What is a guarantee label?
A guarantee label in the EU consists of two official instruments from the EmpCo Directive. The harmonised notice reminds consumers of the legal guarantee of at least two years. The GARAN label shows a voluntary commercial durability guarantee of more than two years. Both have a fixed, EU-wide design that you may not change.
The instruments come from the EmpCo Directive, Directive (EU) 2024/825. A Commission implementing regulation works out the precise form. They refer to each other, so the consumer sees the difference between the legal guarantee and a voluntary longer guarantee.
| Instrument | What it does | Who applies it |
|---|---|---|
| Harmonised notice | Reminds of the legal guarantee of at least two years | The seller, in store or online |
| GARAN label | Shows a commercial durability guarantee of more than two years | The manufacturer, on the product or the packaging |
What is the legal guarantee?
The legal guarantee is the consumer’s right to a product that meets what can reasonably be expected of it. It follows from Directive (EU) 2019/771 and is set out in the Civil Code. The minimum period is two years, but in the Netherlands it can be longer, depending on the product.
In the Netherlands the period is not pinned to two years. The conformity rule in Article 7:17 of the Civil Code ties in with the expected lifespan: you may expect longer use from a washing machine than from cheap earbuds. The liable party is the seller, not the manufacturer in Asia.
What is the harmonised notice?
The harmonised notice points the consumer to the legal guarantee of at least two years. It has a fixed format with a QR code to more information. As a seller you show it in a prominent place: a poster in the store, at the checkout or a fixed reference on your website.
In print the notice may not be smaller than A4. In store it may be in colour or black and white, online it must be in colour. The official files in all EU languages can be downloaded via Your Europe, so you do not have to design anything yourself.
When do you use the GARAN label?
The GARAN label is mandatory as soon as you, as the manufacturer, offer a commercial durability guarantee that is free of charge, covers the whole product and lasts longer than two years. If your guarantee meets that, you use the label. A guarantee on only one component does not fall under it.
The label stands for that voluntary promise: under normal use the product keeps its functions for the stated number of years. If it does not, you as the manufacturer repair or replace free of charge. In addition you supply a commercial guarantee statement that refers to the legal guarantee.
What does the GARAN label look like?
The GARAN label has a fixed design that you may not change. It contains the title GARAN, a checkmark as a sign of durability, a calendar pictogram with the number of years, a reminder of the legal guarantee and a QR code. You only adjust the duration, your brand and the type designation.
The fixed elements are set at EU level:
- The title GARAN with a checkmark as a symbol of durability.
- A calendar pictogram with the number of years the durability guarantee applies.
- A reminder of the legal guarantee of conformity, so both guarantees are visible side by side.
- A QR code to information about the GARAN label in all EU languages.
- Fixed minimum sizes: in print no smaller than 95 by 100 mm, in colour or black and white. Online always in colour, with an enlargeable view.
You fill in three things yourself: the duration of the guarantee in years, your brand or trademark and the type designation of the product. The editable vector files are ready to download in several languages via Your Europe.
The European Commission makes the GARAN label, the harmonised notice and the practical guidelines available free of charge in all EU languages. Download everything on the European Commission’s publication page. Directly: the GARAN label (zip) and the practical guidelines (pdf).
A loose slogan like five-year guarantee is not a GARAN label. If you want to carry the official label, your guarantee must be free of charge, cover the whole product and last longer than two years. You may offer other guarantees, but not in a way that makes the consumer confuse them with the GARAN durability guarantee.
Who is responsible, the manufacturer or the seller?
The legal guarantee is a matter between the consumer and the seller. If you put your own brand on the product, you are often the seller yourself via your webshop or marketplace. As the manufacturer you also decide whether you offer a durability guarantee and therefore carry the GARAN label.
For a brand that has production done in Asia and sells under its own name, those two roles come together. You are the party that must show the notice at the point of sale. And you are the party that decides whether a GARAN label belongs with the product. It is best to settle both choices before sales in the EU start.
Not sure about your guarantee information?
Let us know briefly which product it concerns. We will get in touch with what we can do and what it costs.
May you use the guarantee as a selling point?
You may not present the legal guarantee as a distinctive feature of your offer. It applies to every product, so it distinguishes nothing. That same prohibition in the EmpCo Directive also affects promoting CE marking and other legal requirements. Promoting a commercial guarantee is allowed, as long as it genuinely goes further.
This is where the two sides of the EmpCo Directive meet. The environmental claim rules and the guarantee rules come from the same law. What is legally required you may not present as a plus. What you voluntarily offer on top you may show, provided it is true and verifiable.
What to arrange now
Before 27 September 2026, check how you communicate the legal guarantee. Set up the harmonised notice on your webshop and in store. Decide whether you want to carry a durability guarantee of more than two years. Make sure no guarantee text limits the consumer’s legal rights.
- Download the official harmonised notice via Your Europe and put it on your webshop and at your point of sale.
- Decide whether you give a genuine durability guarantee of more than two years. If so, draw up the GARAN label with your brand, the type designation and the duration in years.
- Draw up the commercial guarantee statement and supply it in a durable medium, with the reference to the legal guarantee in it.
- Review your current guarantee texts and remove anything that limits legal rights or presents an obligation as a plus.
- European Commission, Your Europe: the notice on the legal guarantee and the EU’s GARAN label (form, mandatory elements and downloadable files), europa.eu/youreurope
- Directive (EU) 2024/825 (EmpCo), Article 22a on the harmonised notice and the harmonised label, applying from 27 September 2026, plus the Commission implementing regulation on form and content, text on EUR-Lex
- Directive (EU) 2019/771 on the sale of goods (the legal guarantee of conformity), text on EUR-Lex
- Dutch Civil Code: conformity in Article 7:17 and the pre-contractual information duties in Article 6:230m
Lawyer with a background in e-commerce. Writes about the rules he applies daily in files for brands and manufacturers. More about Francois or connect on LinkedIn.
Frequently asked questions
Does the legal guarantee also apply if I give a one-year manufacturer’s guarantee?
When must I use the GARAN label?
From when do these guarantee rules apply?
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