In short
- 27 September 2026 is the date the EU’s harmonised legal guarantee notice becomes mandatory for every trader selling goods to consumers in the bloc, online and in store.
- The notice is fixed artwork set by Commission Implementing Regulation (EU) 2025/1960. Traders may not redraw it, reword it or fold it into their own returns page copy.
- A second instrument, the GARAN label, applies where a producer offers a free commercial guarantee of durability longer than two years that covers the whole product.
- Twenty member states are under infringement proceedings for missing the 27 March 2026 transposition deadline, according to Commission statements. The application date has not moved.
- Exposure is highest in apparel, footwear, consumer electronics and homeware, where catalogues are large, producer warranty data is thin and product pages are generated from feeds.
What becomes mandatory on 27 September
On 27 September 2026 the consumer information half of Directive (EU) 2024/825 starts to apply across the European Union. The directive, known in practice as EmpCo or the Empowering Consumers for the Green Transition Directive, amends two of the EU’s foundational consumer instruments. It rewrites parts of the Unfair Commercial Practices Directive and parts of the Consumer Rights Directive, Directive 2011/83/EU.
Most trade coverage so far has focused on the greenwashing side of the text. The information side is the part that touches every product page in the single market, including pages that make no environmental claim at all.
From that date, a standardised notice about the legal guarantee of conformity must be displayed to consumers before they buy. According to the European Commission’s own guidance for businesses, the harmonised notice becomes mandatory as of 27 September 2026, and it applies to sellers of consumer goods regardless of size, sector or place of establishment. A separate harmonised label, branded GARAN, must be used in a fixed form whenever a producer offers a qualifying commercial guarantee of durability.
The design and content of both instruments are not left to traders. Commission Implementing Regulation (EU) 2025/1960, adopted in September 2025, fixes the artwork, the wording, the colours and the minimum dimensions.
That combination is what makes this deadline operationally awkward. It is not a policy that can be satisfied with a sentence in the terms and conditions, and it lands on catalogues that in many cases run to hundreds of thousands of SKUs. Retailers that treated the September date as a sustainability marketing problem have been scoping the wrong workstream.
What the legal guarantee notice actually says
The harmonised notice is a general statement, not a product-specific one. It tells consumers that they benefit from a legal guarantee of conformity of at least two years on consumer goods sold in the EU, and that this right exists independently of any commercial warranty a seller or producer chooses to offer. Per the implementing regulation, the notice carries a reference to Article 22a(1) of Directive 2011/83/EU.
The intent behind it is straightforward. EU consumer bodies have argued for years that shoppers routinely pay for extended warranties that duplicate rights they already hold for free. A single recognisable notice, repeated across every shop and every website in the bloc, is the Commission’s answer to that.
Because the notice is general rather than product-specific, it does not need to be varied by SKU. That is the one piece of good news in the compliance scope, and it is the reason the notice is far less work than the label for most catalogues.
Why it cannot be redesigned
The notice is a fixed instrument. None of its elements or text may be edited, which rules out the usual retail practice of restyling a compliance block to match the brand’s design system. Official artwork is published in all 24 official EU languages, and the language shown to a shopper should match the language of the storefront.
Practically, that means the notice is an asset management task rather than a copywriting task. Teams need the correct language variant loaded, served at the right size, and rendered in colour on digital channels. Storefronts operating in a non-EU language, an English-language site selling into Ireland for example, need a defensible fallback rather than an omission.
The two-year minimum is not new law. It comes from the Sale of Goods Directive, Directive (EU) 2019/771, and it has applied since 2022. Several member states already exceed it: the Netherlands applies a conformity standard tied to reasonable expected lifespan, and Sweden, Ireland and Portugal have longer or differently framed periods.
What changes on 27 September is visibility, not the underlying entitlement. Retailers that have quietly relied on shoppers not knowing about the two-year floor should expect a measurable rise in conformity claims once the notice is displayed at the point of sale. Returns and after-sales teams, not just legal teams, need to be in the planning for this deadline.
When the GARAN label applies, and when it does not
The GARAN label is the more misunderstood of the two instruments. It is frequently described as voluntary, and it is frequently described as mandatory, and both descriptions are partly right. Offering a commercial guarantee of durability remains entirely a commercial choice for a producer.
Where a producer does offer one that meets the qualifying conditions, use of the harmonised GARAN label in its prescribed form is not optional. A producer cannot offer a qualifying three-year durability guarantee and then present it in bespoke marketing artwork of its own design.
The label itself is a compact visual block. According to the Commission’s business guidance, it carries the title GARAN, which references the word for guarantee across several EU languages, a tick mark indicating that durability is guaranteed, a calendar symbol showing the duration, a reminder that the legal guarantee of conformity also exists, and a QR code linking through to further information on consumer rights.
The three conditions producers must meet
Three cumulative conditions determine whether a commercial guarantee triggers the label. The guarantee must be offered at no additional cost to the consumer. It must cover the entire good rather than a component, a coating or a single subsystem. And its duration must exceed two years, so that it genuinely extends beyond the legal guarantee floor.
A fourth practical condition sits alongside those three: the producer has to make the information available to the seller. Without that transfer, a retailer has no basis on which to display a label for a product it did not manufacture.
The exclusions matter as much as the inclusions. A paid extended warranty does not qualify. A guarantee covering only the motor of an appliance or only the frame of a piece of furniture does not qualify. A two-year commercial warranty that merely mirrors the legal guarantee does not qualify either, because it adds nothing beyond the statutory floor.
What sellers need from producers
Three fields on the label are editable, and only three: the duration in years, the producer’s brand or trademark, and the model identifier of the covered product. Duration can be expressed in half-year increments, so a three-and-a-half year guarantee is expressible. Everything else in the artwork is fixed.
That short list of variables conceals a real data problem. A retailer needs the manufacturer name and the manufacturer product number populated correctly for every affected SKU, which is precisely the field that is most often missing or inconsistent in supplier feeds. Platform vendors have been explicit that merchants should be asking producers now to confirm guarantee terms and hand over the relevant information.
Printed labels carry a minimum size of 95 by 100 millimetres on the product or its packaging. Digital versions must be rendered in colour. Retailers running physical and online channels therefore have both a packaging artwork question and a product page question to resolve, often with different owners inside the business.
Where the notice and the label have to appear
Placement is where the two instruments diverge most sharply, and it is where retailers are most likely to get the implementation wrong. The notice is a shop-level obligation, displayed prominently, while the label is a product-level one attached to specific goods.
| Feature | Legal guarantee notice | GARAN label |
|---|---|---|
| Mandatory from | 27 September 2026, for all sellers of consumer goods | 27 September 2026, but only where a qualifying guarantee is offered |
| Who is responsible | The seller displaying it at point of sale | The producer, who must make it available to sellers |
| Scope | General, not product-specific | Product-specific, tied to a model identifier |
| Editable elements | None | Three: duration, brand or trademark, model identifier |
| Trigger for use | Selling any consumer good to an EU consumer | Free durability guarantee over two years covering the whole good |
| Governing instrument | Implementing Regulation (EU) 2025/1960 | Implementing Regulation (EU) 2025/1960 |
Online and in-store placement
For digital channels, the requirement is that the notice appear prominently on the website before the consumer is bound by the contract. Platform guidance published ahead of the deadline points to the checkout page, positioned near the terms and conditions confirmation, and to the order confirmation email. The label, being product-specific, belongs on the product detail page and follows the item into the basket and the confirmation email.
There is a design tension here that retailers should anticipate. Conversion teams spend years removing friction from checkout, and this rule inserts a fixed compliance asset into exactly that flow. Attempting to minimise it into a collapsed accordion at the foot of the page is likely to fail the prominence test.
Marketplace sellers are not exempt. Guidance from consultancies tracking the rule is consistent that traders selling through platforms including large marketplaces carry the same obligation as traders on their own storefronts, which pushes the practical burden onto the platform’s listing template and onto the seller’s own product content.
In physical retail the notice can be displayed as a poster, typically on a wall or next to the checkout counter. The minimum size is A4. Unusually, in-store display permits either colour or black and white, whereas online display requires colour.
That asymmetry is worth flagging to store operations teams, because it is the kind of detail that produces an avoidable finding in an inspection. A monochrome print of the notice pinned near a till is compliant. The same monochrome asset rendered on the website is not.
| Channel | Notice format | Minimum size | Typical placement |
|---|---|---|---|
| Physical store | Colour or black and white | A4 | Poster on wall, or near the checkout counter |
| Online storefront | Colour required | Not fixed in the regulation | Checkout page and order confirmation |
| Product packaging (GARAN) | Colour | 95 by 100 mm printed | On the product or its packaging |
| Product detail page (GARAN) | Colour | Not fixed in the regulation | Near the buy box, expandable to full size |
Why 20 member states missing the deadline changes nothing
Member states were required to transpose EmpCo into national law by 27 March 2026. Reporting from law firms and compliance trackers indicates that only seven of the 27 met that deadline. On 28 May 2026 the Commission opened infringement proceedings against 20 member states for failing to notify complete transposition measures, giving them two months to respond.
The states named in that action reportedly include Belgium, Bulgaria, Czechia, Estonia, Greece, Spain, France, Croatia, Cyprus, Latvia, Luxembourg, Hungary, Malta, the Netherlands, Austria, Poland, Portugal, Slovenia, Finland and Sweden. Trackers published since then do not fully agree on which states have closed the gap: CMS lists France, Germany, Hungary, Ireland and Italy as implemented, while other trackers describe the French transposition bill as still moving through the legislature. Retailers should verify status market by market rather than relying on a single tracker.
None of that pushes the application date. The Commission has been explicit that it wants all member states in a position to apply EmpCo from 27 September 2026, and the implementing regulation that fixes the notice and label design is directly applicable across the Union without national transposition.
The practical risk of a transposition gap runs the other way from what retailers might hope. A late-transposing state can adopt national rules with a short or absent grace period, which compresses preparation time rather than extending it. This is the same pattern retailers saw with the Cyber Resilience Act reporting duties starting 11 September, where national enforcement architecture lagged an EU-level date that arrived regardless.
How this differs from the green claims half of the directive
EmpCo is a single directive with two distinct compliance workstreams, and conflating them is the most common planning error. One workstream sits in the Unfair Commercial Practices Directive and governs what a retailer may claim. The other sits in the Consumer Rights Directive and governs what a retailer must disclose.
The claims workstream is the one that has drawn the coverage: generic environmental claims such as green or eco-friendly banned without proof of excellent environmental performance, offset-based claims such as carbon neutral prohibited outright for products, and sustainability labels required to rest on certification schemes or public authority backing. We covered the mechanics of that side in detail when the EU green claims ban and its 4% turnover fines came into focus earlier this month.
The disclosure workstream is broader in one important sense. A retailer that makes no environmental claim whatsoever is untouched by most of the greenwashing provisions, but is fully caught by the guarantee notice. Every seller of physical consumer goods in the EU is in scope of the notice on the same day.
Alongside the guarantee information, the amended Consumer Rights Directive adds pre-contractual duties on the duration of software updates for goods with digital elements, on the availability and cost of spare parts, on repair restrictions, and on the harmonised repairability score where one has been established at EU level for a product category. Those obligations, like the notice, live on the product page.
What the compliance work actually involves
Scoping this correctly means separating three tasks that different teams own. Displaying the notice is a template change. Displaying the GARAN label is a data problem. Meeting the wider pre-contractual duties on repair, spare parts and software updates is a supplier engagement problem.
The product data problem
The GARAN label needs manufacturer name and manufacturer product number populated cleanly for every affected SKU, plus confirmed guarantee terms from the producer. In large assortments those attributes are frequently inherited from supplier feeds of uneven quality, and the model identifier in particular is often a free-text field rather than a controlled one.
Retailers should expect the confirmation exercise itself to take time. A producer has to state whether its commercial guarantee is free, whether it covers the whole good, and how long it runs, and many will need internal legal sign-off before answering. Buying teams that start those conversations in late September will be answering enforcement questions rather than preventing them.
Where a producer does not respond, the safe position is not to display a GARAN label. Displaying one without a qualifying guarantee behind it is itself a misleading practice, which turns a data gap into a claims risk. The same discipline applies to cross-border sellers navigating the wider information requirements set out in our 2026 cross-border compliance refresher.
Platform readiness
Commerce platforms have been shipping support ahead of the date. Shopware has said native support for the notice and label arrives in version 6.7.14, expected in early September 2026, with backports to the 6.6 line and availability including the Community Edition. Its implementation serves the official artwork in all 24 languages with automatic matching to the storefront language and an English fallback outside the EU set.
Merchants on managed platforms still carry residual work. Placement prominence remains the merchant’s responsibility to assess, and heavily customised themes will need the display tested on both desktop and mobile after the update lands. A platform release in early September leaves roughly three weeks for that testing, which is thin for a large custom storefront.
Retailers on bespoke or headless stacks have no vendor doing this for them. For those teams the sequence is to obtain the official artwork set, wire language selection, place the asset at checkout and in confirmation emails, and separately build the product-level label rendering path.
Which retail categories carry the most exposure
Exposure to the notice is universal, but exposure to the label and to the wider repair and durability disclosures is not evenly spread. Categories where producers commonly offer long free warranties will have the largest GARAN footprint to manage.
Consumer electronics, large domestic appliances, power tools and furniture sit at the top of that list. Multi-year manufacturer guarantees are standard marketing practice in those categories, which means a high proportion of the assortment will need label data rather than a small tail of it.
Apparel, footwear and textiles are a different shape of problem. Free durability guarantees beyond two years are rare there, so the GARAN burden is light, but catalogue sizes are enormous and product data is often thin. Compliance guidance aimed specifically at clothing and textile businesses has been circulating since earlier in 2026, which suggests enforcement attention on the sector.
Goods with digital elements carry the heaviest combined load. A connected appliance triggers the guarantee notice, potentially the GARAN label, the software update duration disclosure, and separately the data access obligations under the EU Data Act provisions that start on 12 September. Three EU instruments land on the same product page inside three weeks.
| Date | Instrument | Primary retail impact |
|---|---|---|
| 12 August 2026 | Packaging and Packaging Waste Regulation | Packaging composition and labelling |
| 11 September 2026 | Cyber Resilience Act reporting duties | Incident reporting for connected products |
| 12 September 2026 | Data Act, data access by design | Connected goods data access |
| 27 September 2026 | EmpCo claims provisions | Environmental claims and sustainability labels |
| 27 September 2026 | Guarantee notice and GARAN label | Every product page and every store |
How enforcement and penalties are likely to work
Enforcement runs through national consumer protection authorities applying transposed national law, coordinated where relevant through the Consumer Protection Cooperation network. The headline sanction cited across legal commentary is a fine of up to 4% of annual turnover in the member state or states concerned, the ceiling that applies to widespread infringements under the Unfair Commercial Practices Directive.
That ceiling is more likely to shape settlement conversations than to appear on an early enforcement notice. Regulators typically open with cease-and-desist requests and injunctions, and the directive is also within scope of the Representative Actions Directive, which allows qualified entities to bring collective redress on behalf of consumers.
The realistic near-term risk for a mid-sized retailer is not a headline fine. It is a competitor complaint or a consumer association test purchase, followed by a demand to correct the storefront within a short window. Missing artwork on a checkout page is trivially easy for a third party to evidence with a screenshot, which is why this rule is unusually cheap to enforce.
Packaging is where remediation costs bite hardest, because artwork changes cannot be pushed like a template change. Retailers that lived through the artwork rework triggered when the EU packaging regulation took effect in August will recognise the pattern: digital fixes are same-day, print fixes run to the next production cycle.
What to do in the 30 days that remain
The sequence that fits the time available starts with the universal obligation and works outward. Download the official notice artwork in every language your storefronts serve, and place it at checkout and in order confirmation emails. That single step removes the most easily evidenced compliance gap.
Second, run a data completeness check on manufacturer name and manufacturer product number across the assortment, since both are prerequisites for any GARAN label rendering. Third, issue a standard-form request to producers in the exposed categories asking them to confirm guarantee duration, whether it is free, and whether it covers the entire good.
Fourth, audit the storefront for the adjacent pre-contractual duties that arrive on the same day: software update periods for goods with digital elements, spare parts availability and cost, and repair restrictions. Fifth, brief customer service and after-sales on an expected increase in conformity claims once the two-year entitlement is displayed at the point of sale.
Retailers selling into markets that have not completed transposition should not treat that as slack. The implementing regulation applies directly, national rules may arrive with little notice, and the reputational cost of being the storefront that visibly lacks the notice on 28 September is not worth the three weeks saved. Full official guidance for businesses is published on the Commission’s Your Europe portal.
The broader point is that 27 September is not a sustainability deadline. It is a product page deadline, and the teams that need to be in the room are merchandising, product data and platform engineering, not only legal and brand.
Frequently asked questions
Does the legal guarantee notice apply to businesses outside the EU?
Yes, where they sell goods to consumers in the EU. Compliance guidance is consistent that the obligation attaches to every trader selling consumer goods into the bloc regardless of size, sector, sales model or place of establishment, which includes non-EU sellers shipping into member states and non-EU sellers listing on EU marketplaces.
Is the GARAN label mandatory or voluntary?
Both descriptions circulate because the answer has two parts. Offering a commercial guarantee of durability is a voluntary commercial decision, but where a producer offers one that is free, covers the entire good and runs longer than two years, use of the harmonised GARAN label in its prescribed form is required rather than optional.
Can we restyle the notice to match our brand design system?
No. The notice is a fixed instrument under Implementing Regulation (EU) 2025/1960 and none of its elements or text may be edited. The only flexibility is choosing the correct language variant and, in physical stores, the choice between colour and black and white.
What happens if our member state has not transposed the directive by 27 September?
The application date does not move, and the implementing regulation fixing the notice and label design applies directly without national transposition. A late-transposing state may adopt national rules with a short grace period, which shortens preparation time rather than extending it.
Do marketplace sellers have to display the notice themselves?
Guidance tracking the rule indicates that traders selling through marketplaces carry the same obligation as traders on their own storefronts. In practice this means the burden falls on both the platform’s listing template and the seller’s own product content, and sellers should confirm with each marketplace how it intends to surface the notice.
Does a paid extended warranty qualify for the GARAN label?
No. One of the cumulative conditions is that the commercial guarantee of durability is offered at no additional cost to the consumer. A warranty the customer pays for, or one that covers only a component rather than the entire good, falls outside the label.
How does this interact with the green claims provisions of the same directive?
They are separate workstreams inside one directive that share an application date. The green claims rules amend the Unfair Commercial Practices Directive and govern what you may say, while the guarantee notice and label amend the Consumer Rights Directive and govern what you must disclose. A retailer making no environmental claims is still fully caught by the notice.
What are the likely penalties for non-compliance?
Legal commentary cites fines of up to 4% of annual turnover in the member state or states concerned for widespread infringements, alongside cease-and-desist actions and injunctions. The directive also falls within scope of the Representative Actions Directive, which allows qualified entities to bring collective consumer claims.
What is the single highest-value action to take first?
Place the official notice artwork at checkout and in order confirmation emails in every language your storefronts serve. It is the obligation that applies to every seller without exception, it is the easiest gap for a competitor or consumer body to evidence with a screenshot, and it is a template change rather than a data project.