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EU Guarantee Notice and GARAN Label: The 2026 Rules
Last updated: 1 October 2026. Reviewed against Directive (EU) 2024/825 (EmpCo), Directive 2011/83/EU as amended, Directive (EU) 2019/771 and Commission Implementing Regulation (EU) 2025/1960.
Short answer: Since 27 September 2026, traders selling goods to consumers in the EU have to show a standardised notice about the legal guarantee of conformity, in the shop and online. If the producer offers a free durability guarantee of more than two years covering the whole product, the trader also has to show a second standardised element for that product: the GARAN label. Both come from the Empowering Consumers Directive (EmpCo, (EU) 2024/825), and Implementing Regulation (EU) 2025/1960 fixes their design. The notice is general and the retailer handles it alone. The GARAN label is product specific and only works if the producer hands over the guarantee information for each qualifying model.
Two tools, two different jobs
| Harmonised notice (legal guarantee) | Harmonised label (GARAN) | |
|---|---|---|
| What it covers | The statutory guarantee of conformity, at least two years everywhere in the EU | A voluntary commercial guarantee of durability from the producer |
| Mandatory? | Yes, for traders selling goods to consumers | Only if the producer offers a qualifying guarantee and makes the information available to the trader |
| Product specific? | No. One general notice for the shop or website | Yes. Duration, producer name and model identifier per product |
| Where | Prominently, before the consumer is bound by the contract. In shops, for example on a poster near the checkout | Prominently, clearly tied to the qualifying product. In online checkouts also directly before the consumer places the order |
| QR code | Fixed, links to the EU's Your Europe portal | Fixed, links to the EU's general Your Europe information on durability guarantees, not to the producer's own terms |
The harmonised notice: every trader selling goods to consumers needs it
The notice reminds consumers of a right they already have. If a product turns out to be faulty, the seller is liable for at least two years. The consumer can first ask for a free repair or replacement. A price reduction or ending the contract only comes in under specific conditions, for example when a repair fails or isn't possible, and ending the contract isn't available for minor defects. None of this is new law. What's new is that every trader now has to show it in the same EU format.
You can't design your own version. The text, layout, colours and QR code are set in Annex I of Regulation 2025/1960 and aren't editable, so use the official template unchanged. Printed in a shop, the notice must be at least A4 and can be in colour or black and white. Online, it has to be in colour.
In Germany, the rule sits in Article 246(1) No. 5 EGBGB for physical shops and Article 246a § 1(1) sentence 1 No. 11 EGBGB for distance sales. B2B sales are out of scope. Traders based outside the EU can be covered too if they direct sales at consumers in an EU country. Whether that's the case depends on the applicable-law rules, so check it for your setup.
The GARAN label: only for real durability guarantees
For manufacturers the GARAN label is the more interesting one. It's a selling point, and you can only use it if your data is right. A producer's guarantee qualifies only if it meets three conditions:
- It lasts longer than two years.
- It covers the entire product, not just the motor or the display.
- The consumer pays nothing extra for it.
So a "5-year guarantee on the compressor" doesn't count, and neither does a paid extended warranty. You can still advertise those, just not with the GARAN label.
Most of the label is fixed: the title, the tick mark, the calendar symbol, the QR code and a reminder that the legal guarantee still applies. Three fields get filled in: the guarantee duration in years, the name of the producer offering the guarantee (in the field marked "Brand/Trademark") and the model identifier. Outside online shops, the label must be at least 95 × 100 mm and can be printed in colour or black and white. Online it has to be in colour. Online shops may use nested display: a smaller element on the page that opens the full label on the first click, mouse-over or touch.
Where the GARAN data has to come from
The trader shows the label, but only has to if the producer makes the guarantee information available. Take a retailer with 8,000 SKUs from 200 brands. For every model that carries a qualifying guarantee, they now need the duration, the producer name and the model identifier. The law doesn't prescribe a data format. In practice, though, nobody wants to type this into a shop system by hand, so an importable format is what retailers will ask for.
If you're a manufacturer, expect questions like these in retailers' supplier forms:
- Do you offer a durability guarantee over two years, free of charge, for the whole product?
- For which models, and for how long exactly?
- For goods with digital elements: how long will you provide software updates?
- Is there a repairability score? If not, what about spare parts and repair information?
The last two questions come from the same directive, which added more pre-contractual information duties. Where an EU-harmonised repairability score applies to a product, the trader has to state it. Where none applies, the trader has to pass on producer-supplied information on the availability and estimated cost of spare parts, how to order them, whether repair and maintenance instructions are available, and any repair restrictions. The software update period is also owed when the producer provides it. Smartphones and slate tablets are a good example of the first case: covered models placed on the EU market from 20 June 2025 carry an energy label with a repairability class, and the data sits in the EU's EPREL database.
If this information lives in spreadsheets and email threads, each retailer request turns into manual work. Mistakes are also expensive. A wrong duration on a GARAN label can be a misleading commercial practice, and missing mandatory information is a breach as well. In Germany that can lead to injunction claims from competitors or consumer associations (by an Abmahnung or in court) and to action by authorities.
What this has to do with the Digital Product Passport
Legally, nothing directly. The GARAN label is not a Digital Product Passport, and its QR code doesn't point to one. The notice and label come from consumer law (EmpCo). The DPP comes from ecodesign law (ESPR, Regulation (EU) 2024/1781). Different laws, different authorities.
The underlying data can overlap, though. Durability, repairability, spare parts and software support are among the product parameters ESPR names, and the delegated act for each product group decides which of them end up in that group's DPP (see our DPP timeline for the dates). A manufacturer that keeps guarantee duration, update period and repair data per model in one place can answer retailers today and reuse what fits when a DPP becomes mandatory. Keeping it in two places, one for retail and one for the passport, is how the versions drift apart.
In many companies both topics end up with whoever owns product master data in the PIM, though that varies. Electronics is a good case to watch. Covered smartphones and tablets already handle repairability data, while no product-specific ESPR delegated act or DPP deadline has been adopted for consumer electronics yet (more in DPP for electronics).
Checklist
If you sell goods to consumers (shop or online):
- Download the official notice template in your language and use it unchanged: in stores at least A4 and clearly visible, online in colour and prominently before the consumer is bound.
- Ask your suppliers which products have a qualifying durability guarantee over two years.
- For those products, show the GARAN label prominently and clearly tied to the product: next to it in the store, on the product page online and again directly before the order is placed.
- Check existing guarantee claims on product pages. Anything presented like a GARAN guarantee that doesn't qualify is a risk.
If you manufacture:
- Decide whether you want to offer a qualifying durability guarantee. It's voluntary, but from now on it shows up as a standardised EU label in EU consumer sales wherever the trader has your guarantee information.
- Store guarantee duration, model identifier, software update period and repair data as structured fields per model, not in PDFs.
- Make that data available to retailers in a format they can import.
- Keep it close to your DPP data, so you don't build the same information twice.
How dpp.cloud fits
dpp.cloud doesn't create the guarantee notice or the GARAN label. Those are retail obligations with fixed EU templates. We work on the data layer behind them: we take the product data you already have in your PIM or ERP and turn it into a structured, per-model record that becomes your Digital Product Passport. Guarantee and repair data can sit in the same record where your setup supports it. If you're about to collect this data for retailers anyway, collect it once. Book a strategy session and we'll look at which of your products are affected and what's already in your data.
Sources
- Directive (EU) 2024/825 (Empowering Consumers for the Green Transition), EUR-Lex: eur-lex.europa.eu/eli/dir/2024/825/oj
- Directive 2011/83/EU (Consumer Rights Directive), EUR-Lex: eur-lex.europa.eu/eli/dir/2011/83/oj
- Directive (EU) 2019/771 (sale of goods, legal guarantee), EUR-Lex: eur-lex.europa.eu/eli/dir/2019/771/oj
- Commission Implementing Regulation (EU) 2025/1960 (design and content of the notice and label), EUR-Lex: eur-lex.europa.eu/eli/reg_impl/2025/1960/oj/eng
- Commission Delegated Regulation (EU) 2023/1669 (energy labelling of smartphones and slate tablets), EUR-Lex: eur-lex.europa.eu/eli/reg_del/2023/1669/oj
- Regulation (EU) 2024/1781 (ESPR), EUR-Lex: eur-lex.europa.eu/eli/reg/2024/1781/oj
