Businesses supplying consumer goods into the EU should be reviewing their guarantee information ahead of new requirements taking effect on 27th September 2026.
The changes introduce a new harmonised EU Legal Guarantee Notice for consumer goods, alongside the GARAN label for qualifying commercial guarantees of durability.
For UK businesses selling into EU markets, understanding which requirements apply will depend on how products are sold, the nature of any guarantees offered and the information provided to consumers.
The measures form part of the EU's wider consumer protection framework under Directive (EU) 2024/825, with the design and content of the new notice and GARAN label established by Commission Implementing Regulation (EU) 2025/1960.
What is changing?
From the 27th September, two harmonised measures will apply:
The EU Legal Guarantee Notice
This is a standardised notice reminding consumers of their existing legal guarantee rights. It must be provided prominently before the consumer is bound by the purchase contract.
The notice highlights the EU's minimum two-year legal guarantee of conformity, while also making clear that national law may provide for a longer period.
The GARAN label
The GARAN label applies to a specific type of voluntary commercial guarantee of durability offered by a producer.
Where a producer offers a qualifying guarantee, the harmonised GARAN label must be used from 27 September 2026.
The two measures are separate, but are designed to help consumers distinguish between their statutory legal guarantee rights and any additional commercial guarantee offered by a producer.
Who needs to take action?
The requirements are particularly relevant to businesses selling consumer goods to customers in the EU.
For the Legal Guarantee Notice, the obligation falls on the seller providing the consumer with the relevant pre-contractual information. This means businesses selling directly to EU consumers through their own websites or other online channels should review how the notice will be displayed before purchase.
Businesses supplying EU distributors and retailers may not have the same direct point-of-sale obligation. However, producers should still review the guarantee information they provide to their trade customers, as retailers and distributors will need accurate information to meet their own obligations.
The European Commission also states that producers offering a qualifying commercial guarantee of durability must make the relevant information available to sellers.
What is the GARAN label?
The GARAN label is not intended to cover every manufacturer's warranty.
It applies where a producer offers a commercial guarantee of durability which:
is provided at no additional cost to the consumer;
covers the entire product, rather than only a component;
lasts for more than two years; and
represents a commitment that the product will maintain its required functions and performance through normal use for the stated period.
Where these conditions are met, the GARAN label becomes mandatory.
The producer must also provide the specific terms of the commercial guarantee, including details of what is covered, the conditions that apply and how consumers can make a claim. Where the product does not maintain the required functions and performance under the guarantee, the producer is responsible for repairing or replacing it at no cost.
The label itself has a prescribed format and includes the GARAN title, a durability symbol, the guarantee period, the producer's brand or trademark, a model identifier and a QR code linking to further information.
A five-year warranty does not necessarily mean GARAN applies
This is an important distinction for businesses reviewing their existing warranty arrangements.
A product described as having a "five-year warranty" does not automatically mean it is a commercial guarantee of durability for the purposes of the new EU requirements.
The key consideration is what the guarantee actually promises.
A commercial guarantee of durability is a commitment that the product will maintain its required functions and performance through normal use for the stated period. A warranty that is limited to particular manufacturing defects or specific components may therefore need to be considered separately.
Businesses should assess the actual terms and conditions of their guarantees rather than relying solely on terminology such as "warranty", "guarantee" or the number of years stated.
Where the position is unclear, specialist legal advice should be sought before making changes to consumer-facing claims or guarantee terms.
Marketing claims should also be reviewed
The wording used to promote a product should be considered alongside the formal guarantee documentation.
Claims such as:
"Guaranteed to last five years"
"Five-year durability guarantee"
"Guaranteed performance for five years"
could communicate a broader durability commitment than the formal warranty terms provide.
For businesses supplying products into the EU, it is therefore worth reviewing product pages, packaging, catalogues, advertising and other promotional materials alongside the relevant guarantee documentation.
The aim should be to ensure that the consumer-facing message accurately reflects the guarantee being offered and does not create confusion between a commercial guarantee and the consumer's separate legal guarantee rights.
What should UK businesses supplying the EU do now?
With the new requirements applying from 27 September, businesses should consider taking the following steps:
1. Review EU sales channelsIdentify which products are sold directly to EU consumers and which are supplied through distributors, retailers or marketplaces.
2. Review existing guaranteesCreate an overview of commercial guarantees currently offered and identify those lasting more than two years.
3. Assess whether any guarantees qualify as durability guaranteesConsider whether the guarantee is offered at no additional cost, covers the entire product and commits the producer to maintaining the product's required functions and performance.
4. Review consumer-facing informationCheck websites, product pages, packaging, catalogues, advertising and other marketing materials for claims relating to product durability or guarantee periods.
5. Prepare the required informationWhere applicable, ensure the EU Legal Guarantee Notice and GARAN label are displayed in the required format and at the appropriate point in the purchasing journey. The European Commission has published practical guidance and downloadable artwork for both. (European Union)
6. Liaise with EU trade customersProducers supplying EU distributors and retailers should ensure that their trade customers have the information they need about any commercial guarantees of durability applying to their products.
7. Seek advice where the position is unclearWhere existing warranty wording, durability claims or sales arrangements make the position uncertain, businesses should obtain appropriate legal advice.
Preparing for 27th September
The introduction of the new EU Legal Guarantee Notice and GARAN label does not mean that businesses need to reconsider every warranty they currently offer.
However, 27th September 2026 provides a clear deadline for businesses supplying consumer goods into the EU to review their existing arrangements.
For UK producers, manufacturers, brand owners and suppliers, the priority should be understanding which products and guarantees are within scope, ensuring that consumer-facing information accurately reflects the commitments being made, and working with EU trade customers where information needs to be provided further down the supply chain.
The European Commission's guidance confirms that the new requirements are intended to make the distinction between statutory legal guarantees and voluntary commercial guarantees clearer for consumers.
Further information
Members can refer to the following sources for the detailed requirements, official guidance and artwork:
European Commission: EU Legal Guarantee Notice and GARAN label
European Commission: Sustainable consumption and guarantee information
EUR-Lex: Commission Implementing Regulation (EU) 2025/1960
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