files unmodified, in all 24 official languages matching the shop language, automatically on the product page, collection page, in the cart, in the cart drawer and in the footer. You set up GARAN labels per producer and product, with no product limit. The graphic with a PDF download also appears in the order confirmation.
This overview reflects the legal situation to the best of our knowledge (as of 3 October 2026) and is not legal advice. You should have the cases marked as unclear checked by a lawyer. The legal sources are listed under Legal basis.
Frequently asked questions
Who must display the legal guarantee notice?
Every trader who sells goods to consumers, online and in physical shops. The legal basis is Art. 5 and 6 of the Consumer Rights Directive as amended by Directive (EU) 2024/825, in particular Art. 5(1)(e) and Art. 6(1)(l), as transposed into the national law of each member state.
Does the legal guarantee notice apply to small businesses?
Yes, as soon as they sell to consumers. The rules do not provide for an exception based on size or turnover.
Does the legal guarantee notice apply in B2B trade?
No. Contracts between businesses are not covered by the Consumer Rights Directive. If consumers can also buy from you, the obligation applies to those contracts.
Do I need the notice for second-hand goods?
Yes. The legal guarantee of conformity also applies to second-hand goods. The official notice itself mentions that the period may be shorter for second-hand goods, but not less than one year.
Do I need the notice for digital products?
For digital content and digital services, no official graphic is prescribed, only a reminder of the existence of the legal guarantee of conformity (Art. 6(1)(lb) of the Consumer Rights Directive). For goods with digital elements, the normal notice applies.
Do private sellers on Vinted or classifieds sites have to show the notice?
No. Sales between private individuals are not covered by the Consumer Rights Directive.
Must I show the notice if I sell via Amazon, eBay or Etsy?
The obligation lies with the trader who sells, not with the platform. Check whether the marketplace displays the official graphic in colour, unmodified and before the purchase. The risk of a missing notice is yours.