Does your "lifetime guarantee" need the EU GARAN label?

Some handmade shops carry a line like "lifetime guarantee on every piece". It reads as confidence in your work, and until now it was mostly a marketing decision.

From 27 September 2026 it can also be a labelling decision. The EU's new GARAN label covers exactly this kind of promise, and it comes with a fixed design, a QR code and a number of years that has to be filled in. There is no box on it that says "lifetime".

This post is for makers who promise more than two years. If you do not, the only guarantee requirement you need to deal with from 27 September is the legal guarantee notice, which I covered in the EU legal guarantee notice explainer.

In short

The GARAN label is the EU's harmonised label for a producer's commercial guarantee of durability, set by Implementing Regulation (EU) 2025/1960.

It applies when a producer offers a guarantee that is free, covers the whole product, and lasts more than two years. All three at once.

Sellers must then display the label for the goods it covers. If you make what you sell, that is you twice over.

The label shows the duration in years: whole numbers or half years, like 5 or 2,5. The Commission's guidelines say nothing about "lifetime".

Your options: put a number on it, narrow it so it is clearly not a whole-product durability guarantee, or drop it.

What the GARAN label is

The EU GARAN label is a fixed graphic that tells a buyer the producer guarantees the product will keep working, free of charge, for a stated number of years that is longer than two. It sits alongside the legal guarantee notice, and the two designs cross-refer so buyers can tell them apart.

The difference matters:

The legal guarantee is the seller's liability for faults, set by law. You cannot opt out of it. The notice just announces it.
A commercial guarantee of durability is a voluntary promise by the producer. You choose to give it. GARAN is the label for it.

The duties split too. According to the Commission's practical guidelines, producers decide whether to offer the guarantee and describe its terms, and "sellers are required to display the EU GARAN label in a prominent manner" for the goods it covers. If you make what you sell, both sides land on you.

Does your guarantee trigger it?

Check your shop wording against the three conditions in the guidelines. The label is for a producer's guarantee offered:

at no additional cost to the buyer,
covering the entire good, not just a component, and
for more than two years.

Some typical shop wording, and how it reads against those conditions:

Your shop says	GARAN?	Why
"Handmade to last"	No	A description, not a guarantee
"2-year guarantee on all pieces"	No	Not more than two years
"Lifetime guarantee, free repairs or replacement"	Likely yes	Appears free, whole piece, longer than two years
"5-year guarantee, £10 postage for repairs"	Check carefully	A cost to the buyer may take it outside "no additional cost"
"Free lifetime re-soldering of the clasp"	No, but see below	Covers a component, not the whole piece
"Extended 5-year cover for £15 at checkout"	No	Paid, so not at no additional cost

The "lifetime guarantee" and "£10 postage" rows are where I would want a lawyer's view before relying on my reading. The others are clear.

The "lifetime" problem

The GARAN label has three editable fields, and the first one is the duration. The Commission's guidelines say it is "the corresponding duration in years", shown as whole numbers (3, 5, 8, 11 and so on) or half years with a comma (2,5 or 4,5). No other decimals are allowed. A word like "lifetime" is not a number of years.

I could not find anything in the Commission's guidelines or its Your Europe pages that deals with a lifetime or unlimited guarantee directly. So I am not going to tell you what an enforcement authority would say. What I can tell you is that a free, whole-product "lifetime" promise appears to meet all three conditions, and the label it points to cannot express it.

That leaves three sensible routes.

Option 1: put a number on it

Change "lifetime guarantee" to a fixed period you are genuinely willing to honour, say 5 or 10 years, and use the GARAN label properly. This is the cleanest route if the guarantee is part of your brand.

On Etsy, you do not build the label yourself. Etsy's listing form now has GARAN fields for the duration, your brand name and the model identifier, and Etsy surfaces the label on the listing from those (Etsy Help). Fill in the commercial guarantee terms field too. The guidelines also want the label "shown directly before the consumer places his/her order", in the confirmation email, and with a clickable link to the page its QR code opens. Etsy's article does not say whether it covers checkout or email, so treat those as Etsy's to confirm, the same gap as with the notice.

On your own website, edit the official label from the Commission's file page. Only three fields change: the years, your brand name and the model identifier. The font stays Inter, the QR code is untouched and at least 2 x 2 cm, and in print the label is at least 95 x 100 mm. Show it with the product before purchase (colour is the preferred version), at checkout, and in the confirmation email, with a clickable link to the page the QR code opens.

Everywhere, give the buyer a commercial guarantee statement in a durable form, such as a paper card in the parcel or an email, no later than delivery. Under Article 17 of the Sale of Goods Directive it must say that their legal rights against the seller are unaffected, and give your name and address, how to claim, which goods it covers and the terms. The guidelines suggest putting the label in the parcel with that statement, which is easy if you already send a care card.

The model identifier is the awkward field for one-of-a-kind work. Use a design or model code, the kind that stays the same for every piece made to that design, not a batch code, which identifies one production run. I covered how those two differ in what to put in Etsy's GPSR fields.

Option 2: narrow it

If what you actually mean is "I will fix the clasp" or "free re-plating", say exactly that. A guarantee that covers a part, not the whole piece, is outside GARAN.

The catch is in the guidelines: producers and sellers can offer other kinds of commercial guarantee "under the condition this will not confuse consumers" with the GARAN one. So write it so nobody could read it as a whole-product promise: "Free clasp repairs for the life of the piece. This covers the clasp only."

A narrower promise is still a commercial guarantee, so the Article 17 statement described above still applies.

Option 3: drop it

Stop offering anything beyond the law. That costs you nothing extra, and for a lot of small shops it is the right answer.

One trap here. It is tempting to replace the lifetime line with "every piece comes with a two-year guarantee" as a selling point. EU consumer law bans presenting rights buyers already have by law as a special feature of your offer (point 10 of Annex I to the Unfair Commercial Practices Directive). If you mention it at all, keep it neutral: "Your EU legal guarantee rights apply as normal."

"I resell vintage, the guarantee is mine, not the maker's"

The GARAN label is specifically for a guarantee offered by the producer. If you resell vintage pieces and offer your own free guarantee, you are not the producer, so the GARAN label is not the tool for it. Your promise is still a commercial guarantee, though, and the Article 17 statement still applies. Keep the wording plain and do not borrow the GARAN design for it.

What to do before 27 September

Search your shop for guarantee words: lifetime, forever, for life, guaranteed, warranty. Check your About section, policies, listing template and any card you put in parcels.
Run each one through the three conditions above.
Pick a route for anything that triggers it: a number with the label, a narrower promise, or nothing beyond the legal guarantee.
Do the legal guarantee notice anyway. That one is not optional, and I wrote up what to check on Etsy step by step.

None of this is GPSR, and GPSRHub does not produce guarantee labels. If your safety documents are the bigger gap, the free compliance checker takes about two minutes.

FAQ

Is the GARAN label mandatory?

Offering a durability guarantee is voluntary. If a producer does offer a free one covering the whole product for more than two years, sellers must display the harmonised label for those goods from 27 September 2026.

Does Etsy have a GARAN label option?

Yes. Etsy's listing form has fields for the guarantee duration, brand name and model identifier, and surfaces the GARAN label from them. Etsy says you are responsible for the accuracy of what you enter.

Can I write "lifetime" on the GARAN label?

The guidelines only describe a number of years in that field, whole or half years. They do not mention lifetime guarantees, so the safe approach is a fixed number of years.

Can I change the GARAN label's colours to match my brand?

No. Only the duration, brand name and model identifier are editable. Colours, font, spacing and the QR code stay as published.

Does the GARAN label replace the legal guarantee notice?

No. They are separate. Every trader needs the notice. The label comes in only when a producer offers a qualifying durability guarantee, and then sellers must display it for the goods it covers.

I charge postage for guarantee repairs. Does GARAN apply?

The condition is "at no additional cost to the consumer". A charge may take your guarantee outside it, but that is a question to check with a consumer law adviser rather than assume either way.

Sources

European Commission: practical guidelines for sellers and producers, and high-resolution vector files (guidelines dated April 2026)
Commission Implementing Regulation (EU) 2025/1960
Directive (EU) 2019/771 on contracts for the sale of goods, Article 17
Directive 2005/29/EC on unfair commercial practices, Annex I, point 10
Your Europe: the EU legal guarantee notice and GARAN label
Etsy Help: EU Empowering Consumers for the Green Transition Directive (ECGT) (updated 15 September 2026)
Your Europe for consumers: commercial guarantee of durability