EU warranty label & guarantee label from 27 September 2026: mandatory for online retailers

Since 27 September 2026, all B2C online retailers must show an EU-harmonised legal-guarantee label – similar to the familiar energy label, but for the statutory warranty (Gewährleistung). The basis is EU Directive 2024/825 (new Art. 22a of the Consumer Rights Directive); the exact design is set by Commission Implementing Regulation (EU) 2025/1960. So it's no longer just about the „fine print" in your legal texts, but a visible label in your shop.

There are two different labels

1. The legal-guarantee label – always mandatory. It points to the statutory warranty of at least two years. Since it's the same for all products in the shop, a global, clearly visible display is generally enough. For used goods, where you contractually shorten the period to one year, be careful when using the label – the standard wording („at least two years") can be misleading there.

2. The „GARAN" guarantee label – in one case only. It must be shown additionally when the manufacturer grants a durability guarantee of more than two years. This label is product-specific: it contains brand, model and guarantee duration – so you need it per affected product, not once globally. Pure seller guarantees or „satisfaction guarantees" don't trigger the duty.

Where exactly does the label go?

This is the point that unsettles many – here is the EU Commission's answer:

Legal-guarantee label: it is a general notice and need not appear on every single product. In the online shop, a clearly visible general notice on the website is enough (online the label must be in colour). In a physical shop, e.g. a poster on a clearly visible wall or next to the till suffices – there also in black and white, printed at least DIN A4.

GARAN label: this belongs to the specific product, because it carries brand, model and guarantee duration – so in the online shop, clearly visible in the description of the affected item. A nested display (small at first, the full label on click or hover) is permitted, as with the energy label.

In both cases: prominently, in the correct language version and with a scannable QR code.

Here's what it actually looks like: on its official page Legal-guarantee notice and GARAN label (Your Europe) the EU Commission shows both labels as images including placement examples – available in all EU languages. The binding templates to download are provided by the Commission under Sustainable consumption / harmonised notice and label. Important: the templates may not be altered.

If the marketplace does not show the label

If you sell through a marketplace, you are usually liable yourself for a missing label, even if the marketplace made the mistake. That is the assessment of Händlerbund, a German retailers' association, on 29 September 2026. If the marketplace does not show the label, two options remain: take the listings offline until the marketplace fixes it, or accept the risk of a warning letter (Abmahnung). According to Händlerbund, damages from the marketplace are hard to enforce, because its terms usually exclude liability.

Two practical tests from 29 September rate the marketplaces differently on the deadline day:

Whether a display that appears only after a click is enough is still open. Händlerbund calls the interim solutions by no means optimal or compliant. Carsten Föhlisch, a lawyer at Trusted Shops, on the other hand considers a descriptive link in the header or footer of the page sufficient. Check your listings regularly in the view your customers see.

The underestimated trap

Anyone who shows the GARAN label is also advertising the guarantee – and thereby triggers the existing guarantee information duties (name and address of the guarantor, territorial scope, guarantee conditions). This is exactly where countless warning notices have been issued in the past. The previously common tactic of simply concealing a manufacturer guarantee therefore no longer works as of 27 September. And: missing or faulty labels count as an actionable competition violation (abmahnbar).

What's worth doing now

Check which items have a manufacturer durability guarantee over two years – only there does the more elaborate GARAN label apply. The obligation has applied since 27 September 2026. If you have not implemented it yet, do it now; with many affected products this isn't done „overnight". The label is one of several 2026 duties, such as the right to repair and the PPWR packaging rules from 12 August.

Note: This article does not constitute legal advice and was first published on 29 June 2026 and last reviewed on 30 September 2026. The design and language versions of the labels are fixed by Implementing Regulation (EU) 2025/1960.

Sources

• Händlerbund: practical test of the marketplaces on the deadline day, 29 September 2026
• Händlerbund: label missing on marketplaces, who is liable, 29 September 2026
• wortfilter: marketplace test and Trusted Shops assessment, 29 September 2026
• IT-Recht Kanzlei: New warranty and guarantee labels from September 2026
• Your Europe (EU Commission): Legal-guarantee notice and GARAN label
• Händlerbund: New EU label 2026 – what online retailers need to know More guides on obligations, deadlines and invoicing for small businesses are available at office1.cloud.