Legal Guarantee Notice and GARAN Label from 27.09.2026

From 27 September 2026, online shops that sell goods to consumers must display two new labels: an EU-wide uniform notice on the statutory legal guarantee and, for certain manufacturer guarantees, a guarantee label called GARAN. Both are prescribed in appearance and wording, and there is no transition period. Shopware has included both labels since 9 September with version 6.7.14.0. This article explains what applies, where the limits lie and what you should do now.

Where the obligation comes from

The basis is an EU directive from 2024, the so-called EmpCo Directive (Directive (EU) 2024/825). Its aim: consumers should know their statutory rights better and be able to distinguish them from voluntary manufacturer guarantees. After all, the two are frequently confused in everyday life.

What the two labels look like is set out in an implementing regulation (Regulation (EU) 2025/1960 of 25 September 2025). It applies from 27 September 2026 in all EU member states. In Germany, the obligation has been enshrined in law since February 2026, specifically in Article 246 § 1 EGBGB (Introductory Act to the German Civil Code); competition law (UWG, German Act Against Unfair Competition) was amended accordingly.

Two labels, two sets of rules

Important for understanding: these are two separate things with different rules. Anyone who confuses them will display either too much or too little.

1. The legal guarantee notice

The notice serves as a reminder that the seller is liable for at least two years for defects that already existed at the time of purchase. This is not a new right; it has existed for a long time. What is new is the obligation to make it visible.

The notice is the same for everyone. Whether you sell bicycles, coffee machines or clothing: anyone who sells physical goods to consumers must display it. Text, symbols, colours and the QR code linking to the EU consumer portal are fixed. Custom wording or design adjustments are not permitted. In online retail, the colour version must be used.

The regulation does not specify in detail exactly where the notice must appear. It requires it to be displayed "in a prominent manner". For online purchases, the directive refers to a general reminder on the website. According to Shopware, the notice must appear before the order is submitted and in the order confirmation. A sentence somewhere in the terms and conditions is generally considered insufficient.

According to § 312 (2) BGB (German Civil Code), certain product groups are not affected, such as food and household items for everyday use. Shops that sell exclusively to businesses are also not affected. The prerequisite, however, is that consumers genuinely cannot place orders there.

2. The GARAN label

The GARAN label is product-specific and depends on a single condition: the manufacturer voluntarily and free of charge guarantees that the product will last longer than two years, and this guarantee applies to the entire product. If this is the case, the label must be displayed. If not, the label must not be displayed.

The label itself is language-neutral; all EU languages are already printed on it. Three details are added per product: the manufacturer's brand, the model designation and the guarantee period in years. A fixed QR code leads to the EU consumer portal. The name GARAN was chosen because it resembles the word for guarantee in several EU languages.

In the online shop, the label should be placed directly with the product. The regulation permits a collapsible short form for this (referred to in the regulation as "nested format"): at first only a compact preview is visible, and on the first mouse hover or first tap the full label opens. Shopware uses this display on the product page.

Three examples from a bicycle shop

Where the line is drawn becomes clear by looking at the product range. A fictional online shop for bicycles and accessories has three typical items:

The bike computer. The manufacturer advertises a three-year guarantee on the complete device, free of charge, without registration. Longer than two years, free of charge, entire product: all conditions are met. The GARAN label belongs on this product.

The trekking bike. The manufacturer provides a five-year guarantee on the frame. Sounds like a clear case, but it isn't. The guarantee only covers the frame, not the gears, brakes or wheels. It therefore does not apply to the entire product. According to the wording of the rule, no GARAN label may be displayed here. The shop may still mention the frame guarantee in the description, just not with the EU label.

The helmet. No manufacturer guarantee, only the statutory legal guarantee. No label. The notice from point 1 still applies.

A fourth case is found in many product ranges: the paid extended guarantee. Even if it runs for five years, it is not free of charge and therefore does not fall under the label. These examples show why Shopware itself writes that reviewing the product range takes the most time in practice.

What happens if you don't comply

From the deadline, a missing notice or a missing label is considered an unfair commercial practice under the UWG. In practice, this means: competitors and consumer associations can issue cease-and-desist letters, and consumers may in certain circumstances claim damages (§§ 5, 5a, 9 UWG). Whether authorities will also actively monitor the issue cannot be estimated at present; law firms consider it likely.

How Shopware 6.7.14.0 implements the labels

Shopware released version 6.7.14.0 on 9 September 2026. Both labels are an integral part of it, in all plans including the Community Edition. On 6.7, you no longer need an extension from the Store for this. You can find all other new features of the release in our changelog for 6.7.14.0; this article covers only the two EU labels.

Regarding the 6.6 series: Shopware has announced that the features will also be provided for 6.6. As of 9 September, however, the official changelog only listed 6.7.14.0; there was no corresponding 6.6 release yet. We will add the version number as soon as it is available.

The legal guarantee notice in the checkout

The notice is switched on under Settings > Cart settings > Checkout, separately per sales channel if required. When the setting is active, a link to the statutory legal guarantee rights appears next to the terms and conditions checkbox on the order confirmation page. It opens the full notice in a dialogue window, from where users can continue to the European Commission's information page. The notice is available in all 24 official EU languages; Shopware selects the language to match the storefront, with English used as a fallback for other languages. The same setting controls a section in the order confirmation email.

A note for context: the regulation provides for the collapsible short form only for the GARAN label. There is no such rule for the legal guarantee notice, and law firms differ in their assessment of whether a link with a dialogue window is sufficient. If you want to be on the safe side, also display the notice in full at a fixed location in the shop, for example on a dedicated information page linked from the footer.

The GARAN label on the product

In the Administration, the product page has a new card Guarantee (GARAN label) with two fields: the guarantee period in months and a toggle for display in the shop. The period field only accepts half-year values above 24 months, i.e. 30, 36, 42 and so on, because the label shows whole and half years. For the bike computer in the example, that would be 36 months. Both fields are inherited by variants.

Shopware takes the brand and model designation from existing product data: the assigned manufacturer and the manufacturer product number. The label only appears if all four points are correct: display switched on, valid period, manufacturer assigned, manufacturer product number maintained. If any detail is missing, the label is not shown. This protects against incomplete labels, but also means that a mandatory label may be missing just because a field is empty.

In the shop, the label initially appears as a preview below the buy box on the product page and can be shown in full size with a click. It also appears with the respective item in the cart, on the order confirmation page and in the confirmation email.

The pitfall: custom email templates

One point from the release information deserves special attention. The order confirmation email template is only automatically updated if it still matches the unmodified default. This applies to new installations and to shops that have never touched this template. Anyone who has ever edited the order confirmation, which is likely to be the norm for established shops, will not automatically get the label and notice in the email. In that case, two snippets must be added to the template manually: {{ nestedItem.productId|sw_garan_label_nested_uri(context) }} for the label per line item and {{ context.languageId|sw_legal_guarantee_notice_link }} for the legal guarantee notice. So after the update, don't just check the shop – place a test order and read the email that arrives.

For shops with a custom frontend

Anyone running Shopware without the standard storefront (headless or Composable Frontend) gets both labels via new Store API routes: /store-api/product/{productId}/garan-label and /store-api/legal-guarantee-notice. In addition, there are Twig filters that output the label as SVG or as an embedded graphic for email clients. Integration into the custom frontend remains the responsibility of the respective project.

What Shopware does not take care of

Shopware provides the technology and states explicitly: the legal review remains the merchant's responsibility. The software does not decide whether a suitable manufacturer guarantee actually exists for a product. Nor does it decide whether the placement in an individually customised shop is sufficiently prominent.

What you should do now

• Review your product range: For which products does the manufacturer provide a free guarantee of more than two years on the entire product? This can only be clarified with the manufacturers, product by product.
• Complete product data: Manufacturer and manufacturer product number must be maintained for every affected product, otherwise no label will be displayed. For variants, check whether inheritance still applies.
• Install the update: 6.7.14.0 is available. On 6.6, wait for the announced follow-up release. On 6.5 or older, the only options are an update or an extension from the Store.
• Switch on the setting: The legal guarantee notice is not automatically active after the update. Check per sales channel.
• Check the email template: If the order confirmation has been edited, add the two snippets and verify with a test order.
• Check the design: Custom adjustments to the buy box or the order confirmation page can hide the new elements. Check on desktop and on smartphone.
• For pure B2B sales: The labels are not required, but only if consumers genuinely cannot place orders from a technical standpoint, not just according to the terms and conditions.

As a side note: according to the IHK Köln (Cologne Chamber of Commerce and Industry), further information obligations come into force on the same date, for example regarding the repairability score (so far only for smartphones and tablets) and the availability of spare parts and repair instructions. That is a separate topic, but it belongs on the same list.

Where to find the original files

On 19 March 2026, the European Commission published practical guidelines for retailers and manufacturers, together with the vector files for both labels in all EU languages, in colour and black and white, plus the GARAN label in the collapsible variant for online retail. Anyone who does not display the labels via Shopware but through their own theme or another system should use only these originals. Recreated graphics are not a safe option.

Our recommendation:
The technical side is manageable: install the update, switch on the setting, check the display and, if you have a custom email template, add two lines. The time-consuming part comes beforehand, with the enquiries to manufacturers and data maintenance. Start on this immediately. There are just over two weeks left until the deadline, and 27 September applies without a transition period. For special cases such as private labels, imported goods, marketplaces or mixed B2B/B2C shops, a legal review is worthwhile. This article is an editorial assessment and does not constitute legal advice.

As of: 11 September 2026

Sources

• Directive (EU) 2024/825 (EmpCo Directive), EUR-Lex
• Implementing Regulation (EU) 2025/1960, EUR-Lex
• Practical guidelines and vector files, European Commission, 19.03.2026
• GARAN label and EU legal guarantee notice, Shopware blog, 07.08.2026
• Release News September 2026: What's new in 6.7.14.0, Shopware blog, 09.09.2026
• RELEASE_INFO-6.7.md, tag v6.7.14.0, Shopware on GitHub
• New labelling obligations under the EmpCo Directive, Noerr, 23.07.2026
• The new legal guarantee label in German, IT-Recht Kanzlei, 26.01.2026
• Guarantees and legal guarantee: new information obligations, IHK Köln