EU Legal Guarantee Notice and GARAN Label for Online Shops

Since 27 September 2026, online shops selling goods to consumers have been required to clearly display the official EU legal guarantee notice. Some products also require the GARAN label, but only where the producer offers a free commercial guarantee of durability covering the entire product for more than two years. This article explains the difference, shows a suggested online presentation and lists the information retailers need to prepare.

The new rules distinguish two pieces of information that are easy to confuse. The legal guarantee notice explains the consumer's rights against the seller when goods do not conform to the contract. The GARAN label concerns a specific additional, voluntary commercial guarantee of durability offered by the producer. Neither replaces the other.

 

Who do the rules apply to?

These rules apply to sales of goods to consumers (B2C). An online shop that sells to both consumers and business customers applies them to its consumer sales. Where goods are sold exclusively to business customers (B2B), these consumer information duties do not apply to those sales.

The general notice is required even if the shop has no products that qualify for the GARAN label.

1. Legal guarantee notice: information for the whole online shop

Customers must be informed through the complete official EU notice. When displayed online, it must be in colour; its wording and design must not be changed. An English-language shop should use the English version of the notice. The notice explains that consumers across the EU have at least two years of legal guarantee protection and points them to further information about their rights.

We suggest placing a clearly visible “Legal guarantee notice” link on the final checkout step, directly next to the “Place order” button. Clicking or tapping the link opens the complete official notice, so the customer can read it before submitting the order. An additional link in the website footer makes it easy to find outside checkout. We would also make the EU page referenced by the notice's QR code clickable.

 

Example of where the link can appear at checkout. The panel on the right shows the official notice after opening it. The final design is adapted to each project.

 

Mobile example: the link appears immediately before the order button and opens the official notice when tapped.

2. GARAN label: only for products that qualify

GARAN is the official EU label for a free commercial guarantee of durability offered by the producer that covers the entire product and lasts more than two years. The producer must also make information about that guarantee available to the seller.

The label is therefore not displayed automatically on every product described as having a “warranty”. It does not apply to a paid extended warranty, a guarantee covering only one part of a product, such as its motor, or a guarantee offered solely by the seller. A statement such as “2-year warranty” is not enough on its own to justify the GARAN label.

For each qualifying product, the label must identify the specific model. The official template is completed with the producer's brand or trademark, the model identifier and the guarantee duration in years. The “5” in our illustration means a five-year commercial guarantee of durability from the producer, not five years added to the legal guarantee.

We recommend displaying the label on the product page so customers can see it while choosing an item. Before the order is placed, the GARAN label must be clearly shown for each qualifying product. The law requires information through the label before the order, and the European Commission's guidance expressly refers to the final checkout stage. The exact position on the checkout page is not prescribed. The official compact label may be used if it opens the full label when selected. Online, the label must be in colour. If no products qualify, GARAN is not displayed.

 

Illustrative example for the fictional brand PRIMJER and model K-500. The label is based on the European Commission's official template; real products must use the producer's details and terms. GARAN does not replace the statement setting out the commercial guarantee's terms.

 

Mobile example: the compact label next to the product opens the complete GARAN label.

On the final checkout step, we can place the label in the order summary directly below each qualifying item. Selecting it opens the full label. The general legal guarantee notice remains a separate link beside the order button.

 

Illustrative example: GARAN appears beside the qualifying item; other items do not carry the label.

 

Mobile example: GARAN appears beside the qualifying item, while the general notice remains next to the order button.

What about the order confirmation email?

The prescribed information must also be provided to the consumer on a durable medium, unless it was already supplied in that form before the contract was concluded. The law does not require email to be the only channel.

For an online shop, we suggest including the official notice and any applicable GARAN label in the email confirming the concluded contract, either in the message or as attachments. The delivery method should fit the existing order and ERP process. A later invoice and the producer's guarantee documents serve separate purposes.

What information do we need from the retailer?

Before enabling GARAN, we need to identify which products actually qualify and where reliable product data will come from:

  1. Are there any qualifying products? The answer may be “yes”, “no” or “we are not sure”. If this has not been confirmed, it needs to be checked with the producer.
  2. Where is the information currently stored? Can the ERP send an already completed official label as an image? Does it send the duration and other details, or would those need to be entered in the shop's administration?
  3. Who will maintain it? Responsibility for new products and changes to guarantee terms needs to be agreed.

For qualifying products, we need the shop's product code, brand, exact model identifier, guarantee duration in years, and the available producer's terms or confirmation. If the producer already supplies a completed GARAN label, please send that as well.

What happens next?

The notice, label and order confirmation content are adapted to each online shop. Once the producer's details have been checked, we will decide whether GARAN should be imported from the ERP or maintained on each product in the shop's administration. We will review the final display on the product page and immediately before the order is submitted.

Sources

This article describes a proposed online shop adaptation for information purposes and does not constitute legal advice.