From 27 September, EU law forces every seller of physical goods to display a fixed-format guarantee notice: a durability promise beyond two years now triggers a second, mandatory label too

What actually changed on 27 September

Directive (EU) 2019/771 already guarantees every EU consumer a minimum two-year legal guarantee of conformity on new goods: if a product does not match its description or stops working as it should within that window, the seller must repair it, replace it, reduce its price or refund it, free of charge. What Directive (EU) 2024/825 added, and what Implementing Regulation (EU) 2025/1960 now gives a fixed shape, is the duty to actually tell the consumer about that guarantee, in the same standardised wording and layout, everywhere in the EU. From 27 September 2026, every seller of consumer goods, in a physical shop and in an online store alike, must display this harmonised notice at the point of sale; its content and form are set by the Regulation and cannot be edited, shortened or restyled to fit a brand's own design. Separately, the same Regulation defines a second instrument, the GARAN label, for sellers that go further and promise a commercial guarantee of durability: a producer's own commitment that a good will keep working for a stated period beyond the statutory two years. That label becomes mandatory, not optional, once four conditions are all met: the guarantee is free of charge, it covers the entire good rather than a single component, it runs longer than two years, and the producer has made its terms available to the seller. Meet those four conditions, and anything other than the official format, the word GARAN, a tick mark, a calendar symbol showing the guaranteed duration, a reminder of the legal guarantee, and a QR code linking to more information, is itself a breach.

The numbers behind the deadline

One number marks the application date itself. One marks how much of the EU has not finished the underlying national law. The third is the fine a cross-border case can draw once it is enforced.

The real subject: an EU-wide label standing on national laws that mostly do not exist yet

Most coverage of the 27 September deadline reports a single, clean date: the EU now requires a guarantee notice, full stop. What that framing skips is that two different kinds of EU law are doing two different jobs here, and only one of them was ready on time. Implementing Regulation (EU) 2025/1960 is a Regulation: it applies directly in every member state without needing a national law to carry it, which is why its design specifications, the notice's exact wording, the GARAN label's tick mark and QR code, are identical from Lisbon to Helsinki from day one. But the underlying legal duty that makes displaying that notice mandatory, and the sanctions for not displaying it, come from Directive (EU) 2024/825, and a Directive only binds through whatever each member state writes into its own law. Twenty of the 27 states had not finished that writing when the clock ran out. The Commission's answer is not to postpone the date; it is to expect full application everywhere from 27 September 2026 regardless, while separately pressing the 20 states through infringement proceedings to finish their transposition. A brand selling the same product across France, Germany and Poland this week is looking at one fixed EU label design sitting on top of three different, unevenly finished national legal foundations, in a market where enforcement, if it comes, may run through a national guarantee law still being drafted rather than through a settled one.

Why it matters for brands

Three groups should read past the headline date. First, any brand selling physical consumer goods across several EU markets, from apparel and footwear to sporting goods, leather goods and household products, now needs the harmonised notice live at the point of sale for every SKU, in every physical store and every online listing, in every EU language it sells in, from 27 September, with no phase-in and no exemption for smaller sellers. Second, brands should audit their own marketing copy before assuming the GARAN label does not apply to them: any existing claim that a product is 'guaranteed for five years' or 'built to last a decade', if it is free of charge and covers the whole product, already meets three of the four conditions that make the label mandatory, which means language written for marketing purposes can trigger a labelling duty nobody on the compliance side signed off on. Third, enforcement is uneven by design right now: in the seven member states that transposed on time, a national consumer-protection authority already has a settled law to apply; in the 20 that have not, including France, where the transposition bill was still pending before the National Assembly as this deadline passed, the domestic legal basis is unsettled, though the EU's coordinated cross-border mechanism can still reach a widespread infringement with turnover-based fines regardless of any single country's transposition status. For a brand managing guarantee terms as marketing copy in one country and as compliance data in another, this is a governance problem before it is a design problem: matching each SKU's actual guarantee terms against the label's four legal conditions, consistently, across every market and every channel, is exactly the kind of structured product data question that a generic legal update does not answer on its own.

Two ways to read the 27 September deadline

Frequently asked questions

Sources

1. EUR-Lex: Commission Implementing Regulation (EU) 2025/1960 of 25 September 2025 laying down the design and content of the harmonised notice on the legal guarantee of conformity and of the harmonised label for the commercial guarantee of durability
2. EUR-Lex: Directive (EU) 2024/825 of the European Parliament and of the Council of 28 February 2024, on Articles 4 and its amendments to Directive 2005/29/EC and Directive 2011/83/EU
3. EUR-Lex: Directive (EU) 2019/771 of the European Parliament and of the Council on certain aspects concerning contracts for the sale of goods, on the minimum two-year legal guarantee of conformity
4. European Commission, infringement decision INF_26_1097 of 28 May 2026, opening infringement proceedings against 20 member states for failing to notify full transposition of Directive (EU) 2024/825
5. Latham & Watkins: "EU Empowering Consumers Directive: New Rules on Green Claims Apply From 27 September 2026," corroborating the transposition deadline, application date and the 20-state infringement count
6. Bird & Bird: "Part II, FAQ: The new EU Legal Guarantee Notice and GARAN Label," corroborating the four conditions that make the GARAN label mandatory and the notice's fixed, non-editable format
7. Jones Day, TrendingNow in ESG: "EU Commission Pushes for Transposition of the EmpCo Directive on Environmental Claims," corroborating that only 7 of 27 member states met the 27 March 2026 deadline and naming France among the 20 that did not
8. Bureau Veritas: "Summary of Commission Implementing Regulation (EU) 2025/1960," corroborating the GARAN label's required visual elements (title, tick mark, calendar symbol, legal guarantee reminder, QR code)

Note on verification: this session's network access allows search but blocks direct page retrieval from eur-lex.europa.eu, ec.europa.eu, europa.eu and every law-firm and compliance-vendor domain cited above. The regulation numbers, Commission Implementing Regulation (EU) 2025/1960 and Directive (EU) 2024/825, their adoption dates, and the 27 March 2026 and 27 September 2026 deadlines were confirmed through search-indexed excerpts of the EUR-Lex texts themselves, cross-checked against independent summaries from Latham & Watkins, Bird & Bird, Jones Day, Fieldfisher, the Irish government's enterprise agency and Bureau Veritas, all of which independently state the same dates. The infringement count, 20 of 27 member states, and the naming of France among them, were confirmed through Jones Day's and Mondaq's independent reporting, both citing the European Commission's own 28 May 2026 infringement decision, whose official document address is given above for independent verification. Where a figure or claim could not be cross-checked across at least two independent sources, it has been left out of this article; no specific EU-wide penalty amount is stated for a single-country breach because the Regulation itself sets none, only the separate cross-border mechanism's 4% turnover or EUR 2,000,000 threshold, which is confirmed across multiple independent sources cited above.