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Starting on 27 September 2026, businesses that sell goods to consumers in the EU must show two new pieces of information at the point of sale: (i) a mandatory notice about the legal guarantee; and (b) a new label called GARAN, if the product includes a commercial durability guarantee.
What is changing
The new requirements stem from Directive (EU) 2024/825, which amended the Consumer Rights Directive, and Commission Implementing Regulation (EU) 2025/1960, which sets out the exact design and content of the notice and the new label.
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Legal guarantee notice: the legal guarantee notice is a document that reminds consumers of their statutory rights: a minimum 2-year guarantee on goods sold in the EU, the remedies available (repair, replacement, price reduction, or reimbursement), and that some Member States may offer longer periods. Businesses are not allowed to change the wording or design of the notice. The notice must be clearly visible at the point of sale: in physical stores, for example on a wall poster or near the checkout; online, on the seller’s website. For online sales, businesses should think carefully about where the notice appears during the buying process, as showing it only in the terms and conditions will probably not be enough.
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GARAN Label: the new EU product label (or GARAN label) applies only when a producer voluntarily offers a free durability guarantee covering the entire product for more than two years. If no such guarantee is offered, the business is not required to display the label. The label template must also be used in its prescribed form, and businesses may only modify three elements: the duration of the guarantee, the producer’s brand or trademark, and the product model identifier. For online sales, the full label must appear on the first click, on hover, or next to the product image. In physical stores, it must be displayed on the product packaging or clearly on the relevant shelf, and producers may also place it directly on the product itself. In all cases, the label must be clearly visible and clearly linked to the product it covers.
What this means in practice
The challenge is not the content of the notices, as the templates are ready to use. It is the implementation. For businesses running large product catalogues, or selling through distributors, marketplaces, or intermediaries, some of operational challenges include: identifying which products are in scope, ensuring guarantee information reaches the point of sale, and making sure the right notice is shown to the right consumer at the right time.
What to do now
The first step is to carry out a product catalogue audit to identify which goods are sold to EU consumers, which producers offer a qualifying durability guarantee, and what changes are needed to existing guarantee information and product displays. Businesses should then update their online sales flows and in-store displays to ensure the required notices and labels appear correctly and are clearly visible to consumers. Both sales channels should be tested well before the deadline to confirm compliance.
The EU notice and GARAN label templates are available here in high-resolution vector format, along with practical guidelines on correct application and display.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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