The guarantee notice your shop must show on 27 September

You get an email from a law firm you have never heard of. It says your shop is breaking an obligation that came into force three weeks ago, attaches a screenshot of your own product page and gives you ten days. It is not a scam: since 27 September 2026 something is missing from that page that has to be there.

What you have to show

It is called the harmonised notice on the legal guarantee of conformity and it is an image: a blue and yellow box with the European Union shield, telling the buyer they have at least two years of guarantee, what they can demand if the product fails and who they demand it from. The European Commission publishes it and Implementing Regulation (EU) 2025/1960 sets it.

It applies to any shop selling goods to consumers in the European Union. There is no exception for size, for turnover, or for selling through a marketplace instead of your own site. Only shops selling exclusively to businesses fall outside it.

Where it has to be, and where it does not count

The notice is pre-contractual information. In shop language: it has to be in front of the customer before they buy, not after. That means the product page, where you are making the offer.

Places where putting it achieves nothing:

• Only in your terms and conditions.
• Only in the footer, on a separate page nobody opens.
• Only after payment, in the confirmation email.

That last one throws people off, because it does have to be in the email as well. Just not instead of the product page.

What you cannot do with it: design it

Here is the part that surprises everyone. The annex to the regulation says it in one sentence: «none of the elements of the harmonised notice may be edited». It is a closed piece of work.

Translated into what you probably feel like doing:

• You cannot change its colours to match your shop.
• You cannot redraw it smaller, or trim the text you find excessive.
• You cannot translate it yourself: there is an official version per language and that is the one.
• You cannot hide it in a tab or an accordion «so it takes less room».

That last one is what most people try, and it is the mistake that gets expensive. The regulation allows the folded display only for the other piece — the GARAN label, coming up next — and for the notice it says nothing. The specialist firms that have been looking at this agree: it has to be embedded as a direct image, in plain sight. A tab you have to open is not «in plain sight».

What you can choose is where to put it and what frame it wears. That is not a small thing: an A4-shaped poster stuck next to the price looks orphaned, and the same poster at the foot of the page with a heading beside it looks like a section of your shop.

The second piece: the GARAN label

This is the one almost nobody needs, and it is worth knowing so you do not waste time on it. The GARAN label only goes up when the producer — not you — offers a durability guarantee that meets four conditions at once: it is free, it covers the whole product, it lasts more than two years, and they have given you the information.

If you sell products from manufacturers who offer none of that, you show no label and you still comply. And if you fund the guarantee yourself, that is not GARAN either: it is your own commercial guarantee, which you can advertise however you like, just not with that label.

In Spain it is three years, but the notice says two

This is the question that comes up most. In Spain the legal guarantee has been three years since January 2022, and the official notice mentions a minimum of two. It is not a mistake, and it is not something to correct by hand.

The notice is a single document for all twenty-seven countries, and inside it there is a box warning that some member states have a longer period, plus a QR code leading to the detail for each country. Writing «3 years» over it would be editing it, which is exactly what you cannot do.

And a practical consequence of that QR: it has to be scannable with an ordinary phone. If you make the notice very small so it takes less space, the code drops below sixty pixels a side and no phone will read it. That is also non-compliance, even with the notice sitting right there.

What to do before 27 September

1. Download the official notice for your language. It is inside the Official Journal of the European Union, in the regulation itself, as an image.
2. Put it on the product page, whole and in colour. Colour is mandatory when you sell online; black and white is only for paper.
3. Repeat it in the order summary, before the pay button.
4. Make it reach the confirmation email too, and actually reach it: half the inboxes block remote images, so the safe route is to attach it.
5. Check whether part of your catalogue falls outside. Services and downloads are not goods and follow a different directive.
6. Check the QR scans at the size you chose.

How we have it built

All of the above is an afternoon's work if you do it by hand once, and every afternoon if you have five languages and a mixed catalogue. The EU guarantee notice module carries the official file in all 24 languages of the Union, serves it on the product page, in the checkout and in the email, and ships a screen that tells you whether the QR reads at the width you picked.

There is one detail we are particularly happy with, and it is something the module does not do: if the official file for a language is missing, it shows nothing in that language. We could have served the Spanish notice to a French customer and nobody would have noticed. You would have believed you were compliant without being compliant, which is the worse of the two situations.