The harmonised guarantee notice is a common EU-wide notice that reminds consumers of their right to the legal guarantee of conformity, with a fixed design and a QR code. Its design is set by Commission Implementing Regulation (EU) 2025/1960, which applies from 27 September 2026, and its use is required by Directive (EU) 2024/825, which amends the Consumer Rights Directive. In an online shop, the notice has to appear on the website and in colour. Spain has not yet transposed that directive, but Spanish law already requires traders to remind consumers of the legal guarantee before purchase, and the EU design is final.
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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.
| Element | Harmonised notice | Harmonised «GARAN» label |
|---|---|---|
| What it reminds consumers of | The legal guarantee of conformity, its minimum duration of two years and the possibility of a longer period under national law | The producer’s commercial guarantee of durability, its duration in years and the fact that the legal guarantee still applies |
| Who displays it | The trader, whenever it sells goods to consumers | The trader, only if the producer offers that commercial guarantee and makes the information available |
| Where it goes in online sales | On the website, as a general reminder | Next to the specific product, for example beside its image |
| Format on an online interface | In colour (RGB) | In colour, and it may be shown as an expandable element |
| What can be edited | Nothing | Only the duration, the producer’s name and the model identifier |
| QR code | Leads to the legal guarantee information on the Your Europe portal, with country-specific details | Leads to the commercial guarantee of durability information on the same portal |
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.
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:
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.
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.
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.
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.
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:
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.
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.
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.
The EU design applies from 27 September 2026, but the duty to use it is in Directive (EU) 2024/825, which Spain has not yet transposed. What is mandatory today is reminding consumers of the legal guarantee before a distance purchase, under Article 97.1.n of the TRLGDCU. Using the harmonised notice is the safest way to meet that requirement.
On the website, as a general reminder and in colour, somewhere the consumer sees it before paying. The usual choice is the checkout or a guarantee page linked from it. It does not need to be repeated on every product page, and its design cannot be changed.
No. The GARAN label is only shown on products whose producer offers a free commercial guarantee of durability covering the whole product for more than two years and gives you that information. For all other products only the harmonised notice on the legal guarantee applies.
The harmonised notice states the EU minimum of two years and warns that national law may set a longer period. In Spain, Article 120.1 of the TRLGDCU sets three years for new goods. The QR code leads to each country’s information, so the notice does not contradict the Spanish period, but your legal texts must say three years.
The harmonised notice concerns the legal guarantee for goods. Sellers of digital content or services still have to remind consumers of their legal guarantee, which is two years under Article 120.1 of the TRLGDCU, but the directive does not require the harmonised notice, which is designed for goods.
The harmonised notice is a small change to the website and a good opportunity to review guarantee periods, product pages and terms of sale at the same time. At Innovatech we review the legal texts of online shops as part of our legal service for online shop terms and policies in Spain. Get in touch for a free initial assessment.
Marta Suárez-Mansilla is Managing Partner of Innovatech Legal and a Spanish lawyer (abogada), Madrid Bar (ICAM), working in technology law. She completed Harvard Law School's Copyright course and BerkeleyX's Blockchain programme, and has advised technology companies for more than eight years.
