From 27 September 2026, sellers of consumer goods in the EU must display a harmonised legal guarantee notice, and producers offering a commercial durability guarantee must use the matching GARAN label. This article explains what both require and who they apply to.
What is the EU legal guarantee notice and GARAN label?
Two related EU obligations come into force on the same date:
The harmonised legal guarantee notice — if you sell consumer goods in the EU, you must inform consumers of their legal guarantee rights through a mandatory, standard-format notice.
The GARAN label — if you're a producer who chooses to offer a voluntary commercial guarantee of durability beyond the legal minimum, you must use this harmonised label to represent it.
The two are designed to work together and point to each other, but they're independent. The harmonised legal guarantee notice is mandatory, the GARAN label is an add-on that's made necessary only by your producer's existing durability guarantee.
Key facts:
Both become mandatory from 27 September 2026.
The notice and the label each have a fixed design and wording that cannot be modified.
Both carry a mandatory scannable QR code linking to further consumer information, in all EU languages.
Both must be shown in colour when displayed online, and have minimum print sizes (A4 for the notice, 95 x 100mm for the label).
The legal guarantee of conformity itself is a minimum of 2 years, with the exact period varying by EU member state.
✅ The "legal guarantee of conformity" is the EU's baseline consumer protection: when you buy a physical good in the EU, it's legally guaranteed to match what was advertised and to work as expected for a minimum period after purchase — at least 2 years across the whole EU, though individual member states can set longer periods.
Who is legally responsible? You, as the seller or producer, are accountable for your own compliance with these obligations. Swap does not give legal advice — if you're unsure how this applies to your business, speak to your legal advisor.
Who does this apply to?
The harmonised notice applies to you if you sell consumer goods to customers in the EU or EEA, including via an e-commerce site.
The GARAN label applies if your producer is offering a commercial guarantee of durability that is:
at no additional cost to the consumer,
covering the entire good (not just part of it), and
for a duration of more than two years.
If your durability guarantee meets those three conditions, using the GARAN label is mandatory, not optional. If it only covers part of a product, you cannot use the GARAN label, and you must tell consumers clearly that the guarantee only applies to that part.
The harmonised legal guarantee notice
The notice highlights the main elements of the legal guarantee of conformity — most importantly, that every EU consumer benefits from at least 2 years of legal guarantee protection on consumer goods.
You must display it prominently. For an e-commerce site, this is typically a general reminder shown on the storefront (equivalent to a poster in-store or a notice at checkout for physical retail).
It informs consumers about:
how the legal guarantee period varies by EU country,
common situations where they can use their legal guarantee rights,
the solutions you, as the seller, should provide,
practical steps to seek redress,
a link to further information on guarantees.
Displaying the notice
Fixed features that cannot be changed:
a scannable QR code linking to more information, in the consumer's language,
minimum A4 size when printed,
colour or black-and-white when displayed in a physical shop,
colour only when displayed online.
The notice is available in all EU languages via the European Commission's practical guidelines, which also provide high-resolution, editable vector files.
Where brands are placing it
ℹ️ The obligation is only coming into force on 27 September 2026, so this is emerging practice. Do not treat the below as a compliance guarantee.
The notice isn't tied to an individual product, so it doesn't need to appear on every product page — it's a general, site-wide reminder. Common approaches merchants and platforms are landing on include:
A dedicated guarantee/warranty page, alongside your existing Returns and Shipping policy pages, linked from the footer.
An expandable notice, rather than a plain link — the full official notice should open on click or hover, not just be referenced in a T&Cs paragraph.
Reinforcement at checkout or order confirmation, in addition to the footer link — some legal commentary reads "prominent" as needing more than a footer link alone can offer.
A bare, inconspicuous footer link with no expandable notice behind it is risky, since it is arguably not "prominent" enough to meet the terms of the regulation.
The EU GARAN label
The GARAN label represents a commercial guarantee of durability, expressed in years, that you as a producer choose to offer beyond the legal guarantee. It's a commitment that the good will maintain its required functions and performance through normal use for the stated number of years — if it doesn't, you must repair or replace it at no cost.
You must also provide a commercial guarantee statement to the consumer, in a durable form (paper or email) no later than delivery, covering:
a clear statement that the consumer's legal right to free remedies from the seller is unaffected by the commercial guarantee,
the producer's name and address,
the steps the consumer should follow to use the commercial guarantee,
the goods covered,
the conditions of the guarantee.
As a producer, you're responsible for making this information available to the seller. You can place the GARAN label on the good itself or its packaging.
Displaying the GARAN label
Fixed features that cannot be changed:
the "GARAN" title,
a tick mark symbol for durability,
a calendar icon for years,
a visual reminder of the legal guarantee of conformity,
a QR code linking to more information, in all EU languages.
Elements a producer does customise:
the length of the durability guarantee (in years),
your brand or trademark,
the model ID, so consumers can see which products are covered.
Minimum size is 95 x 100mm when printed; it must be shown in colour online, and may use a nested/expandable display format.
If you're a seller, you must clearly display the GARAN label so consumers can see which products carry a producer's durability guarantee.
If you're unsure how these obligations apply to your business, consult your legal advisor. The above does not constitute legal advice.