New information requirements for consumer contracts from 27 September 2026: the warranty and guarantee label

With effect from 27 September 2026, new European information requirements apply to companies that distribute goods to consumers. In future, a warranty label and – under certain conditions – a guarantee label must be provided. The requirements apply to both brick-and-mortar retail and online distribution.

Companies should address the new requirements as soon as possible. In addition to implementation in distribution, coordination with manufacturers and suppliers and the review of existing compliance processes are becoming increasingly important.

What obligations apply to companies?

The European Union is introducing two standardised information labels designed to inform consumers of their statutory warranty rights and certain manufacturer guarantees.

The warranty label is basically to be provided at all points of sale. The guarantee label is only required if the manufacturer grants a free guarantee of more than two years for the entire goods.

Both labels are subject to mandatory design requirements (marking size, font size, colour, etc.) and must be affixed or integrated in a clearly visible manner. The new information requirements apply regardless of whether goods are distributed in brick-and-mortar retail, online or via both distribution channels.

Both labels contain a QR code which is part of the harmonised design and must not be altered. In the warranty label, the QR code leads to the EU portal 'Your Europe' with general information on statutory warranty rights. In the guarantee label, the QR code refers to general explanations of the commercial durability guarantee.

The legal distinction between statutory warranty and voluntary manufacturer guarantee remains unchanged. Whilst warranty is mandatory under law, the manufacturer guarantee continues to be based on a voluntary undertaking by the manufacturer.

The EU Guidelines on the use of the two labels and the labels in different file formats and languages can be accessed at https://commission.europa.eu/publications/practical-guidelines-and-high-resolution-vector-files-eu-notice-and-label-product-guarantees_en.

The warranty label

The warranty label is in future to be provided everywhere where companies sell goods to consumers. This applies to both brick-and-mortar retail locations and online retail (including platforms).

In brick-and-mortar retail, the label must be affixed in a clearly visible location. For online retail, corresponding prominent integration on the website is required; mere inclusion in the general terms and conditions is unlikely to meet the statutory requirements. Whilst a black-and-white version may be used in brick-and-mortar retail, the label must be displayed in colour online.

The guarantee label

Unlike the warranty label, the guarantee label does not apply to all products. The marking requirement presupposes that the manufacturer grants a free guarantee with a term of more than two years which covers the entire goods.

The guarantee label for the corresponding product edited (the details must be entered in the boxes 'XX', 'Brand/Trademark' and 'Model Identifier') guarantee label must be provided in both brick-and-mortar retail and online retail in direct connection with the products in question. Mandatory design requirements also apply here; the label must be displayed in colour in online distribution.

The guarantee label is designed to be language-neutral: it bears the title 'GARAN' – a multilingual neologism that refers to the word 'guarantee' in various EU languages. At the bottom, the label contains the additional text 'Manufacturer guarantee in years' in all official languages of the European Union, which facilitates consistent use throughout the internal market.

If a guarantee undertaking by the manufacturer exists and accordingly the guarantee label must be used, the manufacturer's guarantee terms must also be communicated. The guarantee declaration must be issued on a durable medium (also as a PDF email attachment) no later than at the time of delivery.

In online retail, a nested display is also permissible. The simplified marking prescribed by law ('nested label') must then be used, which displays the full guarantee label on the first mouse click, the first mouse-over or similar.

Deadlines and preparation

The new information requirements apply from 27 September 2026. Even though there is still time before the requirements come into force, companies should begin implementation as soon as possible. In particular, where product ranges are extensive or multiple distribution channels are served, coordination with manufacturers, suppliers and technical service providers may require appropriate lead time.

Conclusion

With the introduction of the warranty and guarantee label, the European Union is expanding information requirements in B2C distribution. This creates organisational and technical requirements for companies that affect both brick-and-mortar retail locations and online shops.

Whilst the warranty label is in future generally to be provided, the use of the guarantee label depends on the respective manufacturer guarantees and the information provided in relation thereto.