Harmonised guarantee notice for online shops, what changes from 27 September 2026

What the harmonised notice and the GARAN label are

The harmonised notice is mandatory for any trader selling goods to consumers and reminds them of the legal guarantee that covers every product. The harmonised label, titled «GARAN», is different and voluntary. It only exists when the producer offers a commercial guarantee of durability at no extra cost, covering the whole product and lasting more than two years. Both share colours, typeface and a QR code so that consumers can tell them apart at a glance.

Where the obligation comes from

The obligation comes from Directive (EU) 2024/825 of 28 February 2024 on empowering consumers for the green transition. That directive adds Article 22a to Consumer Rights Directive 2011/83/EU. Under that article, the information on the legal guarantee that traders already had to give before the contract is given through the harmonised notice, and the information on the commercial guarantee of durability through the label.

The directive asked the Commission to set the design and content of both, and the Commission did so in Implementing Regulation (EU) 2025/1960 of 25 September 2025, published in the Official Journal of the European Union on 2 October 2025. Its Article 3 makes it applicable from 27 September 2026, the same date from which Member States had to apply the directive.

The two acts work differently. The regulation is directly applicable throughout the EU, but it only governs what the notice looks like. The duty to use it lies in the directive, and a directive binds businesses through each Member State’s national law. Member States had to adopt that law by 27 March 2026, under Article 4 of Directive 2024/825.

What Spanish law says today

Spain has not yet transposed Directive 2024/825. The consolidated text of the Spanish General Law for the Protection of Consumers and Users (TRLGDCU) in the Official State Gazette (BOE) does not include the harmonised notice or label. The planned vehicle is the Sustainable Consumption Law, which the Council of Ministers approved as a preliminary draft, at first reading, on 1 July 2025, and which has not been published in the BOE.

That does not leave online shops without obligations on the legal guarantee. Spanish law already requires two things that the harmonised notice sums up:

• Article 97.1.n) requires distance sellers to remind consumers, before purchase, that a legal guarantee of conformity exists for goods, digital content or digital services.
• Article 120.1 sets that legal guarantee at three years from delivery for goods and two years for digital content or services. For second-hand goods a shorter period may be agreed, never less than one year.

The reminder of the legal guarantee is mandatory in Spain today, and the harmonised format is already defined. What is missing is the Spanish rule stating that the reminder has to be given precisely with the EU notice. The Spanish government’s consumer portal has been promoting the notice among physical and online retailers since August 2026.

How the notice is shown in an online shop

In online sales, the harmonised notice is shown on the trader’s website as a general reminder and in RGB colour, under note 5 of Annex I to Regulation 2025/1960. Recital 28 of Directive 2024/825 describes it as a general reminder on the website, not as a notice repeated on every product page. The sensible approach is to place it where the consumer sees it before paying, for example in the checkout or on a guarantee page linked from it.

What cannot be changed in the design

No element of the harmonised notice can be edited. The colours are those of Annex I (Reflex Blue, yellow, black and white) and the QR code must be scannable with an ordinary mobile phone. In a physical shop the minimum size is A4. Online there is no fixed size, but the notice has to be visible in full and legible. The notice says that the legal guarantee lasts at least two years and that national law may extend it, and the QR code leads to each country’s information. That is why it does not contradict Spain’s three years.

When the GARAN label has to be shown

The label is only shown when the producer offers a commercial guarantee of durability at no extra cost, covering the whole product and lasting more than two years, and makes that information available to the seller. The directive makes clear that the seller does not have to search actively for it on each producer’s website. If the information exists, the label goes next to the specific product and, in an electronic order, is highlighted just before the consumer presses the order button, under the new Article 8(2) of Directive 2011/83/EU.

On an online interface the label must be in colour and may be displayed in an expandable format. In that case it must appear in full on the first click, mouse-over or tap. The typeface is Inter and only three fields can be edited, namely the duration in years, the producer’s brand and the model identifier.

Other obligations in the same directive that affect product pages

Directive 2024/825 also changes what an online shop may say about its products. These are the practices it adds to the list of commercial practices that are unfair in all circumstances, with effect in Spain once transposed:

• Generic environmental claims, such as «eco-friendly», «green» or «environmentally friendly», when recognised excellent environmental performance cannot be demonstrated.
• Sustainability labels that are not based on a certification scheme with third-party monitoring or established by public authorities.
• Claims of climate neutrality or a reduced footprint based on offsetting emissions outside the product’s value chain.
• Presenting as a distinctive feature a requirement that the law imposes on all products in the same category.
• Withholding that a software update will impair the product’s functioning, or presenting as necessary an update that only enhances functionality.

The directive also adds new pre-contractual information when the producer provides it, such as the minimum period of software updates for goods with digital elements, the reparability score or the availability and cost of spare parts. For an online shop, all of this is dealt with in the product page and in the general terms and conditions, which are worth reviewing at the same time as the notice is added.

A practical example

Hogar Norte, a fictitious online shop selling small home appliances, sells coffee makers, vacuum cleaners and food processors. Its terms page says that «all products come with a two-year guarantee», and one of its producers offers a free five-year commercial guarantee of durability on a vacuum cleaner model.

The review of the website shows three problems. The first is the period, because in Spain the legal guarantee for new goods is three years, so the two years in its terms contradict Article 120.1. The second is that there is no visible reminder of the legal guarantee before payment. The third is that the vacuum cleaner with a five-year producer guarantee does not highlight it next to the product.

The fix is to correct the period in the general terms, place the harmonised notice in colour in the checkout and add the GARAN label, with its five years, next to the vacuum cleaner’s image and in the summary before payment. The shop then already complies with Article 97.1.n of the TRLGDCU and is ready for when Spain transposes the directive, without having to redo the design.

What to review in your online shop now

• The guarantee period stated in your terms, your product pages and your confirmation emails, which has to be three years for new goods in Spain.
• Where the reminder of the legal guarantee appears before the customer pays, and whether it can be replaced by the harmonised notice in colour.
• Which producers in your catalogue offer a commercial guarantee of durability of more than two years, and how that information reaches you.
• The space on the product page where the GARAN label would go and its expandable version on mobile.
• The environmental wording and labels on your product pages, banners and collection names.
• The information on software updates and repair for products with digital elements.

Directive 2024/825 is part of a wider set of rules affecting online sales, from Spain’s e-commerce law (LSSI) to the General Product Safety Regulation. You will find them in order in our guide to e-commerce regulations in Spain.