Anyone who operates an online store and sells goods to consumers should take action now. On September 27, 2026, new disclosure requirements will take effect that will fundamentally change how statutory warranty rights and certain manufacturer warranties are presented. In the future, it will no longer be sufficient to merely mention existing rights in the terms and conditions or in a general information text. For consumer information, standardized notices or labels prescribed by the European Union must be used.
Contrary to what was occasionally assumed during the legislative process, the European requirement has now been fully transposed into German law. The Act Amending Consumer Contract Law and Insurance Contract Law, as well as Amending Medical Treatment Contract Law, dated February 3, 2026, was promulgated on February 5, 2026. The new Article 246a, Section 1, Paragraph 1, Sentence 1, Nos. 11 and 11a of the Introductory Act to the German Civil Code (EGBGB) will take effect on September 27, 2026. For online retailers in particular, this means that the law requires the use of the prescribed harmonized EU graphics for consumer information.
The harmonized EU graphics, along with explanatory notes, can be found in Implementing Regulation (EU) 2025/1960. It did not first need to be implemented by the German legislature: as an EU regulation, it is directly applicable. In its two annexes, it sets forth binding requirements for the format of the harmonized notice on statutory warranty rights and the GARAN label. The regulation itself expressly states that it takes effect on September 27, 2026.
The first new label: “Statutory Warranty”
The eye-catching blue-and-white notice with the heading “STATUTORY WARRANTY” is the label that will have the broadest impact on online retailers. Art. 246a § 1 (1) Sentence 1 No. 11 of the EGBGB requires that, as of the effective date, consumers be informed “in a prominent manner using the harmonized notice” about the existence of the statutory warranty right for goods and its most important elements, including the minimum duration of two years.
The graphic not only explains the minimum duration to the consumer. It also provides examples of situations in which warranty rights may apply, such as when a product does not match its description or does not function as intended. It highlights the options for free repair or replacement, as well as price reduction or refund under certain conditions. In addition, there are practical tips for filing a complaint and a QR code that can be scanned to access further information on warranty rights in the respective member state.
Furthermore, the reference to “at least two years” must not be interpreted in isolation as a promise of a specific product lifespan. Statutory warranty rights concern liability for non-conformity with the contract or material defects and must be distinguished from a voluntary durability guarantee. It is precisely this distinction that the new design is intended to make more visible to consumers.
The retailer has no freedom to alter the content of this warranty notice. According to Annex I of the Implementing Regulation, none of its elements may be edited. Texts, layout, colors, symbols, and the QR code may therefore not be modified, shortened, or redesigned according to personal preference. For online user interfaces, the colored RGB version is required. However, there is no mandatory minimum size, such as DIN A4, for online stores; the A4 requirement in the regulation applies to distance sales contracts that are not concluded via an online user interface. Within the store, the notice must be clearly highlighted and legible.
The law does not specify a particular page location where the notice must appear within an online store. The EmpCo guideline already cites, as an example, a general reminder on the seller’s website. The Commission’s practical guidelines, published in April 2026, suggest solutions such as placing the notice in the page header, on a product overview page, or during checkout; in these locations, a sufficiently prominent notice can cause the full text to appear upon the first click or mouseover. However, the guidelines are interpretive aids provided by the Commission’s services and, according to their own disclaimer, do not constitute a binding interpretation of Union law.
For practical implementation, there are therefore strong reasons not to simply place the notice somewhere in the footer, in the terms and conditions, or on a hard-to-find subpage. German law expressly requires prominent disclosure of this information before the consumer submits their declaration of contract. The specific design of the online store should be chosen so that a consumer actually notices the information and can read the full graphic without difficulty.
The second label: the EU-GARAN label
The new GARAN label must be clearly distinguished from the general warranty notice. It does not have to be displayed for every product, nor does it have to be displayed for just any warranty. According to Article 246a, Section 1, Paragraph 1, Sentence 1, No. 11a of the EGBGB, effective September 27, the special labeling requirement applies when the manufacturer grants the consumer a commercial durability guarantee at no additional cost for the entire product and for a period of more than two years, and provides this information to the retailer.
A two-year manufacturer’s warranty is therefore insufficient, as is a warranty that covers only a single component. Other forms of voluntary warranties may not simply be labeled with the GARAN label either. In its current guidelines, the Commission expressly points out that the label is intended exclusively for the manufacturer’s qualified durability warranty.
The GARAN label is much more specifically tailored to the individual product. The designation “GARAN,” the checkmark, the blue shield referring to statutory warranty rights, the QR code, the calendar icon, and the multilingual reference to the manufacturer’s warranty are all strictly prescribed. In contrast, three pieces of information are customized: the warranty period in years, the manufacturer’s name or brand, and the model number. This is intended to make it immediately clear to which specific product the additional durability guarantee applies.
When specifying the warranty period, it is also worth taking a closer look at the Commission guidelines that have since been published. These guidelines provide for whole years and, if necessary, half-years—such as 2.5 or 4.5 years; other decimal values should not be used. This detailed requirement is found in the Commission’s practical guidelines and is not specified in such detail in the actual text of the regulation.
Unlike the general warranty notice, the GARAN label is product-specific. The consumer must be able to identify which specific product is covered by the shelf-life guarantee. The European guidelines specify, for example, that online stores may include the label in the product image, the image gallery, the product description, or use the explicitly provided nested label. No rigid requirement that the label must appear exclusively directly next to the product image can be inferred from this.
The nested GARAN label is particularly interesting for online stores. Initially, only the compact version—showing the warranty period, the “GARAN” logo, and the shield—is displayed. Upon the first click, mouseover, or tap on a touchscreen, the full label must then open. This option is expressly provided for in Annex II of the Implementing Regulation.
Ordering Process
For German online stores, there is an additional special provision: Effective September 27, 2026, Section 312j(2) of the German Civil Code (BGB) will also be amended. The information required under Article 246a § 1(1), sentence 1, no. 11a of the Introductory Act to the German Civil Code (EGBGB)—specifically, the information regarding the qualified durability guarantee—will thus be included in the details that must be provided clearly and comprehensibly in a paid electronic contract immediately before the consumer submits their order. The GARAN label should therefore not merely appear somewhere on the product page, but should be integrated into the ordering process in such a way that this requirement is met.
The European Commission’s practical guidelines point in the same direction. They stipulate that, when displayed digitally, the label must be clearly associated with the product and recommend that it be displayed again immediately before the order is placed. They also recommend including both the warranty notice and, if applicable, a relevant GARAN label in the contract confirmation. These guidelines are extremely helpful for the technical design of an online store, even though the guidelines themselves do not constitute a binding legal norm.
No Substitute for a Warranty Statement
Incidentally, the new labels do not replace other statutory information requirements regarding warranties. If a commercial warranty exists, the requirements applicable to warranty statements must still be observed. The GARAN label is intended to make a specific, qualified manufacturer’s warranty visible at a glance; it is not a substitute for the complete warranty terms and conditions.
Conclusion
Retailers should also systematically review their supplier and manufacturer information now. Particularly with the GARAN label, the retailer’s obligation depends on whether the relevant information from the manufacturer has been made available to them. The directive also clarifies that the retailer is not obligated to actively search manufacturer websites for warranties that have not yet been disclosed. However, if the information is made available to them, they must use it accordingly, provided the other requirements are met.
For goods already in stock, the effective date does not constitute a general grace period either. The duty to provide information is tied to sales to consumers. Therefore, anyone offering such goods and entering into contracts on or after September 27, 2026, must have adapted their online store and consumer information to the new requirements by that date. GvW also points out in this regard that companies should adjust their existing sales processes and product information in a timely manner.
One point is therefore particularly important for retailers: Starting September 27, not every product will require two new labels. The harmonized notice regarding statutory warranty rights is the general mandatory information for B2C sales of goods. The GARAN label, on the other hand, is only required in addition to this for the manufacturer’s warranty—which is defined in more detail by law, provided free of charge, and valid for more than two years—covering the entire product.
Anyone reading this article on September 20, 2026, will have exactly one week left to complete the technical implementation. Online retailers should use this time to integrate the official German warranty notice, check the products they sell for applicable manufacturer warranties, compile the necessary product data, and review the checkout process. Only the original files provided by the European Commission should be used for the graphics.The Commission now provides high-resolution files in PDF, JPG, PNG, and SVG formats, as well as its own online version of the GARAN label.
The statements represent initial information that was current for the law applicable in Germany at the time of initial publication. The legal situation may have changed since then. Furthermore, the information provided cannot replace individual advice on a specific matter. Please contact us for this purpose.