Guide to EU Legal Guarantee Notice & GARAN Label

Regulation (EU) 2025/1960 introduces two guarantee notices starting from 27 September 2026. A harmonised notice must be displayed in all physical and online stores selling consumer goods from this date. It informs consumers of their 2 years of legal guarantee protection.

If you provide a voluntary guarantee beyond 2 years, then you also need to provide a product-specific GARAN label.

• A 2-year legal guarantee protection is required for consumer products
• The EU legal guarantee notice is mandatory when selling consumer products
• The GARAN label is optional (only if an extended guarantee is offered)

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Overview

	EU Legal Guarantee Notice HARMONISED NOTICE ON THE LEGAL GUARANTEE OF CONFORMITY	GARAN Label HARMONISED LABEL FOR THE COMMERCIAL GUARANTEE OF DURABILITY
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Mandated by	Directive 2011/83/EU – Article 22a(1)	Directive 2011/83/EU – Article 22a(1)
Design	Regulation (EU) 2025/1960 – Annex I	Regulation (EU) 2025/1960 – Annex II
Purpose	Informs the consumer that they have the right to 2 years of legal guarantee for any consumer goods sold in the EU	Specifies a (voluntary) additional guarantee expressed in years for a particular product
Date	27 September 2026	27 September 2026
Who is responsible	Seller of consumer goods in the EU	‘Producer’ means a manufacturer of goods, an importer of goods into the Union or any person purporting to be a producer by placing its name, trade mark or other distinctive sign on the goods; Note: May still be displayed by sellers
Required	Yes – Mandatory notice at the point of sale	Voluntary – Offered by producers who wish to assure consumers of the durability of their goods
Scope	Any consumer goods sold in the EU	Any consumer goods sold in the EU
Product specific	No – Provides general information only	Yes
Required edits	None identified	1. Specify length of guarantee in years 2. Specify your brand or trademark 3. Specify the model ID for the covered product
Printed version	Placement: Poster or near counter Minimum size: A4 Colour: Colour or black and white	Placement: On product or packaging Minimum size: 95 x 100 mm Colour: Colour or black and white
Digital version	Placement: Website image Minimum size: Not found Colour: Required (not black and white)	Placement: Website image Minimum size: Not found Colour: Required (not black and white)

Background

Do we need to provide a 2-year guarantee for all consumer products sold in the EU?

Yes, but there are conditions that can be found in Article 5 of Directive (EU) 2019/771.

Article 5 – Conformity of goods

The seller shall deliver goods to the consumer that meet the requirements set out in Articles 6, 7 and 8, where applicable, without prejudice to Article 9.

Note that this specifically requires that sellers must deliver goods that are in a certain condition. It does not state that goods must be indestructible or that you must provide unconditional returns, repairs or refunds just because your customers ask for it.

The specific conditions that must be met are defined in Articles 6, 7, and 8:

Article 6 – Subjective requirements for conformity

Article 7 – Objective requirements for conformity

Article 8 – Incorrect installation of the goods

Do we need to replace any consumer product that breaks within 2 years?

No, the 2-year guarantee does not mandate that any product that breaks within 2 years must be replaced, repaired, or refunded. Here are scenarios when this can become a requirement:

1. The product does not match the description

2. Quality standard differs from advertising

3. Not fit for the purposes for which goods of the same type would normally be used

4. The product quality and performance do not match what is considered normal for the product type

5. The product was installed incorrectly due to insufficient or non-existent user instructions

This does not mean that a company selling toilet paper must provide an unconditional money-back guarantee valid for 2 years. Nor does it mean that you are expected to sell products that are indestructible.

But if you sell, for example, a quartz watch that falls apart after 6 months of normal use, then the customer could ask for a replacement or other measure.

The EU market has been flooded with low-cost items for a long time, and this puts pressure on sellers to improve general product quality and be honest with product descriptions.

At the same time, I can understand that a two-year window can be problematic from a seller’s perspective too. It can be hard to prove what “acceptable” quality is, and there is also a risk that some consumers could abuse this right.

EU legal guarantee notice (harmonised notice)

Who is responsible for providing the EU legal guarantee notice?

Companies selling consumer products within the EU or to consumers in the EU. A seller could be the brand owner, or a retailer (online or offline) reselling the same product.

What is an EU legal guarantee notice?

The EU legal guarantee notice, or harmonised notice, is a general notice that must be displayed in physical stores or online stores. Its purpose is to inform the consumer of their 2-year guarantee right for consumer products.

It is not product-specific, but applies to consumer products in general.

Is the EU legal guarantee notice mandatory?

Yes, the EU legal guarantee notice is required when selling “ any consumer goods sold in the EU”, both in physical and online stores.

Which products require an EU legal guarantee notice?

The EU guidance page states that the guarantee applies to “any consumer goods sold in the EU”.

Which products are exempt?

We cannot find any exemptions.

GARAN label

Who is responsible for the GARAN label?

The producer, which is defined as follows in the Sale of Goods Directive (EU) 2019/771:

‘Producer’ means a manufacturer of goods, an importer of goods into the Union or any person purporting to be a producer by placing its name, trade mark or other distinctive sign on the goods;

This makes sense, as stores generally do not provide a warranty.

What is a GARAN label?

The purpose of the GARAN label is to inform your consumers when you offer a voluntary guarantee for consumer products beyond the mandatory 2 years.

Are GARAN labels mandatory?

Only if you choose to offer an extended guarantee beyond 2 years. When you do so, you must also provide your consumers with a commercial guarantee statement.

Which products require a GARAN label?

We can only find that the GARAN label is required for consumer products, and only if you choose to provide an extended guarantee.

Which products do not require a GARAN label?

We cannot find any exemption.