Legal-guarantee notice and GARAN label from 27 September 2026: what Shopify merchants must do now
Since 19 June 2026 every online shop selling to EU consumers must offer a withdrawal button. On 27 September the second wave arrives: an officially designed notice about the legal guarantee, and the GARAN label for producer durability guarantees of more than two years. Implementing Regulation (EU) 2025/1960 fixes colours, font, QR code and wording down to the detail – none of it may be edited.
What applies from 27 September
1. The harmonised notice on the legal guarantee. A poster in EU blue, at least A4 in physical shops, in colour and “in a prominent manner” online. It reminds consumers that goods sold in the EU carry a minimum two-year legal guarantee, that the seller is liable, and that repair, replacement, price reduction or refund are available. Legal basis: Art. 6(1)(l) of the Consumer Rights Directive as amended by Directive (EU) 2024/825.
2. The GARAN label. If the producer offers, free of charge, a durability guarantee of more than two years covering the entire good, the merchant must display the harmonised label: the title “GARAN”, a tick, a calendar symbol, the duration in years, brand and model identifier, a QR code to the Your Europe portal, and “producer guarantee in years” in all 24 official languages. Online the label may be nested: a slim strip first, the full label on the first click or roll-over.
3. Since 31 July 2026: the right to repair. For new sales contracts consumers may choose between repair and replacement; after a repair the legal guarantee is extended once by twelve months (Directive (EU) 2024/1799).
What about the withdrawal button?
Already law. Art. 11a of the Consumer Rights Directive requires a function labelled “withdraw from contract here”, continuously available, with a second step labelled only “confirm withdrawal”, followed immediately by an acknowledgement of receipt with date and time. Shops without it have been exposed for almost three months.
What this means for Shopify stores
Shopify ships none of this. There are three options:
- Build it yourself. Theme work, official artwork in 24 languages, an evidence log for withdrawals, transactional e-mails. Realistically several days of agency time – repeated at every theme change.
- Combine several apps. One for withdrawals, one for the guarantee labels. Double the cost, two data-processing agreements, two support addresses.
- One app for all of it. That is what EU Compliance Suite was built for.
Checklist before 27 September
- Withdrawal button on every page, with the official label.
- Add a sentence about the button to your withdrawal policy.
- Show the legal-guarantee notice on product pages or in the cart, in colour and unchanged.
- For products with producer guarantees over two years: record duration, brand and model, display the GARAN label.
- Update your privacy policy for withdrawal data processing.
Frequently asked questions
Does the legal-guarantee notice apply to every shop?
It applies to traders selling goods to consumers in the EU. The notice must be visible before purchase, in colour and unchanged – on the product page or in the cart, not buried in the terms and conditions.
Does every product need a GARAN label?
No. The label is mandatory only where the producer offers, free of charge, a durability guarantee of more than two years covering the entire good. For two years or less it must not be shown.
Is a “withdrawal” link in the footer enough?
No. Art. 11a of the Consumer Rights Directive requires a function labelled “withdraw from contract here”, available on every page, a second step labelled “confirm withdrawal”, and an immediate acknowledgement of receipt on a durable medium.
What happens if the notice is missing on 27 September?
Missing mandatory information is an unfair commercial practice and can be challenged by competitors or consumer associations; national market-surveillance authorities can act as well.
This article is not legal advice. It summarises the situation as of 12 September 2026; when in doubt, please ask a lawyer.