Every trader selling goods to consumers in the European Union must show a standardised poster about the two-year legal guarantee from 27 September 2026, and the European Commission has spent the past five months telling companies exactly how to print it. The instrument is Commission Implementing Regulation (EU) 2025/1960, adopted on 25 September 2025 and published in the Official Journal on 2 October 2025. A companion set of practical guidelines from the Directorate-General for Justice and Consumers, dated April 2026 and registered on 27 April 2026, converts the two annexes of that regulation into placement rules covering shop entrances, checkout counters, product pages, confirmation emails, homepage banners and third-party promotional placements.

In Short

From 27 September 2026, every shop and online store selling goods in the EU has to display a standard notice explaining the two-year legal guarantee that comes with any purchase. If a manufacturer also promises its product will last longer than two years, at no extra cost and for the whole item rather than one part, it has to show a second graphic called the GARAN label with the number of years printed on it. The practical change for marketing teams is that both graphics are fixed artwork files with rules on size, colour and position, and the GARAN one may appear in an advertisement only where the product it names is genuinely covered.

Two instruments, one applicability date

The legal chain runs back further than the implementing regulation. Directive (EU) 2019/771, adopted on 20 May 2019, harmonised the rules on conformity of goods and repealed Directive 1999/44/EC with effect from 1 January 2022. Its Article 10 makes sellers liable for any lack of conformity that exists at delivery and becomes apparent within two years. Article 11 presumes that a defect appearing within one year already existed at delivery, with member states free to extend that presumption to two years. Article 17 governs commercial guarantees, and it is the provision that gives the durability label its legal weight.

Directive (EU) 2024/825 of 28 February 2024 amended the Consumer Rights Directive 2011/83/EU and the Unfair Commercial Practices Directive 2005/29/EC. It inserted Article 22a, which required the Commission to specify the design and content of a harmonised notice and a harmonised label. Recital 16 of the implementing regulation ties the timing together: member states apply the measures transposing Directive (EU) 2024/825 from 27 September 2026, so the regulation becomes applicable on the same day. Both texts are marked as carrying EEA relevance.

The two graphics do different jobs. According to Implementing Regulation (EU) 2025/1960, "The harmonised notice is a mandatory notice at the point of sale", while the label represents a voluntary commercial guarantee of durability offered by producers who want to reassure buyers about how long a good will last. The regulation also records that the Commission consulted representative stakeholder groups and ran a field test with representative consumer groups before settling the final design.

Inside the harmonised notice

The harmonised notice carries the words LEGAL GUARANTEE across a blue or black header, a shield logo containing the letter G ringed by the European stars, and four blocks of body text. It states the minimum two-year protection for goods sold in the European Union, lists two situations in which consumers can claim, names free repair and free replacement as the first remedies, and adds price reduction or full reimbursement in some cases. A side panel notes that some countries apply a longer period and that second-hand goods may carry a shorter one, but not less than one year. A two-step instruction block covers contacting the seller and providing proof of purchase. At the foot sits a cross-reference to the GARAN label.

Nothing in it may be edited. The guidelines list the prohibitions in visual form: no altering or deleting the border line or inner separator, no colour changes or filters, no spacing or alignment changes, no typography substitutions, no moving or resizing the QR code, no cropping or stretching, and no added elements, icons or text. The reference palette is fixed at Pantone Reflex Blue C, hex #003399, Pantone Yellow C, hex #FFED00, Pantone Black 6 C and Pantone 000C.

Sizes and viewing distance

Print versions use CMYK and may not run below A4, which measures 210 by 297 mm. Three larger formats are available: A3 at 297 by 420 mm, A2 at 420 by 594 mm and A1 at 594 by 841 mm. The guidelines attach a recommended viewing distance to each. A1 suits 2 to 3 metres and large retail floors with high walls. A2 covers 1 to 2 metres. A3 is built for 0.5 to 1 metre. A4 is intended for 0.3 to 0.5 metres, described as appropriate for kiosks and compact interiors. Suggested placements include the entrance door, a poster on a wall or aisle, and the store counter.

Online placement

Digital display uses the RGB colour version, must remain legible at default display size, and must be accompanied by a clickable link pointing to the same destination as the QR code. That destination is language-specific. The guidelines publish a table of 24 addresses on the Your Europe portal, from europa.eu/youreurope/guarantees in English to europa.eu/youreurope/reklamationsrätt in Swedish and europa.eu/youreurope/virhevastuu in Finnish.

Three online patterns appear in the document. On a product catalogue page, a line such as "Your legal guarantee rights" can trigger the full notice on the first mouse click or roll-over. The same mechanism is illustrated in a website header and again on the checkout page, where a mock-up shows the prompt placed beside the shipping and payment fields. The guidelines also state that the notice should appear in the order confirmation email, citing the 2021 Commission guidance on Directive 2011/83/EU and its section on confirmation of the contract.

The GARAN label

The EU GARAN label is language-neutral by design. Its title combines the word GARAN, chosen because it resembles the word for guarantee in several EU languages, with a tick-mark symbol. A shield logo repeats the legal guarantee reminder from the notice. A calendar icon marked 365 sits beside a large numeral. A QR code points to the Your Europe page at europa.eu/youreurope/commercial-guarantee-durability/index.htm. Across the bottom runs the phrase "producer guarantee in years" rendered in all 24 official languages, from Bulgarian through to Swedish, a block the guidelines describe as an integral part that cannot be omitted or cut out.

Three fields are editable and only three. The letters XX are replaced by the duration in years. Brand/Trademark is replaced by the producer name. Model identifier is replaced by the model the guarantee covers. The duration must be a whole number, with one permitted exception: half years may be shown as 2,5 or 4,5, with a comma as the decimal separator. Values such as 4,1 or 4,2 are explicitly not permitted, a restriction the guidelines justify on comprehension grounds.

Eligibility is narrow. The label may be used only where the commercial guarantee of durability is offered by the producer, at no additional cost, covering the entire good rather than a component, and for a duration of more than two years. Directive (EU) 2019/771 defines durability as the ability of goods to "maintain their required functions and performance through normal use". Where those conditions are met, the arrangement stops being optional. According to the Commission's Your Europe portal, "use of the GARAN label is mandatory" once a producer offers a qualifying guarantee.

Printed labels may not fall below 95 by 100 mm. At that minimum, the regulation fixes the translation block at 7 pt, the brand and model identifier fields at 9 pt and the numeral representing years at 80 pt. The typeface is Inter in Regular, SemiBold and ExtraBold. The QR code must stay scannable under normal lighting with a standard mobile device and, according to the practical guidelines, should never be smaller than 2 by 2 cm. Physical placements listed include the shelf beside the product, the exterior of the main packaging, and a hang tag or adhesive label attached to the item, which the guidelines note is useful for unpackaged goods. Including the label inside the package alongside the commercial guarantee statement is described as good practice.

Online, the full label may be reached through a compact graphic the guidelines call the nested label, showing only the numeral, the GARAN wordmark and the shield. It has one editable element, the duration. It must expand to the full label on first mouse click, roll-over or tactile screen expansion, and it cannot be printed or used in a physical environment. Product pages may carry the label as part of a product image, as a standalone image in the gallery, inside the product description or in nested form. Where it appears on a product photograph, the image should open in a larger zoomable view. The label should also be shown immediately before order placement at checkout, and included in the confirmation email.

Where the rules reach advertising

Section 3.4 of the guidelines is the part that lands directly in media operations. It states that the label can be shown in homepage banners, product carousels, emails, third-party placements, video, printed flyers and leaflets, both online and offline. Two constraints follow. The label may appear only where the product it accompanies is genuinely covered by a qualifying producer guarantee. And where several products share a layout, such as a banner carrying multiple items, the guidelines direct users to avoid presentation that could suggest every product is covered unless that is the case.

That second rule is a creative-template problem rather than a legal-department problem. Multi-product banners, dynamic carousels and retail media units assemble themselves from feeds at serve time, and a badge placed at unit level rather than item level would breach the condition without anyone deciding to breach it. The guidelines also permit other commercial guarantees, provided they do not create confusion with the durability guarantee the GARAN label signifies. The Your Europe page gives the sharpest illustration: a durability guarantee covering only part of a product cannot carry the label, and consumers must be told clearly that the promise applies to that part alone.

Directive (EU) 2019/771 adds a further exposure. Article 17(1) provides that where the conditions set out in a commercial guarantee statement are less advantageous to the consumer than those in the associated advertising, the advertising terms bind the guarantor, unless the advertising was corrected before the contract was concluded in the same or a comparable way. Creative copy is therefore not decorative around a guarantee. It is capable of setting the terms.

What sellers must do, and one thing they must not

Obligations split cleanly. Only sellers carry a duty in respect of the notice, and the guidelines give them latitude on how to achieve prominence. On the label, producers may decide voluntarily to offer a qualifying durability guarantee, must then make that information available to the seller, must set out the exact terms in the commercial guarantee statement, and may place the label on the good or its packaging themselves. Sellers must display the label prominently so that buyers can identify which specific goods are covered, and must keep it clearly visible.

One instruction cuts against the instinct of any retail operations team. According to the practical guidelines, "Sellers should not actively seek such information from the producer", with searching product-specific websites given as the example. Responsibility for pushing durability data down the chain sits with the producer, not with the retailer scraping it back up.

The commercial guarantee statement itself has five mandatory components under Article 17(2) of Directive (EU) 2019/771: a clear statement that free remedies remain available from the seller by law and are unaffected by the commercial guarantee, the name and address of the guarantor, the procedure for invoking the guarantee, the designation of the goods covered, and the terms. It must reach the consumer on a durable medium no later than delivery, expressed in plain and intelligible language. Where a producer offers such a guarantee, Article 17(1) makes that producer directly liable to the consumer for repair or replacement throughout the guarantee period.

Why this matters for the marketing community

European digital advertising reached 131.1 billion euros in 2025, with retail media among the two formats driving growth. A large share of that spend renders product creative assembled from catalogue data, which is precisely the layer the GARAN rules touch. Feed-driven compliance obligations are already routine in the region. Google's Merchant Center specification carries European energy labels through EPREL codes with the European Commission named as issuing authority, and from 30 September 2026 pickup cost and minimum order value become mandatory attributes across the EEA, Switzerland and the United Kingdom. The GARAN label introduces a third data point with the same characteristics: producer-supplied, product-specific, and legally consequential if rendered against the wrong item.

The regulation stops short of specifying how that data should travel. It fixes artwork and placement, not feed schemas. No attribute exists in the major shopping specifications for durability guarantee duration, which leaves the mapping between a producer's guarantee terms and a rendered badge to be built internally or through feed management vendors. Producer-facing obligations that reach retail listings are not unprecedented, since extended producer responsibility schemes already attach end-of-life costs to whoever places a product on a market, with effects reaching listings, feeds and print advertising.

The compliance pattern is also familiar. The Commission published free labelling icons in vector formats ahead of the AI Act transparency deadline in August 2026, and Google subsequently shipped an AI label setting across five advertising platforms while declining to guarantee that the setting satisfies any particular law. The guarantee files follow the same route: high-resolution vector artwork in JPG, SVG and PNG, published on the Commission's website for producers to edit in standard design software, with the editable fields the only permitted change.

Timing compounds the load on European retail teams. Google removed free shopping listings across the EEA over two days in September 2026 on Digital Markets Act grounds, reshaping the surfaces through which product data reaches shoppers in the same month the guarantee rules begin to apply. The broader consumer file has not settled either. A Digital Fairness Act remains in preparation covering manipulative practices, unfair pricing, influencer marketing and digital subscriptions, and IAB Europe and allied trade bodies objected to the scope of its consultation in July 2025, arguing that existing instruments already cover the ground. Implementing Regulation (EU) 2025/1960 is a narrower thing than that debate, but it arrives first, and it arrives with a fixed date.

One open question sits in the regulation itself. Recital 15 states that the Commission may review and adapt the durability label in light of future uptake, how consumers understand it and the implementation of other Union instruments. Whether the label becomes a recognised shorthand in European product advertising or a rarely used graphic will depend on how many producers conclude that a guarantee longer than two years, covering the whole good and costing the buyer nothing, is worth the commercial advantage the label confers. The definition of a consumer as a natural person acting outside a trade, business, craft or profession decides who the whole apparatus is built for, and it excludes business-to-business sales entirely.

Timeline

Summary

Who: The European Commission, through its Directorate-General for Justice and Consumers, addressing every seller of consumer goods in the European Union and every producer choosing to offer a durability guarantee. National consumer authorities enforce the transposed rules.

What: Commission Implementing Regulation (EU) 2025/1960 fixes the design and content of a mandatory harmonised notice on the legal guarantee of conformity and a harmonised EU GARAN label for the commercial guarantee of durability. Practical guidelines issued in April 2026 specify sizes, colours, typography, QR code behaviour and placement across physical shops, product pages, checkout flows, confirmation emails, banners, carousels and third-party placements.

When: Adopted 25 September 2025, published 2 October 2025, applicable from 27 September 2026, the same date member states apply their measures transposing Directive (EU) 2024/825.

Where: All 27 member states, with both instruments marked as carrying EEA relevance, covering physical retail and distance contracts concluded through an online interface.

Why: Directive (EU) 2024/825 set out to make consumers more aware of their guarantee rights at the point of sale and to stimulate demand for and supply of more durable goods. The notice raises awareness of the statutory two-year minimum. The label gives producers a standardised way to signal a longer commitment, with the conditions and the artwork fixed centrally so the claim means the same thing in every market.