New EU Rules Force Online Retailers to Display Product Guarantee Labels from Next Week

2026-09-20 digital

Brussels, Monday 21 September 2026
Effective 27 September 2026, EU retailers must display standardised warranty notices and durability labels online and in-store, risking severe legal penalties and warnings for non-compliance.

A Two-Tiered Regulatory Shift

The upcoming 27 September 2026 deadline introduces a major regulatory shift across the European Union, originating from Directive (EU) 2024/825—the Empowering Consumers for the Green Transition Directive—and Implementing Regulation (EU) 2025/1960 [1][4][6]. This framework mandates two distinct information requirements for business-to-consumer (B2C) transactions: a harmonised notice for statutory legal guarantees and a standardised ‘GARAN’ label for voluntary commercial durability guarantees [4][5][6]. While the legal guarantee notice is universally mandatory for physical goods to remind consumers of their minimum two-year rights, the GARAN label specifically targets voluntary manufacturer durability guarantees [1][2][5].

Criteria for the GARAN Label

Crucially, the GARAN label is only triggered if a producer offers a voluntary durability guarantee that is completely free of charge, covers the entire product, and extends for a duration strictly exceeding two years [1][2][4]. Guarantees of exactly two years, paid extensions, or retailer-specific warranties do not qualify for and are prohibited from using the GARAN marking [2][5]. This clear demarcation aims to resolve long-standing consumer confusion regarding the difference between statutory seller liabilities and additional commercial guarantees [4][5].

Technical Specifications and UI Challenges

For digital storefronts and multi-channel retailers, the technical requirements demand immediate architectural updates. The mandatory legal guarantee notice is strictly fixed in design, utilising a specific colour scheme including Pantone Reflex Blue C (#003399), Pantone Yellow C (#FFED00), Pantone Black 6 C, and Pantone 000C [1]. Online, this notice must be displayed clearly and visibly before a contract is concluded, such as directly on product pages or within checkout flows, preventing retailers from burying it in standard terms and conditions [2][4][5]. For physical retail, the notice must be presented in formats ranging from A4 (210 x 297 mm) to A1 (594 x 841 mm) with strict placement rules [1].

Integrating the Label on E-Commerce Platforms

The GARAN label itself is language-neutral, featuring a calendar icon, a QR code linking to the ‘Your Europe’ portal, and an editable field for the guarantee’s duration, which must be expressed in whole numbers or specific halves, such as 2.5 or 4.5 years [1][6]. E-commerce agencies note that implementing these labels requires managing structured product data, including manufacturer details, brand, and model identifiers [2][4]. For platforms like Shopify, Shopware, and PrestaShop, this requires theme-level integrations to ensure the labels are visible across all purchase paths, including quick-add buttons and cart drawers, without relying on slow external scripts [2][4][7].

The Legal Risks of Non-Compliance

With the compliance deadline set for 27 September 2026, the risk of legal action is high [1][2][3]. In Germany, the national transposition of these rules enters into force on the same date, following the enactment of the amendment legislation on 3 February 2026 [6]. Legal experts warn that incorrect, missing, or unjustified use of the GARAN label constitutes a significant ‘warning trap’ (Abmahnfalle) [3][5]. This warning risk is compounded by a ruling from the Higher Regional Court of Cologne (OLG Köln) on 27 March 2026, which established that competitors can claim warning costs under the Act Against Unfair Competition (UWG) if non-compliant labelling constitutes misleading advertising [6].

Marketplace Challenges and Platform Limitations

Multi-channel merchants selling on marketplaces such as Amazon or eBay face additional operational hurdles [3][5]. While the technical limitations of these platforms may complicate compliant layouts, the legal responsibility for displaying the correct guarantee information remains entirely with the individual merchant [4][5]. Consequently, trade associations recommend that retailers audit their product portfolios immediately and formally request marketplace operators to provide compliant display solutions [5].

Broad Operational Scope and Exclusions

The regulation applies broadly to B2C retail of physical goods, including second-hand items and products with digital components, such as smart-home devices and smartphones [2][4]. Even legacy sectors like the tyre trade are heavily impacted; starting 27 September 2026, tyre retailers must display the legal guarantee notice on product pages online and in minimum A4 print formats in physical shops, alongside stricter rules governing environmental ‘green claims’ [8]. Conversely, pure digital content, software-as-a-service (SaaS) platforms, and pure business-to-business (B2B) webshops are entirely exempt from these specific labelling mandates [2][4].

Sourcing and Information Duties

Retailers are not legally obligated to actively hunt for manufacturer warranty information across external websites [6][7]. The duty to display the GARAN label only applies if the retailer has explicit knowledge of the commercial guarantee, or if the manufacturer has provided the necessary details directly [6][7]. However, once a manufacturer provides this information or displays it on product packaging, the merchant is legally bound to implement the corresponding GARAN label before the purchase is finalised [1][2][7].

Sources & Ecosystem Partners

E-commerce Regulation Consumer Rights