When does the EU legal guarantee notice become mandatory?

27 September 2026. The artwork and the Commission's practical guidelines are already published, so there is nothing to wait for.

Who has to show the EU legal guarantee notice?

The seller, not the manufacturer. The obligation follows the trader, so it applies to a shop based in Canada or the United States selling goods to a consumer in the EU.

Can the harmonised notice be redesigned or translated by the seller?

No. Annex I of Commission Implementing Regulation (EU) 2025/1960 states that none of the elements of the harmonised notice can be edited. A redrawn or re-typeset copy is not the harmonised notice. The Commission publishes the official file in all 24 EU languages.

What is the GARAN label and does my shop need one?

GARAN marks a commercial guarantee of durability and is voluntary and conditional. It applies only where the producer offers a durability guarantee at no additional cost, covering the whole product, for longer than two years, and has made that information available to the trader. Two years or less is not a GARAN: that is the legal guarantee every EU shopper already has, and presenting it as something the shop offers is listed in Annex I of Directive 2005/29/EC as unfair in all circumstances.

The EU legal guarantee notice, and what you must do by 27 September 2026

Q: How must the notice appear on an online store?

The full notice must appear on the first mouse click, roll-over or tactile screen expansion, behind a sentence informing consumers about their legal guarantee rights. It must be legible at default display size, shown in colour, and a clickable link to the same destination as its QR code must always be available.

From 27 September 2026, traders selling goods to consumers in the EU must display a harmonised notice about the legal guarantee of conformity. Its design and wording are fixed by law and may not be altered. This page explains what the obligation actually says, who it falls on, and how it differs from the GARAN durability label, which is a separate thing that most shops do not qualify for.

The short version

What: a standard notice, drawn by the European Commission, telling shoppers they have at least two years of legal guarantee on goods sold in the EU.
Who: the seller, not the manufacturer. It follows the trader, so it applies to a shop in Canada or the United States selling to a consumer in the EU.
When: 27 September 2026.
How: prominently, online as well as in shops, using the Commission's own file without modification.

Where the rule comes from

Two instruments, and it helps to keep them apart. Directive (EU) 2024/825 amended the Consumer Rights Directive 2011/83/EU to require the information. Commission Implementing Regulation (EU) 2025/1960 then fixed what the notice looks like and what it says. So the duty to inform comes from the directive as transposed into your customer's national law, and the artwork comes from the implementing regulation.

What may not be changed

Annex I of the implementing regulation is explicit: none of the elements of the harmonised notice can be edited. Not the wording, not the colours, not the layout, not the QR code. A redrawn or re-typeset copy that merely looks similar is not the harmonised notice.

The Commission publishes the artwork in all 24 official EU languages, in colour and in black and white, as high resolution vector files, alongside its practical guidelines. Use those files.

How it has to appear online

The Commission's practical guidelines set out the online behaviour. The full notice must appear on the first mouse click, mouse roll-over or tactile screen expansion, behind a sentence that informs consumers about their legal guarantee rights. It must be legible at default display size, shown in colour, and a clickable link must always be available to the same destination as the QR code inside it, which is the Your Europe page on guarantees for the shopper's language.

In practice that means a short line of text a shopper can click, opening the notice itself. It does not mean a PDF in your footer, and it does not mean a paraphrase in your terms page.

The GARAN label is a different thing

GARAN is the second harmonised label in the same regulation, and it is where most of the confusion sits. It marks a commercial guarantee of durability, and it is voluntary and conditional. Under Article 6(1)(la) of Directive 2011/83/EU, as amended, it applies only where all of the following are true:

the producer offers a guarantee of durability for the goods,
at no additional cost to the consumer,
covering the whole product, not one component,
for longer than two years, and
the producer has made that information available to the trader.

Two years or less is not a GARAN. Every EU shopper already has at least two years of legal guarantee by law, and presenting a legal right as something your shop offers is listed in Annex I of the Unfair Commercial Practices Directive 2005/29/EC as unfair in all circumstances, with no need to show that any consumer was actually misled. That is a stricter test than it sounds.

The GARAN artwork is language-neutral, with the phrase "producer guarantee in years" printed along the bottom in every EU language, and that line may not be cut out. It carries three fields the producer fills in: the duration in years, the brand or trademark, and the model identifier. Durations are whole years, or a half year written with a comma, for example 2,5 or 4,5. No other decimal is permitted. Its QR code points to the Your Europe page on commercial guarantees of durability.

If you sell on Shopify

Nothing here requires a developer. The notice is a fixed image with defined behaviour, so the practical questions are only: is the official file being served unmodified, does it follow the shopper's language, does it open on first click, and is it actually switched on in your live theme. That last one catches people out: installing an app is not the same as enabling it.

We build Clearmark, a Shopify app that does exactly this, and it is free for the mandatory notice. We would rather you understood the obligation than bought anything: if you implement it yourself from the Commission's files, that is a good outcome.

Dates worth writing down

27 September 2026: the harmonised notice becomes mandatory.
Now: the artwork and guidelines are already published, so there is nothing to wait for.

This page explains a published EU regulation and links to the primary sources. It is not legal advice, and whether the obligation applies to your business is your decision to make. Last reviewed 18 August 2026.