Directive (EU) 2024/825 and Commission Implementing Regulation 2025/1960 harmonize guarantee information across the European Union
Don’t miss our content
SubscribeBeginning September 27, 2026, businesses selling goods to consumers in the European Union (“EU”) must display a harmonized notice on the legal guarantee of conformity at every physical and online point of sale.
This requirement was introduced by new Article 22a of Directive 2011/83/EU, as inserted by Directive (EU) 2024/825. Commission Implementing Regulation (EU) 2025/1960 further specifies the notice’s design and technical requirements.
What is the harmonized notice?
The harmonized notice is a mandatory information tool established under Article 22a of Directive 2011/83/EU. Businesses must display it wherever they sell goods to consumers, including in physical stores and through online sales interfaces.
The notice reminds consumers of the existence and main elements of the legal guarantee of conformity. These include the minimum two-year guarantee period established by Directive (EU) 2019/771. The notice also explains that the applicable guarantee period may be longer under the national law of each individual Member State.
Commission Implementing Regulation (EU) 2025/1960 prescribes the notice’s format, dimensions and typography, while Annex I sets out the required design. Key requirements include the following:
- Traders may not edit or alter any element of the notice.
- For contracts concluded on business premises, the notice must appear in color or black and white. It must be at least A4, although businesses may use the larger A3, A2 or A1 formats.
- For distance contracts concluded through an online interface, the notice must appear in color and use the RGB color model.
What is the harmonized label?
The harmonized label for a commercial durability guarantee is a voluntary information tool. It is intended for producers that offer a commercial durability guarantee covering the entire good for more than two years at no additional cost to the consumer.
The label uses a language-neutral design intended to be understood throughout the EU without requiring a full translation.
Annex II to Commission Implementing Regulation (EU) 2025/1960 prescribes the label’s design and content.
Transposition and application in Portugal
The Portuguese Circular Economy Action Plan 2030 (PAEC 2030) provides the framework for Portugal’s transition to a circular economy.
The plan was approved by Council of Ministers Resolution 58/2026 of March 24. It expressly mentions Directive (EU) 2024/825 and includes measures to combat premature obsolescence and strengthen product durability.
Transposing the new rules will require amendments to Decree-Law 84/2021, which governs consumer guarantees, and Decree-Law 24/2014, which governs distance contracts. It may also require amendments to the unfair commercial practices regime established by Decree-Law 57/2008.
To date, Portugal has not approved any proposal to transpose Directive (EU) 2024/825.
Key dates
| Date or deadline | Significance |
| February 28, 2024 | Adoption of Directive (EU) 2024/825 |
| September 25, 2025 | Adoption of Commission Implementing Regulation (EU) 2025/1960 |
| March 27, 2026 | Deadline for Member States to transpose the directive |
| September 27, 2026 | Date the national implementing provisions and the implementing regulation become applicable |
What should businesses do?
In light of the new obligations, businesses should take the following proactive steps:
- Display the harmonized notice on the legal guarantee of conformity at every physical point of sale and through every online sales interface. The notice must comply with the format, color and size requirements established by Commission Implementing Regulation (EU) 2025/1960.
- Identify any commercial durability guarantees offered by the producers of the goods they sell. Where applicable, businesses should display the harmonized GARAN label.
- Update the precontractual information provided to consumers. This information should cover both the legal guarantee of conformity and any commercial durability guarantees.
- Ensure that all notices and labels comply with the applicable technical specifications established by Commission Implementing Regulation (EU) 2025/1960. This includes providing functional QR codes that direct consumers to the Your Europe portal.
Don’t miss our content
Subscribe