EU Warranty and Guarantee Label in Shopify

From 27 September 2026, a new information requirement will apply to online retail in the EU: the EU warranty label. When selling products with manufacturer’s warranties, the so-called GARAN label must also be displayed. Both labels are standardised across the EU, apply without a transition period and with no exceptions based on shop size or sector. This guide explains the legal basis and shows you how to implement the labels in your Shopify shop.

Key points at a glance

• From 27 September 2026, B2C online retailers must display a standardised EU-wide warranty label in their online shops
• Where a manufacturer’s voluntary guarantee exceeds two years, a guarantee label (GARAN) must also be displayed on the product
• Both labels are strictly standardised in terms of design and text. No alterations – for example, to match your own shop design – may be made.
• The labels must be visible and clearly noticeable to consumers before the contract is concluded. Ideally, they should also be included in the order confirmation.
• Breaches may result in warnings under competition law

What will change from 27 September 2026?

The basis for the new obligation is EU Regulation 2025/1960. It forms part of the so-called EmpCo (Empowering Consumers) package on consumer protection. As this is a regulation and not a directive, it will apply directly from 27 September without first needing to be transposed into German law. The obligation to comply applies to B2C online retailers, regardless of turnover, product range or sector.

Two new, EU-wide standardised labels are being introduced:

• The guarantee label (“harmonised notice”) – compulsory for every sale of goods to consumers.
• The guarantee label or GARAN label (‘harmonised labelling’) – mandatory only if a free manufacturer’s guarantee of more than two years applies to the entire product.

Both labels are required in addition to existing legal documents such as the terms and conditions or the cancellation policy, as part of the online retailer’s additional duty to provide information.

Warranty label vs. guarantee label

Before moving on to the technical implementation, it is worth making a clear distinction between the terms, as this gives rise to different obligations.

The statutory warranty (the seller’s liability for defects, at least two years for new goods) and the voluntary manufacturer’s guarantee remain, in legal terms, two separate matters. The new labels do not alter this in any way – they merely stipulate how information about both must be provided.

What do the labels actually look like?

Both labels are standardised down to the last detail. Customised designs are not permitted – the templates are provided by the European Commission and must be used as they are.

Quality assurance label

• Static graphic in the EU style with a blue border and EU stars
• summarises the statutory rights in respect of defects, refers to the statutory minimum guarantee period of two years, and mentions the possibility of a shorter guarantee period for second-hand goods
• gives specific examples of when a warranty claim arises
• Outline of consumers’ rights in the event of a fault (for example, free repair, free replacement or a refund of the purchase price)
• contains a QR code that links to the EU’s ‘Your Europe’ information page, which provides further detailed information on consumer rights
• is available in a separate language version for all EU languages – the coloured version must be used in the online shop
• must appear in the language of the relevant sales page (for a German-language Shopify shop, this means the German version; for multilingual online shops, the selected language in each case)

Guarantee label (GARAN):

• A standardised design, supplemented by three product-specific details: brand, model code and warranty period
• Legally, this is regarded as warranty advertising – which automatically triggers the obligation to provide the full terms and conditions of the warranty (costs, geographical scope, contact details of the warranty provider)

The following applies to the standard Shopify checkout: it must be displayed in colour, there is no fixed minimum size, but the QR code must remain readable under normal conditions using a standard smartphone.

The files are available to download here free of charge 

Where should the labels appear in the Shopify shop?

The EU regulations do not specify a particular location for the guarantee label, such as ‘below the “Buy” button’. However, they do require that the label:

• clearly recognisable
• clearly visible and
• before placing the order

is integrated. The following locations are therefore possible for correct integration:

• Product details page
• Central to the checkout process

Only the coloured version of the warranty label may be embedded directly as an image. A nested display – such as one that only appears on mouseover or after clicking a tab – is not permitted. Similarly, the label must not simply be displayed as part of a product image gallery.

The guarantee label must also:

• clearly recognisable and
• clearly visible

be incorporated. As a warranty is product-specific, the label must be displayed on the relevant product detail page. Unlike the guarantee label, it cannot be incorporated into the checkout process. However, with the warranty label, it is possible to incorporate it directly as an image or as a nested advert. In the case of a nested advert, care must be taken to ensure that it is clearly visible to the naked eye and is displayed in an equally prominent position on the product detail page.

Why is this particularly relevant for Shopify merchants?

Shopify does not currently support these labels natively. This means that, unless you take action, your shop will not display a legally compliant label on 27 September 2026 – and you will therefore be at risk of receiving a formal warning.

Technical implementation in Shopify: 2 options

There are essentially two ways to carry out integration:

Option 1: Manual implementation via the theme and meta fields

1. Incorporate the warranty label as a static snippet or section within the theme – across the entire shop, as it does not vary from product to product. The official graphic in the appropriate language version is obtained from the European Commission (Annex I of the GDPR or its publication page containing vector files) and incorporated.
2. Create one meta-field per product for the GARAN label (e.g. ‘Manufacturer’s warranty in years’, ‘Brand’, ‘Model code’). The label is only displayed via a Liquid condition if the warranty period exceeds two years and a free manufacturer’s warranty is actually in place.
3. Integration into the checkout: With Shopify Plus, this is possible via Checkout Extensibility or Checkout Branding. Shops without a Plus plan have more limited options here and will need to check which customisations are permitted by their specific checkout configuration.
4. Integration into the order confirmation via the notification templates (Settings → Notifications → Order Confirmation)
5. For multilingual shops, the correct official language version of the label must be provided for each available sales language.

This approach requires knowledge of custom code (Liquid, Metafields, and possibly Checkout Extensibility) and ongoing maintenance, for example when theme updates are released, as these may overwrite the custom code.

Option 2: Shopify app from the App Store

For retailers who wish to avoid the hassle of manual implementation, there are already specialised apps available in the Shopify App Store that automatically comply with the requirements of the regulation. Typical features of such solutions include:

• Automatic inclusion of the warranty label on all product pages, in the customer’s chosen language
• Provision in the relevant official EU languages
• Editable GARAN label showing the make, model and warranty period; can be integrated via a theme block without any code
• Automatic exclusion rules for digital goods, services and B2B sales that are not subject to the labelling requirement
• Centralised management via the dashboard rather than manual updates for each product

The app-based approach significantly reduces the technical workload. However, it does not replace a content check: retailers must still ensure that they accurately maintain a record of which products actually come with a free manufacturer’s warranty of more than two years.

Shopify checklist for EU guarantee labels and warranty labels

• [ ] Check whether any products are being sold that are covered by the statutory guarantee, and if so, which ones
• [ ] Check which products sold come with a free manufacturer’s warranty of more than two years covering the entire item
• [ ] Obtain the official warranty label template in the relevant language version from the European Commission
• [ ] Integrate the warranty label technically into the online shop
• [ ] Prepare the GARAN label for the relevant products via the metafield or the app (brand, model, warranty period)
• [ ] Clarify integration at checkout (Shopify Plus vs. Standard Plan)
• [ ] Add the label(s) to the order confirmation email
• [ ] For multilingual shops: specify the relevant language version for each sales language
• [ ] Provide a link to the full terms and conditions of the guarantee whenever the GARAN label is used
• [ ] Obtain a legal review of the overall implementation before the deadline

Conclusion

27 September 2026 is a fixed deadline with no transition period – for every Shopify shop that sells goods to consumers in the EU. Whilst the warranty label is relatively straightforward to integrate as a static, shop-wide element, the product-specific GARAN label requires meticulous data management via Metafields or a specialised app. Those who plan ahead can complete implementation well before the deadline – those who wait risk an unnecessarily high likelihood of receiving a warning letter from the end of September onwards.

If you need help integrating the warranty or guarantee label into your Shopify shop, please feel free to get in touch with us.