Warranty and Guarantee Label from 27 September 2026: Which Presentation Requirements Apply – and Which Questions Remain Open
From 27 September 2026, retailers in the B2C sector must comply with two new notices that are uniform across the EU:
- the harmonised notice on statutory warranty law (“warranty notice”): a uniformly designed notice that informs consumers that they are entitled to statutory warranty rights against the seller;
- the harmonised label for the commercial durability guarantee (“GARAN label”): an additional label, likewise standardised across the EU, for cases where the manufacturer voluntarily grants a specific durability guarantee for the goods.
The design and content of both notices are largely prescribed by EU law, in particular by Annex I and Annex II of Implementing Regulation (EU) 2025/1960.
In practice, however, there are clear differences in implementation: whereas comparatively specific requirements exist for the online display of the GARAN label, and a nested display is expressly permitted, it is in particular unclear in the case of the warranty notice how the prescribed requirement to make it available “in a prominent manner” is to be put into practice in an online shop.
The Warranty Notice
The warranty notice is a standardised piece of consumer information on statutory warranty law.
It is intended to remind consumers that, when they buy goods, they have statutory rights if the goods are defective. This includes in particular a reference to the minimum period of two years and to the fact that the warranty period under national law may be longer.
The underlying information obligation under Art. 22a of the Consumer Rights Directive requires that this information be made available “in a prominent manner” using the harmonised notice.
Unlike the GARAN label, the warranty notice is not product-specific. It therefore does not have to be affixed to every individual item or placed directly next to every individual product, but serves as general consumer information on statutory warranty law for goods.
In the case of distance contracts, this is a pre-contractual information obligation. The consumer must receive the information before they are bound by the contract or by their contractual offer.
In principle, the obligation applies to every retailer that sells goods to consumers. There is no exemption based solely on product range, company size or turnover.
Clearly Visible, but Not Necessarily on Every Product
In bricks-and-mortar retail, the harmonised warranty notice is to be made available in a prominent manner. One conceivable option is a clearly visible poster on the wall or in the till area.
For online sales, it is to be made available as a general notice on the retailer’s website. Placing it directly next to every individual product image is therefore not mandatory.
How exactly the online display must be designed has, however, not been conclusively clarified. The European Commission’s practical guidelines show various possible digital implementations, for example on product or catalogue pages, in the header or at checkout. A clearly visible short notice can appear first, with the complete harmonised notice displayed on the first click or on mouse-over.
These practical guidelines are, however, not legally binding.
The GARAN Label
The guarantee label, the so-called GARAN label, by contrast concerns only certain goods for which the manufacturer provides a qualifying commercial durability guarantee.
The obligation applies only if
- the manufacturer grants the guarantee,
- it is offered at no additional cost,
- it covers the goods as a whole,
- it runs for more than two years, and
- the manufacturer has provided the retailer with the information required for this purpose.
In principle, the retailer is not obliged to search actively for such manufacturer information.
The GARAN label is intended to show the consumer directly which specific product is covered by the special manufacturer guarantee and how long it lasts.
That is why the GARAN label – unlike the warranty notice – is product-specific.
The Directive mentions as possible placements, for example, the packaging, the shelf area or, for online sales, a position directly next to the image of the product concerned.
Warranty Notice and GARAN Label Compared
| Warranty notice | GARAN label |
|---|---|
| General information on statutory warranty law | Product-specific information on a voluntary manufacturer guarantee |
| In principle relevant to sales of goods to consumers | Only for a qualifying manufacturer guarantee |
| Need not be affixed to every product | Product-specific placement |
| Specific online incorporation not conclusively regulated | Nested online display expressly provided for |
| Content and design prescribed as binding | Content and design likewise largely prescribed as binding |
The warranty notice is therefore, in principle, a general mandatory piece of information. The GARAN label, by contrast, is added only if the conditions for a qualifying manufacturer guarantee are met.
Legal Framework
Legal Basis under EU Law
The legal basis under EU law is Directive (EU) 2024/825 (“EmpCo Directive”), which amended the Consumer Rights Directive 2011/83/EU. Art. 2 no. 5 of Directive (EU) 2024/825 inserts the new Art. 22a into Directive 2011/83/EU.
The warranty notice is based in particular on Art. 5(1)(e) and Art. 6(1)(l) of the Consumer Rights Directive in the consolidated version applicable from 27 September 2026; these provisions were reworded by Art. 2 no. 2(a) and no. 3(b) respectively of Directive (EU) 2024/825.
The GARAN label is based in particular on the newly inserted Art. 5(1)(ea) and Art. 6(1)(la) of the Consumer Rights Directive in the same consolidated version; these provisions were inserted by Art. 2 no. 2(b) and no. 3(c) respectively of Directive (EU) 2024/825.
The specific design and content of both notices are laid down by the directly applicable Implementing Regulation (EU) 2025/1960:
- Annex I: harmonised notice on statutory warranty law;
- Annex II: harmonised label for the commercial durability guarantee.
The new requirements apply from 27 September 2026.
In Germany, the corresponding information obligations for distance contracts and off-premises contracts are implemented in particular through § 312d para. 1 of the German Civil Code (BGB) in conjunction with Art. 246a of the Introductory Act to the German Civil Code (EGBGB). For bricks-and-mortar retail, the parallel requirements are found in Art. 246 EGBGB.
How Must the Notices Be Displayed?
A considerable proportion of the design requirements is clearly regulated. Differences exist, however, when it comes to specific online placement.
Design of the Warranty Notice
The design of the warranty notice is prescribed by Annex I of Implementing Regulation (EU) 2025/1960.
In principle, the wording, symbols, colours and QR code may not be altered.
In bricks-and-mortar retail, the notice may be displayed in colour or in black and white. For physical display, a minimum size of A4 applies as a general rule.
For contracts concluded via an online interface, by contrast, display in colour in RGB format is mandatory. No specific minimum size is laid down for online display.
In addition, the warranty notice must be made available “in a prominent manner”.
Unlike for the GARAN label, however, the Implementing Regulation contains no express provision on nested display for the warranty notice.
Design of the GARAN Label
The GARAN label is governed by Annex II of the Implementing Regulation.
Certain components of the label are fixed. The entries to be made are in particular the guarantee period, the manufacturer or brand, and the model identifier.
For the GARAN label too, display in colour is mandatory online.
For contracts concluded via an online interface, the Regulation expressly permits a nested or collapsed display. In that case, the complete label must already be displayed in full at the first corresponding user interaction.
On this point, the legal position is therefore clearer for the GARAN label than for the warranty notice.
What Does “in a Prominent Manner” Mean?
Questions of interpretation remain, particularly with regard to the online display of the warranty notice.
The term “in a prominent manner” is not defined in such specific terms that a particular position in the online shop can be derived from it directly.
It is therefore not conclusively settled, for example, whether the notice must be placed
- in the header,
- on the product page,
- in the basket,
- at checkout,
- as a sticky element or
- in another prominent place.
A notice placed merely in the footer, where it is easily overlooked by consumers, is likely to carry an increased legal risk.
The obvious course therefore appears to be placement in a prominent position that consumers can readily notice before concluding the contract.
Which specific design satisfies the requirements will ultimately have to be clarified by the courts.
What Does This Mean in Practice?
For retailers, this results in a different risk profile for each of the two notices.
For the warranty notice, it should first be ensured that the harmonised notice is used in the prescribed design and is made available in a way that is easily noticeable to consumers before the contract is concluded.
Those who wish to keep the legal risk as low as possible can opt for a directly visible, non-nested incorporation. At present, this is the lowest-risk option.
For the GARAN label, the position is clearer: it must be incorporated only for a qualifying manufacturer guarantee and displayed on a product-specific basis. A nested online display is expressly permitted, provided that the complete label appears at the first user interaction.
In implementation, a clear distinction should therefore be drawn between
- binding statutory and EU-law requirements,
- non-binding implementation guidance from the European Commission and
- precautionary recommendations for minimising risk.
This differentiation is particularly important for the warranty notice for as long as the specific online placement and the permissibility of a nested display have not been specified in a binding manner by case law or by further clarifications at EU level.
Conclusion
From 27 September 2026, retailers must distinguish between two different information instruments.
The warranty notice provides general information on statutory warranty rights and must be made available in a prominent manner. Content and design are largely prescribed; the specific online placement, and in particular a nested display, have, however, not been conclusively clarified.
The GARAN label, by contrast, concerns only certain goods with a qualifying free manufacturer guarantee of more than two years. It is product-specific and is subject to more specific display requirements. A nested online display is expressly permitted.
For retailers, there therefore remains a degree of design latitude, particularly with the warranty notice – but also legal uncertainty. Pending a binding clarification, it is advisable to implement the notice in a way that makes it clearly noticeable to consumers before the contract is concluded and that adopts the design prescribed by EU law without alteration.
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Frequently Asked Questions
Must the Warranty Notice Appear on Every Product or on Every Product Page?
No. The warranty notice is, in principle, designed as general consumer information. Placing it directly on every product or next to every product image is not mandatory.
Where exactly it must appear in the online shop for the information to be made available “in a prominent manner” has, however, not yet been conclusively clarified.
May the Warranty Notice Be Collapsed or Displayed via a Link?
Such a display is not clearly ruled out.
However, the Regulation contains no express permission for a nested display of the warranty notice. The European Commission’s practical guidelines, by contrast, show solutions in which a short notice appears first and the complete notice is displayed on the first click or on mouse-over.
Because the guidelines are not legally binding, a residual risk remains. A directly visible, non-nested incorporation is currently the lowest-risk option.
Where Must the GARAN Label Appear in the Online Shop?
The GARAN label is product-specific. It is intended to let the consumer see which specific product the special manufacturer guarantee applies to.
For online sales, the label is therefore intended in particular to be displayed close to the product, next to the image of the goods. Depending on how the ordering process is designed, a display at the point of ordering may also be relevant.
May the GARAN Label Be Displayed in a Nested Manner?
Yes. A nested display is expressly provided for in online distance contracts. The complete label must, however, already be displayed in full at the first corresponding user interaction.
What Applies to Second-Hand Goods with a Shortened Warranty Period?
A permissible shortening of the warranty period for second-hand goods remains possible. The harmonised notice points out that a shorter period may apply to second-hand goods under national law.
