Harmonised Notice and “GARAN” Label: Compliance Guide for Your Ecommerce

As from 27 September 2026, all physical and online stores will have new obligations regarding information on guarantees. Directive (EU) 2024/825 and Implementing Regulation (EU) 2025/1960 introduce two instruments: the harmonised notice on the legal guarantee of conformity and the harmonised label for the commercial guarantee of durability.

If you have an ecommerce business, it is important to know what these two instruments are, when they are mandatory and how to implement them correctly. In this guide we explain it step by step, with a final checklist to ensure you meet the deadline.

1. Legal Guarantee of Conformity vs. Commercial Guarantee of Durability

To understand the new obligations, it is essential to distinguish between two legal figures that complement each other but are different:

• Legal Guarantee of Conformity. It is a mandatory legal right that protects the consumer against lack of conformity that existed at the time of delivery of the goods and manifests itself within the legal guarantee period of minimum two years in the European Union. In this case, the seller is directly responsible and must offer free repair or replacement, or a price reduction or refund.
  
• Commercial Guarantee of Durability. It is a commitment by the producer to the consumer about the durability of the good. The producer thereby commits that the good will maintain the necessary functions and performance under normal conditions of use for a determined period.

To clearly communicate these two types of consumer protection, European legislation introduces two differentiated instruments:

• On the one hand, the harmonised notice corresponds mandatorily to the legal guarantee of conformity, functioning as a reminder of minimum legal rights.
• On the other hand, the harmonised label corresponds specifically to the commercial guarantee of durability that highlights concrete products in which the producer voluntarily offers a durability commitment.

Below, we will detail the specific characteristics and requirements of each of these two instruments as well as the new obligations that ecommerce businesses will have to comply with from September onwards.

2. The Harmonised Notice

What is the Harmonised Notice?

The harmonised notice is a mandatory informational notice designed to inform consumers about their minimum legal rights throughout the EU and prevent confusion with commercial guarantees.

What Must the Harmonised Notice Contain?

The notice must contain:

• Main elements of the legal guarantee of conformity
• Explicit reminder of the minimum legal duration of two years
• Remedial measures available to the consumer (repair, replacement, price reduction or refund)
• General reference to the fact that the legislation of the Member State may provide for a longer duration
• In the case of Spain, 3 years apply for goods and 2 years for digital content or services
• Standardised QR code that directs the consumer to the official "Your Europe" portal to consult the specific rights of each country

Where and How Should the Harmonised Notice Be Located?

According to Directive (EU) 2024/825 and Implementing Regulation (EU) 2025/1960, the harmonised notice on the legal guarantee of conformity must be placed in a prominent and clearly visible way for consumers. It should be adapted depending on whether it is a physical store or ecommerce:

1. In Physical Stores:
   • Location: Must be displayed in a visible place, for example, hanging on a store wall or placed near the checkout
   • Format: Must be at least A4 size and can be printed in colour (CMYK) or black and white
     
     
2. In Ecommerce:
   • Location: Must be included as a general reminder in a prominent way on the merchant's own website
   • Format: Must be presented in colour (RGB)

What Obligations Must My Ecommerce Comply With?

Ecommerce businesses must mandatorily include from 27 September the harmonised notice as a visible and prominent general reminder on their website.

The notice must be displayed in colour (RGB) according to the standard design set by the European Commission.

3. The Harmonised Label "GARAN"

What is the Harmonised Label "GARAN"?

The harmonised label is a distinctive designed to inform about concrete goods that have a commercial guarantee of durability.

Unlike the harmonised notice, which is always mandatory, the harmonised label is only mandatory when the following conditions are met cumulatively:

• The producer offers a commercial guarantee of durability without additional costs
• The guarantee covers the entire good and not just specific parts
• Its duration is more than two years
• The producer makes this information available to the merchant

What Must the Harmonised Label Contain?

The harmonised label must contain:

• The "GARAN" header designed and recognisable throughout the EU
• Brand or trademark to distinguish the name of the producer granting the guarantee
• Model identification: exact code or model of the product covered by the guarantee
• Duration of the commercial guarantee
• Translation of the text "producer guarantee in years" translated into all official EU languages
• Scannable QR code that redirects to the section on commercial guarantees of the official "Your Europe" portal
• Visual reminder of the legal guarantee to prevent the consumer from confusing the manufacturer's guarantee with their minimum legal rights

Where and How Should the Harmonised Label Be Located?

According to Directive (EU) 2024/825 and Implementing Regulation (EU) 2025/1960, the harmonised label for the commercial guarantee of durability must be clearly visible to consumers and its placement should be adapted depending on the sales channel:

1. In Physical Stores:
   • Location:
     • On the product or its packaging: the producer or merchant may place the label directly on the specific good or printed on its packaging
     • On the shelf: the merchant may display the label prominently on the shelf or display where products covered by the guarantee are located
       
   • Format: Can be presented in colour or black and white but must have minimum dimensions of 95 x 100 mm. If printed in a larger size, its elements must not be distorted or separated.
     
     
2. In Ecommerce:
   • Location:
     • On the product sheet: must be placed prominently directly next to the image of the specific good in the ecommerce
     • Before payment: the merchant must show the label clearly and prominently before the consumer places the order so they can make an informed purchase
       
   • Format: Must be mandatory in colour and a reduced version of the label is permitted showing the "GARAN" header, the duration of the guarantee and visual symbols. If the nested version is used, the harmonised label must appear completely on the first click or mouse scroll over the image.

What Obligations Must My Ecommerce Comply With?

Ecommerce businesses should only display the harmonised label if the producer offers the commercial guarantee of durability for a period exceeding two years, covering all the goods, and provides this information to the merchant, without the ecommerce having to actively search for it.

If you have the obligation to display the label, it must be placed in colour, prominently displayed directly next to the image of the good or at the time prior to payment.

Compliance Checklist Before 27 September 2026

To make it easier for you to adapt your ecommerce before 27 September 2026, we have prepared this compliance checklist. We recommend that you review each of these points to verify that your platform complies with the implementation of the harmonised notice on legal guarantee and the harmonised label on commercial guarantee of durability.

✅ Download the harmonised notice
✅ Place the harmonised notice clearly visible in colour on the website
✅ Download the harmonised label
✅ Check which products meet the requirements of the mandatory harmonised label
✅ Introduce the label visible only in products that meet the conditions on the website
✅ Check the correct functioning of QR codes
✅ Maintain terms and conditions that comply with European legislation and the legislation of your Member State

Conclusion

The entry into force of Directive (EU) 2024/825 and its Implementing Regulation (EU) 2025/1960 from 27 September 2026 establishes new obligations not only in physical stores but also for ecommerce businesses. In this way, with the correct implementation of the harmonised notice and the harmonised label, greater transparency is offered to consumers so they can make informed purchases.

Therefore, it is time to prepare your ecommerce website to display these instruments to comply with the new European consumer protection regulation.

However, it is not enough to display the notice and label on your ecommerce website; they must be backed up by Terms and Conditions that are consistent and updated to current applicable regulations at all times. That is why at Lawwwing we have developed software that automates your legal texts so that your website always complies with the regulations.

Frequently Asked Questions

When is the Harmonised Notice Mandatory?

From 27 September 2026, the date when Directive (EU) 2024/825 and Implementing Regulation (EU) 2025/1960 come into effect. It affects all physical and online stores selling to consumers in the EU.

Must all Ecommerce Display the GARAN Label?

No. Only when the producer offers a free commercial guarantee of durability, lasting more than two years, covering the entire product, and provides that information to the seller.

How Long is the Legal Guarantee in Spain?

Three years for goods and two years for digital content and services. The European minimum is two years, but each Member State may extend this.

Can the Harmonised Notice Be Displayed in Black and White on a Website?

No. In ecommerce it must be displayed in colour (RGB). Black and white is only permitted in physical stores.

Where Can the Official Notice and Label Be Downloaded?

The official designs are found in Implementing Regulation (EU) 2025/1960, published in EUR-Lex, along with the QR codes that link to the "Your Europe" portal. You can download them here.