EU GARAN from 27 September 2026: Implement the QR Code and Online Shop Correctly

From 27 September 2026, sellers must use a harmonised EU notice to inform consumers about the legal guarantee in physical stores and online commerce. A separate EU GARAN label is available for certain voluntary commercial guarantees of durability offered by producers. Both design elements contain an official QR code. They serve different purposes, however, and cannot be treated as freely editable campaign or product labels.

For e-commerce teams, this is primarily a mapping task. The legal-guarantee notice operates at shop level, while the GARAN label belongs to a specific product model. Each QR code leads to an EU-defined information destination. Product-specific guarantee terms, service processes and a company's own landing pages remain separate.

Two elements with different conditions

Commission Implementing Regulation (EU) 2025/1960 was adopted on 25 September 2025, published in the Official Journal on 2 October 2025 and applies from 27 September 2026. It defines the design and content of both the harmonised notice on the legal guarantee of conformity and the GARAN label.

The notice is general information at the point of sale. Sellers must display it prominently because it reminds consumers of the main elements of the legal guarantee. The Regulation refers to a minimum duration of two years and notes that national law may provide for a longer period. The notice is not reserved for any one product.

The GARAN label is product-specific and subject to narrower conditions. It applies only where a producer offers, at no additional cost, a voluntary commercial guarantee of durability for more than two years, covering the entire good, and makes that information available to the seller. The seller must then display the label in a way that allows consumers to identify the covered product. A guarantee for selected components, a paid extension or a term of exactly two years does not meet these conditions.

The same distinction should exist in the shop's data model. The legal-guarantee notice is a shop-wide, language-specific resource. The GARAN label needs a reliable relationship to the producer, model identifier and guarantee period; a general banner can wrongly imply coverage of an entire range.

The official QR code is not your guarantee link

Both EU elements contain a QR code, but its destination has already been defined. The notice links to the appropriate language section on the Your Europe portal, which provides further information about the legal guarantee and access to country-specific sources. The GARAN label links to the fixed Your Europe page on the commercial guarantee of durability.

The GARAN QR code is therefore neither a serial identifier nor a digital product passport, and it does not replace the specific guarantee terms. A producer must not replace it with a proprietary dynamic QR code, a redirect service or a product-specific support URL, even if the company's page appears to provide similar information. Annex II of the Regulation explicitly lists the QR code as a non-editable element.

The commercial guarantee statement remains separate. According to the European Commission's practical guidelines, it covers the producer's name and address, the invocation procedure, the goods and the terms. A sound shop therefore keeps three destinations: the unchanged EU QR code, the guarantee statement, and the producer's service or repair path.

The general technical lesson resembles the separation required for AI labelling: a QR code supplements information visible to people; it does not replace it. For GARAN, the constraint is even more explicit because the QR destination itself is fixed.

Online display needs colour, a direct link and the complete element

For contracts concluded through an online interface, the Regulation requires the colour version. The Commission guidelines specify RGB for digital use. The complete legal-guarantee notice has to remain legible, with a clickable link to the same destination as the QR code. A QR code on a phone is not practical navigation on that same device.

The Commission gives several examples for positioning the general notice: the product catalogue, the shop header and the checkout. The guidelines also recommend including it in the confirmation email. The key requirement is not a particular component but prominent availability before the consumer is bound by the contract. Hiding it in terms and conditions, the footer or a help centre does not achieve that purpose.

The GARAN label must be associated with the specific product and visible before purchase. It can appear on the product page as a standalone image, in the gallery, in the description or through a compact nested display. It should also be shown at checkout before the order is placed, and the guidelines recommend including it again in the confirmation email.

Make the nested display work on every input method

A compact nested GARAN display is permitted online. The complete label must appear on the first mouse click, mouse roll-over or tactile screen expansion. The guidelines also require accessible text and a link or comparable interaction leading to the full label.

A hover-only pattern is unsuitable for mobile. The trigger must be keyboard-accessible, labelled for assistive technology and operable by touch. The complete label should not require multiple dialogs, a PDF or a login. If embedded in a product image, it should open in a larger, zoomable view.

The direct link beside the QR code belongs in acceptance testing as well. It must resolve to the same EU destination as the code and should not produce a different journey through analytics parameters, consent screens or redirect chains. Proprietary measurement and campaign management are not reasons to rebuild the official destination.

Only three GARAN fields can be edited

No element of the general legal-guarantee notice may be changed. On the GARAN label, only three details are editable: the guarantee duration in years, the producer or brand, and the model identifier. The title, symbols, multilingual line, typography, proportions and QR code remain fixed.

For the duration, the guidelines permit whole years and, where necessary, half years written with a decimal comma, such as 2,5 or 4,5. Other decimal values are not provided for. A controlled data field with permitted values is therefore safer than free-form marketing copy. The model identifier should come from the authoritative product master record and remain identical on the product page, in the cart, at checkout and in the email.

The Commission published its download hub for the guidelines and high-resolution assets on 19 March 2026; the practical-guidelines file is dated 1 April 2026 on that page. Official PDF, PNG, JPG and SVG files are available for colour, black-and-white and digital nested use. Teams should treat them as controlled source assets rather than recreating the label.

Test print output and scan performance separately

In physical stores, the legal-guarantee notice must be at least A4. The printed GARAN label must be at least 95 by 100 millimetres. Colour in CMYK is preferred, while black-and-white is also allowed in physical settings. The compact nested digital version must not be printed.

The guidelines give a minimum QR-code size of 2 by 2 centimetres for the GARAN label. The Regulation requires both QR codes to remain scannable under normal lighting with a standard mobile device. This is a functional requirement, not merely a file check. Every approved print size should be tested on the actual substrate, in realistic lighting and with several ordinary devices.

Moving, resizing or editing the QR code is prohibited, as are altered colours, filters, added text, removed borders, distortion and cropping. A successful scan does not make such changes acceptable. The visual integrity of the official element and its technical readability must both be preserved.

A reliable release process before September

The seller should define where the shop-wide notice appears before contract conclusion and how the correct language is selected. It then needs reliable producer information identifying eligible models, not an inference from promotional copy or a generic warranty page.

The official assets then enter a versioned media process. Only the three permitted fields are populated. Product page, gallery, cart, checkout and email must show the same model mapping and duration, while the separate guarantee statement is linked and checked.

Technical acceptance should cover desktop, touch, keyboard operation, screen magnification, the direct link and QR scanning. Physical applications add print size, substrate, contrast and lighting. Finally, changes to a guarantee period or model status need a clear publishing workflow so an expired or no longer eligible label is not left online.

The central architecture decision is straightforward: the EU GARAN label is a controlled, product-specific information object with a fixed QR destination. Treating it as a freely designed badge creates a risk of incorrect product mapping and altered EU information. Separating the shop notice, GARAN label, guarantee statement and service path makes it possible to implement the 27 September 2026 requirements consistently across sales channels.