01 - The Brief
From 27 September, every EU B2C seller must show a standardized legal-guarantee notice
A new EU-wide requirement takes effect on 27 September 2026: any business selling goods to consumers in the EU must prominently display a harmonized notice informing shoppers of their legal guarantee rights, the statutory minimum two-year guarantee that products must match their description and work as intended. It's set out in Commission Implementing Regulation (EU) 2025/1960, under the Empowering Consumers Directive. This applies to online shops and physical stores alike.
The wording and design are fixed, and it applies to non-EU sellers
This isn't a "write your own returns policy" rule. The notice has a fixed form set out in the regulation: sellers display it unchanged, translated into the language of the market, and it includes a QR code directing consumers to country-specific rights information. And like the other EU rules we've covered, it reaches businesses outside the EU, US, UK and other non-EU sellers directing sales at EU consumers are in scope, with no exemption based on company size or turnover.
It has to be visible before purchase, not buried in your terms
The notice must appear prominently, before the consumer is bound by the contract, meaning on the product page or in the checkout flow, not hidden in a linked terms-and-conditions page. For online sellers, this is a concrete, product-page-level change to make across the catalogue, which is why it's worth starting now rather than the week before the deadline.
02 — The Deep Dive
What the new guarantee notice requires, how it differs from today, and how to be ready before 27 September
Consumers in the EU have long had a legal guarantee (often called a statutory warranty): the right to a remedy if goods don't match their description or don't work as they should, for a minimum of two years. What changes on 27 September 2026 isn't the right itself, it's that sellers must now actively and uniformly tell consumers about it, using a standardized notice they can't reword or restyle. It's a presentation-and-transparency obligation layered on top of rights that already existed.
What's actually required
The obligation comes from Commission Implementing Regulation (EU) 2025/1960, which sits under the Empowering Consumers Directive (Directive (EU) 2024/825). It defines two distinct elements. The first, and the one that applies to essentially every B2C seller, is a harmonized notice of the legal guarantee of conformity: a fixed-format statement reminding consumers they're entitled to at least a two-year statutory guarantee, with a QR code linking to more detailed, country-specific information. The wording and design are set in the regulation's annex; you display it as-is, in the local language, rather than drafting your own version.
The second element is a separate durability guarantee label (referred to in guidance as the "GARAN" label). This one is narrower: it only applies where a producer offers a voluntary commercial guarantee that is free of charge, covers the whole product, and lasts longer than two years. Importantly for sellers, this obligation only bites if the producer makes that information available to you, you are not required to chase producers to obtain it. So for many sellers, the durability label won't apply at all, while the legal-guarantee notice applies to everyone.
The rights aren't new. The obligation to tell every customer about them, in fixed wording you can't edit, on the product page or at checkout, is. That's the change to prepare for.
How this differs from what you do today
Today, most sellers mention warranty or returns information somewhere, often in a terms-and-conditions page or an FAQ, in their own words. The new rule removes that flexibility for the legal-guarantee notice: it must be the standardized EU notice, prominently placed, in the correct language, before the customer commits to buying. A link buried in your footer terms won't satisfy it. For a store with a large catalogue, that's a templating and product-page task, ensuring the notice renders consistently everywhere a customer can buy.
Who is in scope, and why non-EU sellers should note it
The requirement applies to any trader selling goods to consumers in the EU, regardless of where the business is based. A US, UK or Asian seller shipping to EU consumers is covered exactly like an EU-based shop, and there is no carve-out for small businesses; it applies regardless of turnover or headcount. This is consistent with the direction of recent EU rules we've covered, from the AI Act to the DSA to packaging, obligations increasingly attach to where the customer is, not where the seller sits.
The member-state wrinkle worth knowing
The two-year minimum is exactly that, a minimum, and some member states go further. Spain, for example, provides a minimum of three years of statutory guarantee on new goods. The harmonized notice accounts for this by pointing consumers (via its QR code) to country-specific details rather than baking a single number into the visible text everywhere. The practical implication: your obligation is to display the correct standardized notice for each market, not to become an expert in each country's exact period, but you should be aware the underlying rights differ by country.
Why it's worth acting on now
Because the notice is fixed-format and must appear at product or checkout level, this is a technical implementation task, not a quick copy edit. Ecommerce platforms are already responding: several (including major shop systems) have begun shipping native support for the standardized notice and label. If you're on a mainstream platform, the fastest path is likely to check whether your platform has a built-in feature or plugin for it before building anything custom. Either way, the fixed deadline and the product-page-level nature of the change reward starting early over scrambling in late September.
Action plan, if you sell goods to EU consumers
Confirm you're in scope. If you sell physical goods to consumers anywhere in the EU, you are, regardless of where you're based or how small you are. Don't assume a size exemption; there isn't one.
Check your platform first. Before building anything, see whether your ecommerce platform has released native support or a plugin for the standardized guarantee notice. Several have. This is likely the fastest route to compliance.
Use the official notice, unchanged. The wording and design are fixed in the regulation. Don't reword it or design your own version; display the standardized notice in the correct language for each market.
Place it before purchase, not in your terms. It must be prominent on the product page or in checkout, before the customer is bound. A footer T&Cs link doesn't meet the requirement. For online sales specifically, the notice must be displayed in colour (black-and-white is only permitted for in-store).
Check whether the durability (GARAN) label applies. Only if a producer offers a free, whole-product guarantee longer than two years and gives you that information. If not, you only need the legal-guarantee notice, not the durability label.
This article is for informational purposes only and does not constitute legal advice. Requirements under Implementing Regulation (EU) 2025/1960 and its national implementation can vary in detail by member state. Consult a qualified legal adviser to confirm exactly how the rules apply to your business and markets.
03 — The Stack
our ecommerce platform's native guarantee-notice support
Given this week's topic, the most useful "tool" is a feature your platform may already have shipped, worth checking before you build anything.
Often built-in ✓Product-page level ✓Multi-language ✓Fixed EU format ✓Marketplace-aware ✓
Because the deadline is fixed and applies to so many sellers, major ecommerce platforms have started adding native support for the standardized legal-guarantee notice and durability label, some across all plan tiers, including free ones. Before commissioning custom development or buying a third-party plugin, check your platform's changelog or help center for a built-in guarantee-notice feature. For most sellers on mainstream platforms, this turns a catalogue-wide compliance task into flipping a setting on.
The one limitation worth noting: native support handles the display, but you still have to configure it correctly per market (right language, right placement) and, where relevant, supply the producer-provided data for the durability label. The platform feature does the rendering; getting the inputs right for each country you sell into is still on you.
Not a sponsored placement. No affiliate relationship.
04 — The Number
2 years
The EU-wide minimum statutory guarantee on consumer goods that the new harmonized notice must inform shoppers about, from 27 September 2026, though some member states, such as Spain, require longer.
Source: Commission Implementing Regulation (EU) 2025/1960, under the Empowering Consumers Directive (Directive (EU) 2024/825)
The two-year figure itself is not new, it has underpinned EU consumer rights for years. What's new is the EU deciding that a right consumers often didn't know they had should be stated plainly, uniformly, and unavoidably at the point of sale. For sellers, the takeaway is that transparency obligations, not just the underlying rights, are now the thing that carries a deadline and a compliance task.