The legal guarantee notice and durability label in your online store

What changed for online retailers on 27 September 2026?

Directive (EU) 2024/825 on empowering consumers for the green transition amends two older directives: the Unfair Commercial Practices Directive and the Consumer Rights Directive. Member states had to transpose it by 27 March 2026, and it has applied since 27 September 2026. Both dates are in the text of the directive, not in anyone's forecast.

For an online store this lands as three things at once. The buyer has to learn, before buying, that a legal guarantee of conformity exists, even when the seller promises nothing on top of it. A commercial guarantee of durability offered by a producer for more than two years is shown with a harmonised label whose design the European Commission sets. And claims about environmental performance may not be generic or unverifiable.

The date was not a grace period. The obligation applies to sales completed after it, not to products you happen to publish later. A store that kept selling on 28 September 2026 with descriptions written in August was selling under the new rule with the old content.

What is the legal guarantee, and why is it not a warranty?

The legal guarantee of conformity is a right the buyer has by law, and nobody issues a document for it. Under Directive (EU) 2019/771 the seller is liable for lack of conformity for at least two years from delivery, and some countries set longer periods or special rules for second-hand goods. A seller cannot contract out of it in the terms and conditions.

A warranty is a different thing. It is a voluntary promise by the seller or the producer that sits on top of the legal guarantee and cannot replace it. That distinction has been a source of confusion for years: the buyer read "1 year warranty" and concluded that after one year there was nothing left, while the legal guarantee was still running through the second year.

So the new rule does not create a right. It makes an existing one visible. The buyer has to be reminded of the legal guarantee before buying, in language they understand, and not in the third paragraph of terms three clicks away.

Where does the notice have to appear?

The directive speaks about pre-contractual information. For an online store that means the product page and the step before order confirmation, because those are the only two places a buyer reliably sees.

A sensible baseline is three places. On the product page, a short line next to the price or the add-to-cart button. In the cart or on the final checkout step, the same line, because buyers often land straight in the cart from an ad. And in the order confirmation email, because the buyer keeps that and will read it exactly when something goes wrong.

What to avoid: a notice only in the footer, a notice that appears only after clicking a small question mark, and a notice written in one language while the store sells in five. The text has to be in the language the purchase runs in.

This is not legal advice. The directive text is linked below the article and is the authority; for special cases such as second-hand goods, auctions and business-to-business sales, talk to your own lawyer.

When do you need the durability label, and when must you not use it?

The harmonised label is tied to a commercial guarantee of durability given by the producer for a period longer than two years and covering the whole product. Where there is no such guarantee, the label is not required and must not be shown: a label on a product without the guarantee is a claim that is not true.

That is why, in a well-built store, the label is conditional. It appears when the product record carries a guarantee period longer than two years, and disappears when that record is absent. The opposite approach, a label on everything with manual exceptions, breaks on the first import from a new supplier.

The Commission sets the design of the label in an implementing act, so do not draw your own and do not repaint it in your brand colours. A single appearance is the entire point of the measure: the buyer should recognise the same label in a Slovenian, a German and a Polish store.

Why is 2 year warranty in the product description not enough?

A product description is free text. A supplier can overwrite it on the next import, a translation tool can shorten it, and an editor can lose it while copying. An obligation that lives in free text fails on the first bulk price-list import.

The second reason is verifiability. A sentence in the description does not say whether it refers to the legal guarantee or to a commercial warranty, and that is precisely the ambiguity the new rule is meant to remove. The phrase "2 year warranty" is redundant at best and misleading at worst, because it presents a statutory right as a favour from the shop.

The third reason is maintenance. When the rule changes you want to edit one setting, not three thousand descriptions. So let the notice come from the system, not from text a person typed while entering a product.

What counts as an unfair green claim?

The same package bans generic environmental claims without substantiation. Words like eco-friendly, green, natural and climate neutral may not appear in an advert or on a product page without recognised evidence behind them.

Also banned: a neutrality claim based only on emission offsetting, and presenting a requirement the law already imposes as a special advantage of the product. That last trap is common in online stores, where packaging free of a banned substance is not an advantage but a condition of sale.

The working rule is simple and you can enforce it yourself. Every environmental claim on a product page should sit next to a source, a figure or a certificate. Anything without one gets removed, not softened with a more careful word. A claim without evidence stays a claim without evidence, even after you add the word "helps".

What about software updates and digital elements?

More and more products carry a software part: a smart plug, a scale, a bike computer, a speaker. For those products the buyer also cares how long updates will keep coming, because without them the product becomes unusable long before it wears out.

The 2024 package therefore adds, to pre-purchase information, the period for which the producer provides free software updates, where that period is known. It is information, not a promise by the shop: copy it from the producer's data and do not estimate it yourself.

For a store that means one more field on the product record. When the field is empty, the line does not render. When it is filled, it renders in the same block as the legal guarantee notice, because the buyer reads both at the same moment: just before clicking buy.

What happens in an enforcement check?

Enforcement sits with national consumer protection authorities, and the level of penalties is set in national law rather than in the directive, so it differs by country. A store that sells into several countries is supervised in each of them.

In practice a case starts with a buyer complaint or a routine sweep of websites, not with a visit. What gets examined is what is publicly visible: the product page, the cart, the terms and the advert. That is why a tidy public page is the cheapest defence, not a folder of evidence.

A record of what the buyer saw, and when, is the second half of that defence. A system that stores the version of the terms shown at order time answers a question with data. A system that does not stores nothing and answers with memory.

How do you do this in WooCommerce and Shopify without manual work?

The obligation splits into two parts: text that is identical for every product, and data that differs per product.

The legal guarantee notice is the same for every product in a given country, so it belongs in a setting, not in the product. Set it once per language and market; a change in the law then means one edit, not a new import file.

The durability guarantee is specific to each product and belongs on the product record as a number of months. Render the label from that field, never from a manual flag. When the field arrives from a supplier price list the label appears by itself, and when the supplier drops the guarantee the label disappears by itself.

In Entexia the system carries both. The notice lives in store settings per language, the guarantee period lives on the product, and both travel to WooCommerce or Shopify on sync without anyone editing the shop by hand. Because the display is computed from data, it is consistent across every language the store sells in.

A checklist before your next product goes live

Five checks you can run today without involving anybody else.

One: open a random product page and count the clicks to the legal guarantee notice. More than zero is too many.

Two: open that same page in every language you sell in. A missing translation is the same failure as a missing notice.

Three: find a product with a guarantee longer than two years and check that it carries the label. Then find one without such a guarantee and check that it does not.

Four: search your own store for "eco-friendly" and read the hits. Every hit without a source is a task for today.

Five: place a test order and read the confirmation email. If it says nothing about the legal guarantee, the only thing that ever saw your notice was a browser, not a buyer.