If you sell physical products to consumers anywhere in the EU, two new requirements are on the way that will affect your business. 

From September 2026, every EU Member State will require sellers to display a standardised Harmonised Notice about consumer guarantee rights. And where producers offer longer durability guarantees, a new label called GARAN must appear alongside the product.

These requirements come from the Empowering Consumers for the Green Transition (ECGT) Directive, which added new rules to the existing Consumer Rights Directive. The European Commission then set out the exact design and content of both tools in Regulation (EU) 2025/1960, which took effect on the same date.

Here's what you should know about complying with the new EU guarantee notice and label.

‍How do consumer guarantee rules currently differ across the EU?

EU law has long required a minimum two-year legal guarantee on consumer goods. But Member States have always been free to go further, and many have — which means the rules you're working with can look very different depending on which market you're selling into.

For example: 

• Spain extended its legal guarantee to three years in January 2022, making it the longest mandatory guarantee period among major EU economies.
  
  
• France has stuck with two years, but the burden of proof sits with the seller for the full duration. If a defect appears at any point within those two years, it's presumed to have been there at delivery, and it's on the seller to prove otherwise.
  
  
• Germany takes a different approach: the standard period is two years, but for second-hand goods, sellers and buyers can agree to reduce that to one year.
  
  
• Ireland doesn't specify a fixed guarantee period at all. Instead, consumers have a six-year limitation period in which they may be able to bring a claim, depending on the circumstances.
  
  
• In the Netherlands, the guarantee isn't tied to a set number of years either. It's assessed based on what a consumer could reasonably expect given the product's price, type, and expected lifespan.

For businesses selling across borders — particularly through Amazon, other e-commerce platforms, or your own online shops — keeping track of these variations is a headache. The new notice and label are the EU's answer to that inconsistency, at least when it comes to what consumers see at the point of sale.

‍Who is in scope for the new Guarantee Label and Notice?

Both requirements generally apply when businesses sell physical products directly to consumers. However, as the scope follows the Consumer Rights Directive, there are limited exceptions, including foodstuffs, healthcare contracts, and vending machine sales.

These rules can also affect non-EU businesses — including UK companies — who sell physical products directly to consumers in EU member states through websites or online marketplaces. 

If your business only sells B2B, these requirements won't affect you. But if any part of what you do involves selling physical products directly to consumers in an EU member state, you'll need the notice in place and may need to display the GARAN label by September 2026.

‍The Harmonised Notice: a mandatory reminder for all sellers

The Harmonised Notice is a standardised poster or banner that reminds consumers about their legal guarantee of conformity — the minimum two-year protection that applies across the EU under Directive (EU) 2019/771.

The legal guarantee of conformity already exists across the EU. What's new is the requirement to actively remind consumers about it, using the same format in every member state.

Every seller of tangible consumer goods in the EU must display this notice. In a physical shop, that means putting it up in a prominent spot: by the checkout or on a wall, somewhere customers will see it, at a minimum A4 size. For online sellers, it needs to appear clearly during the purchasing journey.

A few other details to keep in mind:

• The notice must be in the language of the Member State where you're selling
• Nothing on the notice can be changed; the design and wording are fixed.
• It comes in colour and black-and-white versions, though online it must be in colour
• The notice includes a QR code linking to the Your Europe portal, where consumers can read more about their rights

‍The GARAN label: For producers offering durability guarantees

The GARAN label (named to echo the word “guarantee” across several EU languages) is tied to voluntary commercial guarantees of durability offered by producers. It only applies when a producer offers a free commercial durability guarantee covering the entire product and lasting longer than two years. When those conditions are met, the label must be displayed.

Businesses can still offer their own warranties or extended guarantees alongside the new EU rules. But the GARAN label is not intended for every type of warranty or after-sales promise, so check carefully whether your existing guarantee arrangements actually qualify. 

‍What goes on the GARAN label

The GARAN label includes both fixed and customisable elements. Producers can fill in the number of years covered, along with their brand or trademark and a model identifier. Everything else must remain as provided on the label: the GARAN title, a reminder about the legal guarantee, a QR code linking to the Your Europe portal, a calendar icon denoting years, and translations of “producer guarantee in year” across all EU official languages.

In physical shops, the label can be printed in either colour or black-and-white. For online sales it must be displayed in colour, but there's a compact “nested” display format designed for product listing pages where space is tighter.

‍Who is responsible for displaying it?

If a producer offers a qualifying durability guarantee and provides the relevant information to the seller, the seller is required to display the GARAN label. It should go somewhere consumers can easily connect it to the right product: on the packaging, on the shelf beside it, or next to the product image online.

However — and this is a welcome clarification from the ECGT Directive — retailers are not expected to independently investigate whether qualifying guarantees exist. The obligation is on the producer to make the information available to you. 

One thing to keep in mind if you already offer your own warranty or after-sales service: producers and sellers are free to continue doing so alongside the GARAN label, but the information you provide about those other guarantees must not create confusion about the existence or duration of the durability guarantee. The GARAN label needs to stand on its own without being muddied by competing claims.

‍Timeline and next steps

Member States were required to transpose the ECGT Directive into national law by 27th March 2026. The new notice and label will then become mandatory on 27th September 2026.

The European Commission has also indicated that an online tool is in development to help producers and retailers generate the notice and label. That's expected sometime in Q2 2026. In the meantime, the downloadable templates and practical guidelines are already live on the European Commission's website. 

For the Harmonised Notice, the vector files are available in all 24 EU languages. For the GARAN label, templates are available in colour, black-and-white, and nested display formats.

Now is a good time for businesses to review product pages, checkout flows, packaging, and marketplace listings ahead of the September 2026 deadline — especially where longer-term producer guarantees are already being advertised.

‍If you'd like help understanding how the EU guarantee notice and label apply to your products or e-commerce setup, get in touch with our team. We're always happy to talk it through.