If you sell goods to consumers online in the EU, there is a graphic you have been required to show since 27 September 2026. It is called the harmonised notice, in German „Gesetzliche Gewährleistung“.
It is a small change to a website, and it is easy to get subtly wrong. This post covers what the notice is, which rules put it on your site, who has to show it, how it differs from the GARAN label, and how to place it so it holds up. At the end there is a short example of how we built it for a client’s headless shop.
This is not legal advice. It is what we learned building the feature, with links to the primary sources. For your own shop, check with a lawyer.
What is the „Gesetzliche Gewährleistung“ notice?
The notice is an official EU graphic with a QR code and the link europa.eu/youreurope/garantien. Its job is to remind consumers that they have a statutory guarantee of conformity of two years on goods they buy.
It is not a trust badge, and it says nothing about your shop’s own warranty or any extra guarantee you offer.
You do not design it. The European Commission publishes the official files in 24 languages, as PDF, PNG and SVG, together with practical guidelines, on its page for the notice and label files.
Which rules require it?
Three layers of law stack on top of each other here.
- The EU directive. Directive (EU) 2024/825, the “Empowering Consumers for the Green Transition” directive, amends the Consumer Rights Directive 2011/83/EU. The relevant parts are Art. 5(1)(e), Art. 6(1)(l) and the new Art. 22a.
- The design. Commission Implementing Regulation (EU) 2025/1960 of 25 September 2025 fixes exactly what the notice looks like.
- Austrian law. The Verbraucherrechts-Änderungsgesetz 2026, BGBl. I Nr. 59/2026, published on 28 July 2026, puts the obligation into § 4 Abs. 1 Z 12 FAGG. The notice has to be shown „in hervorgehobener Weise“, which means prominently.
The rules apply from 27 September 2026. In Austria they apply to contracts concluded after 26 September 2026 (§ 20 Abs. 6 FAGG). So this is already in force: an order placed in your shop today falls under it.
Who has to show it?
Every trader selling goods to consumers, whether you are a retailer or the producer. The Commission’s practical guidelines from April 2026 put it plainly: “Sellers are required to display the harmonised notice in a prominent manner.”
There is no general exemption for food or drink. The Austrian Verbrauchergewährleistungsgesetz (VGG, § 1) covers all „bewegliche körperliche Sachen“, movable physical goods, and wine is one of them. If you run a wine shop, a coffee roastery’s web shop or a deli that ships orders, the notice applies to you. The one narrow carve-out in the FAGG is groceries delivered on frequent, regular rounds (§ 1 Abs. 2 Z 11 FAGG), which does not describe a normal web shop.
The notice and the GARAN label are two different things
The two are easy to confuse, because both come out of the same regulation and the files sit on the same Commission page.
| Harmonised notice („Gesetzliche Gewährleistung“) | Harmonised label (GARAN) | |
|---|---|---|
| What it tells the consumer | They have the statutory 2-year guarantee of conformity | The producer gives a free durability guarantee longer than 2 years |
| Who needs it | Every trader selling goods to consumers | Only when a producer offers that guarantee for the whole good and tells the seller |
| Austrian basis | § 4 Abs. 1 Z 12 FAGG | § 4 Abs. 1 Z 12a FAGG |
| Where it goes | As a general reminder on the website | Clearly tied to the product it applies to (e.g. next to the product image), and again at checkout |
| Do most shops need it | Yes | No |
If none of your producers give you a free durability guarantee of more than two years covering the whole product, you need the notice and you can leave the label alone. The Your Europe page for businesses covers both side by side if you want to check your case.
How the notice has to look online
The display rules come from Annex I of the regulation and § 2.3 of the Commission’s practical guidelines. For a web shop they come down to this:
- Use the official file unedited. The regulation says: “None of the elements … can be edited.” No recolouring to match your brand, no cropping, no redrawing it in your design system.
- Show it in colour. Online the notice has to be in RGB colour.
- Keep it legible at the default display size. A thumbnail you have to zoom into does not meet that.
- Add a clickable link to the page the QR code points to, every time you show the notice.
- Nested display is allowed. You can show a text link such as „Ihre gesetzlichen Gewährleistungsrechte“ in the header, on the catalogue page or at checkout, and have the full notice appear on the first click or hover.
- Put it in the order confirmation e-mail too. The Commission recommends it.
The first two come from the regulation itself; the rest are the Commission’s guidelines, which are not binding law.
The nested option keeps the design cost low: a visible text link that opens the unedited notice on the first click is one of the Commission’s own examples.
Where to place it
Recital 28 of Directive 2024/825 describes the notice as “placed as a general reminder on the website of the trader”. The Commission’s examples put it in three places: the header, the catalogue page and the checkout.
The footer is the obvious place to tuck it away. Whether a link that only sits in the footer counts as “prominent” has not been settled, and we would not rely on it. Our recommendation is two placements:
- A site-wide link that is present on every page.
- A line with the link directly before the buy button at checkout, where the purchase decision happens.
Add the order confirmation e-mail on top of that, as the Commission recommends.
Common mistakes
These are the ones we would check for first on any shop:
- The graphic has been edited. Recoloured to the brand palette, cropped to fit a slot, or rebuilt as an icon. It has to be the official file as published.
- It is shown in black and white online. Online it has to be in colour.
- It is too small to read at normal display size.
- The link to europa.eu is missing, so only the QR code carries the destination.
- It is in the footer only. That may turn out to be enough, but nobody can tell you that today.
- The GARAN label was used instead of the notice, or added to every product as a precaution. The label states that a producer gives a durability guarantee of more than two years, so it belongs only where one exists.
- It went through the image CDN. The Commission’s practical guidelines say: “No colour substitutions or format conversions should be made outside of the provided files.” Image optimisers convert PNG to WebP or AVIF by default, so serve the official file as is, not through the image CDN.
- It lives in the CMS. If the notice is a content block, a redesign or campaign edit can delete or move it without anyone noticing.
How we built it for a client’s shop
In September 2026 we added the notice to a client’s shop, a headless Next.js storefront. What we did:
- The Commission’s German colour PNG is served byte-identical. Nothing in our pipeline recolours, crops or re-encodes it.
- It opens in a dialog on the first click, with alt text and the europa.eu link inside.
- A fixed link row sits under the footer. It is rendered in code rather than coming from the CMS, so a content edit cannot remove it.
- A line with the link sits directly above the buy buttons at checkout.
- The order confirmation e-mail is sent by the shop’s ERP (Odoo, in this case), so that part of the change goes into its e-mail template rather than the storefront.
In a headless shop the storefront and the ERP each own part of the customer’s path, and this requirement touches both.
The same law also brought the „Vertrag widerrufen“ withdrawal button, which applies in Austria from 1 October 2026. We cover it in our post on the withdrawal button.
Getting it onto your shop
We build headless storefronts and connect them to the systems behind them, so the notice, the checkout line and the change to the confirmation e-mail template are handled in one piece of work. See our headless website service, or get in touch and tell us what your shop runs on.