What Changes on September 27
Two new requirements become mandatory for anyone selling goods to EU consumers on September 27, under Commission Implementing Regulation (EU) 2025/1960.
Every seller, online and in a physical shop, must display a harmonised notice reminding the customer of the two-year minimum legal guarantee. The notice has to be prominently placed, at least A4 size when printed, in colour online, and it carries a scannable QR code linking to the consumer's actual rights.
The second requirement is voluntary until a manufacturer triggers it. Any commercial durability guarantee that is free of charge, covers the entire product, and runs longer than two years must now carry the EU's fixed GARAN label: a design with a checkmark, a calendar icon and a QR code, printed at a minimum of 95 by 100 millimetres. A brand that keeps advertising 'three years free' without the label is no longer just making a marketing claim, it is making a claim the regulation already has a required format for.
| Legal Guarantee Notice | GARAN Durability Label | |
|---|---|---|
| Applies to | Every seller, every sale | Only guarantees meeting the three triggers below |
| Trigger | Automatic, no condition | Free of charge, whole product, over two years |
| Minimum size | A4 when printed | 95 x 100 mm when printed |
| Must show | Two-year guarantee summary, QR code | GARAN title, checkmark, calendar icon, QR code, duration |
A Law Twenty Countries Have Not Finished Writing
The notice and the label both trace back to the Directive on Empowering Consumers for the Green Transition, adopted in February 2024, which member states had until March 27, 2026 to transpose into national law.
On May 28, the European Commission opened infringement procedures against twenty of the twenty-seven member states for failing to notify complete transposition: Belgium, Bulgaria, Czechia, Estonia, Greece, Spain, France, Croatia, Cyprus, Latvia, Luxembourg, Hungary, Malta, the Netherlands, Austria, Poland, Portugal, Slovenia, Finland and Sweden. Each got two months to reply, a window that closed around July 28, roughly seven weeks before shops have to comply regardless.
Ireland and the UK Sit Outside the Missing List
Ireland is not among the twenty states the Commission named, and neither is the United Kingdom, which sits outside the directive entirely as a non-EU market.
That does not make a UK-based retailer exempt. The Commission's own guidance says the notice and label obligations reach any business, inside or outside the EU, that directs its selling activity toward EU consumers, so an Irish shopper buying from a UK site is still covered even though the UK itself never had a transposition deadline to miss.
What A Tech Retailer Does With Twelve Days Left
The practical first move is an audit, not of the label itself but of every existing durability claim already in a product listing or a shop window.
Compliance guidance tracking the underlying directive puts the maximum penalty at four percent of a company's annual turnover in the member states concerned. A retailer's national enforcement authority may still be waiting on its own government to finish the law, but the label design itself comes from a directly-applicable EU Regulation, not from that unfinished national text, so the shelf obligation and the enforcement readiness are running on two different clocks that only look connected.
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