The new EU guarantee notice your listings need from 27 September

You sorted your GPSR paperwork. Good. Here is a completely different EU rule landing on 27 September 2026, roughly a month from now, that applies to the same listings and that almost nobody in the Etsy and Amazon seller forums is talking about yet.

Short version: from that date, if you sell physical goods to consumers in the EU, you have to show them a standardised legal guarantee notice. Not your own wording about returns. A specific, EU-designed graphic with a QR code in it, which you download and display as-is.

This has nothing to do with GPSR. You can have a perfect technical file, a named EU Responsible Person and every safety field filled in, and still be missing this.

What actually changes on 27 September

EU consumers already have a minimum two-year legal guarantee on goods they buy. That is not new, it comes from the Sale of Goods Directive (EU) 2019/771. What is new is that traders now have to actively tell buyers about it, in words the Commission wrote rather than words you wrote.

Two instruments do the work:

Directive (EU) 2024/825, the "empowering consumers for the green transition" directive, which amends EU consumer law and sets the 27 September 2026 application date.
Commission Implementing Regulation (EU) 2025/1960, adopted 25 September 2025, which fixes the exact design of the notice and of a second thing called the GARAN label.

There is no transitional period. Neither instrument gives you a grace window, so 27 September is the date, not the start of a phase-in.

The notice is a file you download, not text you write

This is the bit that trips people up. The legal guarantee notice is not a paragraph you draft for your shop policies. It is a fixed piece of artwork, published by the Commission in all 24 official EU languages, and the rules on it are strict:

Use only the official template files. Colours, typography, spacing, borders and the QR code must not be altered.
Do not crop it, stretch it, or add your own elements to it.
Online, it must be in colour. Black and white is only allowed for physical shop displays.
When printed it cannot be smaller than A4.
The QR code has to stay scannable. It points buyers to the official EU explanation of their guarantee rights.

You can get the files, in every language and in PDF, PNG, JPG and SVG, from the Commission's own page: practical guidelines and high-resolution vector files. Download the languages that match the markets you actually ship to.

What the notice tells the buyer, in case you are wondering what you are displaying: the two-year minimum guarantee, when they can use it, what remedies they get (repair, replacement, price reduction or refund), how to complain, and that national law may give them longer.

Where it has to go

Honestly, this is the part where the official guidance is looser than you would like, and where the various law-firm write-ups do not fully agree.

Your Europe, the Commission's own business portal, says the notice must be shown "in a prominent manner", and for e-commerce describes it as a general reminder on your website. Several commercial analyses go further and put it on the product page before the buyer orders, and in the order confirmation.

The common thread is before the order is placed, and prominent. So the safe reading, and the one I would build to, is:

On the product listing, or somewhere clearly visible from it.
Again at checkout, before the buyer commits.
In the order confirmation.

Nested or expandable display is allowed online, so a compact preview that opens the full-size notice on click is acceptable. It does not have to dominate your page.

If you sell on Etsy or Amazon, you control less of this than you think

Here is the practical problem for the sellers I work with. You do not own your checkout. You cannot add a graphic to Etsy's order confirmation email. If the notice genuinely has to appear at the point of order, that is a marketplace implementation job, not a seller one, and the marketplaces have a month to do it.

So the realistic split:

What the platform will almost certainly handle: checkout display, order confirmations, language selection per buyer.
What you control: your listing descriptions, your shop policies page, your shop announcement, and anything you send with the parcel.
What you should do now: watch for a seller announcement from your marketplace. If nothing has landed by mid-September, put the notice in your shop policies and in the listing description yourself. It is a one-off copy and paste per listing template, and it is far cheaper than arguing about it later.

If you sell from your own Shopify, WooCommerce or Shopware store, this is fully on you. Shopware has already shipped support for it, which tells you the platforms are taking the date seriously.

The GARAN label: most of you can ignore this

The same implementing regulation creates a second thing, a durability label called GARAN. It gets mentioned in the same breath as the notice, which makes people think they need both. Most small sellers do not.

GARAN is only triggered when a producer offers a commercial guarantee of durability that meets all of these at once:

longer than two years, and
covering the entire product, not just a component, and
at no additional cost to the buyer.

Offer nothing beyond the statutory two years, which is what almost every handmade seller does, and GARAN never applies to you. Advertise "lifetime guarantee on every piece, free" in your shop, and it does, and then you are using the official label with its three editable fields (duration in years, your brand or trademark, and the model identifier) and nothing else changed.

Worth reading your own shop copy for this. "Guaranteed for life" is the sort of warm marketing line makers write without thinking of it as a legal commitment, and after 27 September it is one.

Does this apply to me if I am not in the EU?

Assume yes.

No source I reviewed carves out sellers established outside the EU, and EU consumer law generally attaches to where the consumer is, not where the trader is. If you are a UK or US seller who advertises to and ships to EU buyers, you are the trader in a contract with an EU consumer, and the two-year legal guarantee already applies to you. The notice is just the requirement to say so out loud.

Same logic applies to size: there is no small-business or micro-seller exemption in either instrument. Same as GPSR, which by now you will find depressingly familiar.

What to actually do about it

In rough priority order, and none of this takes long:

Download the notice in the languages of your top EU markets from the Commission's file page. Ten minutes.
Check your marketplace's seller announcements for their implementation plan. Do not assume silence means it is handled.
Add the notice to your shop policies page now, and to your listing description template if you use one. It costs you nothing to be early.
Read your own guarantee wording. Any "lifetime", "forever" or "we will always replace it" claim needs checking against the GARAN trigger.
Diary 27 September. If your platform has not shipped anything by then, you want the notice in your own listings before the date, not after.

Where GPSRHub sits on this, honestly

It does not cover it, and I am not going to pretend otherwise. GPSRHub generates the GPSR side: your technical file, your risk assessment, your Declaration of Conformity and your labelling sheet, and can act as your EU Responsible Person. The guarantee notice is consumer contract law, a different regime with a different deadline, and it is a download-and-display job rather than a documentation job.

What is worth noticing is the pattern. The €3 parcel duty in July, this in September, GPSR underneath both. Selling into the EU from outside is becoming a paperwork discipline, and the sellers who quietly keep a folder of current documents are the ones who will still be shipping there in two years.

If you have not done the GPSR half, that is the harder half and the one with real fines attached. The compliance checker is ten questions, takes about two minutes, and tells you exactly which documents you are missing. It is free.

Quick FAQ

When does the legal guarantee notice become mandatory? 27 September 2026, with no transitional period.

Can I write my own version of the notice? No. You must use the official Commission template without altering its design, colours, typography or QR code.

Is there a small-business exemption? None identified in either Directive (EU) 2024/825 or Implementing Regulation (EU) 2025/1960.

Do I need the GARAN label? Only if you offer a free durability guarantee of more than two years covering the whole product. Most handmade sellers do not.

Does this replace anything in GPSR? No. They are separate regimes with separate obligations. You need both.

Does it apply to second-hand goods? Second-hand goods sold by a professional trader are generally within consumer guarantee law, so yes, though the legal guarantee period can be shortened by agreement to no less than one year in some member states.