Frequently asked questions about the legal guarantee notice and GARAN-Label
Answers to the most important questions about the EU requirement from 27 September 2026 and using GARAN-Label.com.
Legal Background
Is the GARAN-Label legally required?
Only if you advertise a free manufacturer guarantee of more than two years. It is based on Directive (EU) 2019/771 in conjunction with Implementing Regulation (EU) 2025/1960. It becomes mandatory from 27 September 2026. Full details on the requirement →
What happens if I advertise a long-term guarantee but don't use the label?
If the required label or the corresponding guarantee terms are missing, this counts as a competition law violation. This can lead to costly cease-and-desist warnings from competitors or consumer protection associations, whether the violation was intentional or simply an oversight.
Is the GARAN-Label the same as the legal guarantee label?
No. The legal guarantee label concerns statutory liability for defects and is mandatory for every seller, regardless of any manufacturer guarantee. The GARAN-Label only concerns voluntary manufacturer guarantees of more than two years. Full comparison →
What must appear on the legal guarantee notice?
The notice on the statutory minimum two-year guarantee, consumer rights for non-conforming goods (free repair or replacement, in some cases a price reduction or full refund), the steps to take when filing a claim, and a QR code linking to country-specific details. The content is set by Implementing Regulation (EU) 2025/1960 and may not be altered. Download the official template →
Where do the design requirements for the label come from?
Colours, minimum sizes, and mandatory elements such as the QR code are precisely defined in Implementing Regulation (EU) 2025/1960 and may not be changed. The underlying basis is Directive (EU) 2019/771 together with the Empowering Consumers Directive (EU) 2024/825, which originally introduced the labelling requirement. Full legal basis →
Do I have to use the label before 27.09.2026 already?
No, it becomes mandatory from that date. Earlier voluntary implementation is permitted and often makes sense from a customer communication perspective, for example to stand out before competitors who haven't switched over yet.
Does the requirement also apply to used goods?
The legal guarantee label generally applies to new and used goods sold by a commercial seller to consumers. The GARAN-Label is only relevant if a commercial guarantee of over 2 years is actually offered for that product, which is less common for used goods but does happen, for example with refurbished electronics.
Does this also apply to digital products?
No, both labels only concern physical goods, not digital content or services. An e-book, a software licence, or a streaming subscription needs neither label.
Who monitors compliance with this requirement?
There is no dedicated market surveillance specifically for this label. In practice, enforcement happens through competition law, i.e. through cease-and-desist warnings from competitors or consumer protection associations. These often spot-check individual listings without needing a specific tip-off first.
Does the requirement apply uniformly across the EU?
Implementing Regulation (EU) 2025/1960 applies directly in all member states and does not need to be transposed into national law first. Minor additions only arise where national law, such as the EGBGB in Germany, imposes supplementary rules. Full legal basis →
Practical Implementation
Do I also need to provide the guarantee terms?
Yes. Displaying the GARAN-Label legally counts as guarantee advertising and requires you to simultaneously provide complete, legally compliant guarantee terms, at the latest at the time of delivery, on a durable medium, for example as a PDF by email or for download on the product page.
What applies if my guarantee is under two years?
Then it does not fall under the GARAN-Label requirement. You can continue to advertise it freely without having to use the label. The statutory legal guarantee notice remains mandatory regardless.
How big does the legal guarantee notice have to be?
A minimum print size applies so all mandatory elements (logo, text, QR code) stay legible; the official A4 template provided here satisfies this. Online, the notice must be shown in colour and at a size that lets customers read it without zooming or scrolling. Download the official template →
What happens if the label is missing?
A missing legal guarantee notice, or a missing GARAN-Label where one is required, counts as a competition law violation. Competitors or consumer protection associations can send you a costly cease-and-desist notice for it, whether the violation was intentional or accidental. Add the missing label as quickly as possible on all affected listings. Full difference and risk →
Using GARAN-Label.com
Do I need programming skills?
No. GARAN-Label can be used entirely without programming via manual entry or CSV upload. The API is additionally aimed at customers with their own system integration, for example to connect it automatically to a webshop or an inventory system. API & CSV documentation →
What's the difference between sandbox and live mode?
In sandbox mode, the same label is generated with a visible "SAMPLE" watermark, without using credits. Live mode generates the real, deliverable label and uses one credit (if the label is newly generated). That lets you test layout and integration as often as you like before spending a credit.
What happens if I request the same product multiple times?
You receive the already generated label again, at no extra cost. Only an actual re-generation, for example with a changed guarantee duration, uses a credit.
What format do I receive the labels in?
As a PNG image file, plus via a permanent, directly linkable URL. That URL also works well for embedding directly into product descriptions or shop templates without manually uploading the file.
Do my credits expire?
There is no subscription commitment. You pay once for a balance that you use at your own pace, with no expiry date. View pricing →
Do I need a password?
No. You register once with your name and email address and then log in afterwards via a secure link sent by email.
Can I give someone else temporary access to my account?
Yes. Under "Grant account access" in the portal, you can invite an agency, freelancer, or employee by email and give them time-limited access to manual entry and CSV upload, without sharing your login. The invited person uses your existing credits while access is active.
Is there a limit for CSV processing?
Even very large files are processed reliably. Generation continues in the background even if you reload or leave the page, and you receive a result file with the generated label URL for each row at the end. View the CSV format & example →
How secure is my API key?
It identifies your account to the interface and should be treated like a password. If accidentally shared, contact support. API documentation →
Sales Platforms
Does this requirement also apply on Amazon, eBay, or Etsy?
Yes. The labelling requirement applies to the individual seller, regardless of whether they sell through their own shop or through a sales platform. The seller behind the listing is always responsible, not the marketplace operator. We have detailed, practical guides for Amazon and eBay. For other platforms such as Etsy, the same principle applies: the label is product-specific additional information, not a product image, so it belongs in the product page's information area or the item description, not the image gallery. Guide for Amazon → Guide for eBay → All sales channels →
Amazon
Do I need to use the legal guarantee notice as an Amazon seller, even though Amazon has no official requirement?
Yes. The legal requirement applies regardless of the sales platform. Whether or not Amazon has published its own guidance doesn't change your legal responsibility as the seller. Full guide for Amazon →
Can I upload the GARAN-Label as a product image in the image gallery?
No. The GARAN-Label is product-specific additional information, not a product photo. It belongs in the information area of the product page, not the image gallery.
Can I add the GARAN-Label through A+ Content?
Amazon's A+ Content policy explicitly prohibits words like "warranty" or "guarantee" and references to external refund policies in text or images. Since the GARAN-Label shows exactly that kind of information, it's currently unclear whether or how a compliant implementation via A+ Content can be achieved.
Is it enough to add the label only to products with a manufacturer guarantee?
No. The legal guarantee notice applies to all physical goods, even without a manufacturer guarantee. The GARAN-Label is only additionally required if you advertise a voluntary manufacturer guarantee of more than 2 years. Full difference →
eBay
Can I add the label as an additional listing image instead?
No. The GARAN-Label is product-specific additional information, not a product photo. Add it as an image directly in the item description instead, in the information area around the product details. Full guide for eBay →
Can I link to the label URL permanently in my item description?
Only temporarily. We delete labels from our server 30 days after generation. Download the image and host it yourself so your item description keeps working long-term.
Do I need to add the label to every single listing, or is the shop homepage enough?
The label must appear on each affected listing itself. A notice only on the shop homepage isn't sufficient, since customers can also reach listings directly via search without visiting the homepage.
Does this requirement also apply to classified ads or private eBay sales?
No. The labelling requirement applies to commercial sellers in B2C business. Purely private sales between individuals are not covered.
Shopify
Do I need an app to add the GARAN-Label in Shopify?
No. A product metafield of type image/file is enough to store the GARAN-Label per product. A paid subscription app isn't required for this. Full guide for Shopify →
Can I just add the GARAN-Label to the regular product images?
No. The GARAN-Label is product-specific additional information, not a product photo. Output it via the metafield in the information area of the product page, not in the regular image gallery.
Does the metafield approach also work with Shopify Plus / custom checkout extensions?
Yes. Metafields are a native Shopify feature available on all plans, including Shopify Plus. Custom checkout extensions typically affect the checkout process, not the product page where the label is displayed.
How do I keep metafields up to date with frequent product changes?
For ongoing syncing, one of the common Shopify apps for CSV data import/export with metafield support, such as Matrixify, is recommended. This lets you combine the tool's CSV mode directly with a bulk metafield update. More on CSV mode →
Shopware
Does this also work with custom-coded Shopware themes?
Generally yes. On heavily customised themes, the exact place to implement it in the template may differ, so it makes sense to check with the agency or developer team maintaining it. Full guide for Shopware →
What is the difference between a free-text field (Shopware 5) and a custom field (Shopware 6)?
Both serve the same purpose: an additional, freely usable field per product where you can store the GARAN-Label. Only the name and the exact admin interface differ between the two Shopware versions.
Can I just add the GARAN-Label to the regular product images?
No. The GARAN-Label is product-specific additional information, not a product photo. Output it in the information area of the product page in the storefront template, not in the regular image gallery.
Does the GARAN-Label need to be stored separately for every variant of a product?
Yes, if brand, model, or guarantee duration differ between variants. If all details are identical across every variant, a single label at the product level is enough.
xt:Commerce
Do I still need a GARAN-Label.com account with the plugin?
Yes. The plugin uses the GARAN-Label.com API, which still requires an account with credits. The plugin itself does not replace registration. Full guide for xt:Commerce →
Can I override the manufacturer name or guarantee duration per product?
Yes, and it's often necessary: many xt:Commerce stores don't use xt:Commerce's own manufacturer page system. Without stored manufacturer data, the name and guarantee duration can be entered directly on the product and overridden there at any time.
Is there an official solution from xt:Commerce itself?
None is currently known. A free plugin already fills that gap, though.