Note: This article is for information only and does not constitute legal advice. For a legally binding assessment, please consult a licensed attorney.
TL;DR
- From 27 September 2026, online merchants in the EU must prominently display the harmonised notice on the legal guarantee of conformity (the "EU warranty label") - legal basis: Regulation (EU) 2025/1960, based on Directive (EU) 2024/825.
- This checklist walks through 12 checkpoints: from scope and placement to languages, the voluntary GARAN label and the guarantee statement per § 479 BGB.
- Rule of thumb: use the official files, place prominently, match the customer's language, change nothing.
- As with the withdrawal button: the violation is visible from outside - warning-letter firms can spot it without a test purchase.
Why a checklist?
The requirements come from several sources: the regulation itself, the European Commission's practical guidelines (April 2026) and - for guarantees - Germany's § 479 BGB. The full background is in EU warranty label: mandatory from 27 Sept 2026. Here is the compact list to tick off.
Part 1: Basics (points 1-3)
☐ 1. Scope clarified. You sell goods to consumers (B2C) as a merchant - then the notice obligation applies, regardless of size, revenue or legal form. Pure B2B is not covered. The obligation also applies offline; here we focus on your online store.
☐ 2. Official files obtained. Only the official files from the European Commission may be used (RGB version for digital). Rebuilt graphics, changed colours, different fonts or an edited QR code are not permitted.
☐ 3. No modifications. No cropping, stretching, recolouring, no removing or adding elements. The label is a standardised official document - any "adaptation to the shop design" is a violation.
Part 2: Placement in the store (points 4-7)
☐ 4. Prominent placement chosen. Permitted per the EU guidelines: product catalogue/category page, website header, checkout - each as a notice sentence (e.g. "Your legal guarantee rights") that opens the full notice on first click or mouse-over. An automatic display on every product page is one of the most visible permitted variants.
☐ 5. Clickable link present. Digitally, a clickable link to the same destination as the QR code - the "Your Europe" portal - must always be available. An image alone is not enough.
☐ 6. Legibility verified. The notice must be legible at standard size - including on mobile. A tiny footer icon that only becomes readable after zooming does not serve the purpose.
☐ 7. Confirmation email covered. The guidelines state the notice should also be included in the order confirmation email. Most merchants forget this point - it belongs on the list.
Part 3: Languages (points 8-9)
☐ 8. Customer's language. The notice exists in all 24 EU official languages - and must be understandable for your customers. If you only sell to Germany, the German version is sufficient.
☐ 9. Cross-border covered. If you sell to several EU countries, you need the respective language version - a hard-coded German graphic does not satisfy the requirement for French or Polish customers. Automatic language logic (as in the EU warranty label for Shopify) removes exactly this source of error.
Part 4: GARAN label and guarantees (points 10-11)
☐ 10. GARAN only where permitted. The GARAN label is reserved for the manufacturer's durability guarantee: free of charge, covering the whole product, duration of more than two years, offered by the manufacturer. Merchant guarantees, component-only guarantees or paid guarantees must not carry the GARAN label. Fields: XX (years), brand, model - details in GARAN label explained.
☐ 11. Guarantee statement per § 479 BGB in place. If a guarantee is advertised, a guarantee statement with the statutory mandatory content is required - on a durable medium, at the latest upon delivery. What exactly belongs in it: § 479 BGB: mandatory content of the guarantee statement.
Part 5: Testing (point 12)
☐ 12. Tested end to end. Desktop and mobile: notice visible? Click/mouse-over opens the full notice? Link leads to the Your Europe portal? Switching the storefront language switches the language version? GARAN only appears on products with a registered manufacturer guarantee? Order confirmation contains the notice?
What happens if points stay open?
If the notice is missing or altered, the main risk from the effective date is competition-law warning letters - the state of compliance can be checked from outside, much like the withdrawal button per § 356a BGB, where the warning-letter scene became active quickly after the deadline. The difference: this time there is still time to prepare.
The shortcut for Shopify stores
The EU warranty label for Shopify covers the technical points of this list automatically: the official notice, unaltered, as a theme app extension (points 2-6), automatically in the customer's language across 24 EU official languages (points 8-9), the GARAN label per product with the XX/brand/model fields (point 10) and exclusion rules for B2B products. The substantive decisions (which products, which guarantees, legal texts) remain yours as the merchant - the app is a technical tool, not legal advice.
FAQ
Is hiding the label somewhere in the footer enough? No. A prominent notice is required. The guidelines name catalogue page, header and checkout as examples - each clearly visible with a click/mouse-over mechanism.
Do I need something different for used goods? The notice itself already addresses used goods (shorter period in some countries, at least one year). The same harmonised notice applies.
What if I offer no manufacturer guarantees at all? Then only the mandatory notice concerns you (points 1-9, 12). The GARAN label is voluntary and only relevant when a manufacturer provides a qualifying durability guarantee.
Further reading:
- EU warranty label for Shopify
- EU warranty label: mandatory from 27 Sept 2026 (Regulation (EU) 2025/1960)
- GARAN label explained: the EU label for manufacturer guarantees
- § 479 BGB: mandatory content of the guarantee statement
- Setting up the EU warranty label in Shopify: step by step
Primary legal sources: Regulation (EU) 2025/1960 (EUR-Lex) · Directive (EU) 2024/825 · Directive (EU) 2019/771 · § 479 BGB