EU Product Guarantee Information: A Snapshot of the Harmonised Notice and Label

This blog was originally posted on 8th October, 2026. Further regulatory developments may have occurred after publication. To keep up-to-date with the latest compliance news, sign up to our newsletter.

AUTHORED BY EMILIA ASSENZA, MANAGER – GLOBAL REGULATORY COMPLIANCE, ADHERENT

---

Introduction

One of the key objectives of Directive (EU) 2024/825, known as the Empowering Consumers for the Green Transition – ECGT Directive, is to better inform consumers on the durability of products by giving more harmonised information on consumer’s legal guarantees rights.

To that end, the ECGT Directive supplements the Consumer Rights Directive 2011/83/EU (CRD) with a new Article 22a which establishes two instruments, the Harmonised Notice and the Harmonised Label, to provide information concerning guarantees for goods.

The new tools must be used across all EU Member States from 27 September 2026. They must be easily recognisable and understandable for consumers and easy to use and reproduce for traders. 

To support their implementation, the EU Commission has specified the design and content of both tools through Regulation (EU) 2025/1960 which, in line with the ECGT Directive, became applicable on the same date (27 September 2026).

Practical Guidelines and High Resolution Vector Files have also been published by the EU Commission in April 2026 to help companies correctly apply and display both tools.

Scope

Both the harmonised notice and the harmonised label only apply to B2C products. 

In fact, the harmonised notice and the harmonised label implement the provisions of Directive (EU) 2024/825 which amends the Consumer Rights Directive (CRD).

The CRD applies to “contracts concluded between consumers and traders”, including both sales contracts and service contracts.

Sales contract means any contract under which the trader transfers or undertakes to transfer ownership of goods to the consumer, including any contract having as its object both goods and services.

The definition of goods is taken from point (5) of Article 2 of Directive (EU) 2019/771 – meaning any tangible movable item.

There are very limited exceptions as listed in Article 3(3) of the CRD, such as foodstuffs, contracts concluded by means of automatic vending machines or automated commercial premises, contracts for healthcare etc.

Harmonised Notice

The harmonised notice serves as a reminder to the consumers about the legal guarantee of conformity applicable to all goods in accordance with Directive (EU) 2019/771. It should remind consumers about its existence and its main elements, such as its minimum duration of two years.

It is mandatory and must be displayed in a prominent manner by the seller. It must be in the language of the Member State where the product is offered.

As confirmed by the recent FAQ document published in November 2025, the harmonised notice must be displayed, for example, on a poster in an eye-catching way on a wall in the shop, next to the checkout counter or, in cases of online sale, placed as a general reminder on the website of the trader selling goods.

Moreover, illustrative examples are provided in the Practical Guidelines on the locations where to place the harmonised notice:

• Physical display: at the entrance door of the store, on a poster placed on the wall or an aisle inside the store, at the store counter
• Digital display:
  • on the product catalogue page, by adding a sentence informing consumers about their legal guarantee rights (e.g. “Your legal guarantee rights”), where the harmonised notice shall then appear on the first mouse click or mouse roll-over.
  • on the header of the seller website, add a sentence informing consumers about their legal guarantee rights (e.g. “Your legal guarantee rights”) where the harmonised notice shall then appear on the first mouse click or mouse roll-over.
  • at the product check-out page, add a sentence informing consumers about their legal guarantee rights (e.g. “Your legal guarantee rights”) where the harmonised notice then shall appear on the first mouse click or mouse roll-over.
  • The harmonised notice should also be included in the confirmation email.

Regulation (EU) 2025/1960, in its Annex I, provides for its design and content as follows:

The notes establish the colours to be used (either colour or black and white, apart from online where it must be in colour) and the minimum size (A4). The QR code must lead to the dedicated language section on the legal guarantee of conformity on the Your Europe portal, in order to provide consumers with more detailed information on their rights provided by the legal guarantee of conformity as established by Directive (EU) 2019/771.

It is important to note that none of the elements of the harmonised notice can be edited. 

The official template of the harmonised notice is available in all the official languages of the EU in high-resolution vector files (in JPG, SVG or PNG files).

Harmonised Label

The harmonised label aims to inform consumers about the fact that a commercial guarantee of durability is offered in accordance with Article 17 of Directive (EU) 2019/771. It is a new label for producers willing to promote the durability of their products and for consumers interested to choose for products with a longer lifespan.

It applies to commercial guarantees of durability that are offered by the producer:

• At no additional cost
• Covering the entire product
• For a period longer than two years

It represents the voluntary commercial guarantee of durability and must be displayed in a prominent manner. 

As clarified by Recital 28 of the ECGT Directive, the harmonised label should be used in a way that allows consumers to easily identify which particular good benefits from such commercial guarantees of durability, for example by placing the label directly on the packaging of a particular good, by displaying the label in a prominent manner on the shelf where the goods covered by such a guarantee are placed or by placing it directly next to the picture of the good in the case of online sale. 

Illustrative examples are provided in the Practical Guidelines:

• Physical display: placed on the shelf next to the product, on the product packaging, attached to the product (as a tag, adhesive label or other physical attachments). It is also specified that “In addition to the shop display, it is a good practice to include the EU GARAN label inside the package, either as a stand-alone leaflet or printed inside the user manual, together with the commercial guarantee statement. This will allow the consumer to keep a record of the commercial guarantee duration and other relevant information.”
• Digital display:
  • on the product page (ror example  as part of a product image, as a standalone image in the product gallery, in the product description, or as a nested label)
  • The harmonised label should be shown directly before the consumer places the order at the product check-out page.
  • The harmonised label should be also included in the confirmation email.

It is important to note that the harmonised label must be used whenever the producer offers a commercial guarantee of durability. In other words, the harmonised label is not mandatory unless the producer offers a commercial guarantee of durability. 

Additionally, as confirmed by Recital 32 of the ECGT Directive, the producer and the seller remain free to offer other types of commercial guarantees and after-sales services. However, the information provided to the consumer about other commercial guarantees or services should not confuse the consumer with regard to the existence and duration of the commercial guarantee of durability offered, and for which a harmonised label is used.

A final clarification relates to which operator is required to comply. As clarified in Recital 26, displaying such a label is required by the seller, where the producer offers such commercial guarantees of durability and makes the information available to the seller. Importantly, sellers are not required to actively search for relevant information from the producer, for example, by searching on product specific websites or elsewhere. Also, producers can themselves place the harmonised notice directly on the good or its packaging, with the aim of benefitting from a commercial advantage.

According to the template shown in Annex II of Regulation (EU) 2025/1960, the harmonised label must have the following format:

Certain elements of the harmonised label can be edited to specify the duration of the commercial guarantee of durability and the information on the brand/trademark and the model identifier. The elements that cannot be edited are instead:

• The title of the label (‘GARAN’ which refers to ‘guarantee’ in several languages of the EU)
• The visual reminder of the existence of the legal guarantee of conformity
• The QR code leading to the Your Europe portal page
• The calendar symbol representing ‘years’
• The translation of ‘producer guarantee in year’ in all official languages of the EU

For distance contracts concluded through an online interface, the harmonised label can be displayed using a nested display, as shown below:

The high-resolution vector files of the harmonised label are available (in JPG, SVG or PNG files) and can be edited by producers as detailed above.

Is there a transition period?

There is no transition period. This means that both the harmonised notice and label must be used since the application date of the ECGT Directive, being 27 September 2026.  This is also confirmed in the FAQ document which states that the harmonised notice “should be displayed in a prominent manner as of 27 September 2026” and that “As of 27 September 2026, the harmonised label will become available for products and visible at the point of sale.”

See Adherent in Action

Discover how agentic AI is reshaping product compliance for global enterprises.

BOOK A DEMO