Guide · 23 September 2026
The EmpCo product page, duty by duty
Most of what has been written about 27 September 2026 is about the guarantee notice. The notice is one line of the Directive. The same amendment adds five more things to a product page and takes a list of familiar marketing claims off it. Each duty below comes with the condition that switches it on — several will not apply to you, and knowing which is the whole job.
1. The legal guarantee reminder — always
Article 6(1)(l) of the Consumer Rights Directive now requires a reminder of the legal guarantee of conformity and its main elements, including its minimum duration of two years, in a prominent manner, using the harmonised notice. No condition, no exemption for small shops: if you sell goods to consumers in the EU, this one is yours.
The notice is official artwork in all 24 languages and may not be edited. Where it belongs, what "prominent" has meant so far, and how to show it in a theme: setting up the notice on Shopify.
2. The GARAN label — only when the producer's guarantee qualifies
Article 6(1)(la) is conditional, and every word of the condition matters: the producer offers a commercial guarantee of durability at no additional cost, covering the entire good, with a duration of more than two years, and makes that information available to the trader. Where all of that is true, the duration has to be given prominently, using the harmonised label.
One detail that is easy to miss: Article 8(2) lists point (la) among the information a shopper must be made aware of directly before placing the order. So the label belongs on the cart page as well as the product page — which is also why a "label" that is only a product-page badge is not the whole duty.
The four conditions in full, and the cases people get wrong: the GARAN label explained.
3. A reminder for digital content and digital services
Point (lb) adds a reminder of the legal guarantee of conformity for digital content and digital services. It is a separate obligation from the notice in point 1 — the harmonised notice is about goods — and it catches shops selling downloads, memberships or software alongside physical products.
4. The software-update period — if the producer told you
Point (lc): for goods with digital elements, digital content and digital services, where the producer or provider makes the information available to you, you give the minimum period during which they provide software updates — either as a length of time or as a date.
The condition is the same shape as GARAN's: this is information you were given, not information you are expected to go and find.
5. The reparability score — where one applies
Point (u): where applicable, the reparability score for the goods. "Where applicable" is doing a lot of work. A reparability score in the Directive's sense is a score based on harmonised requirements set at Union level; for most product categories no such score exists yet, and some member states have their own national index. If no score applies to your goods, this point is simply not yours — and inventing a number to fill the field would be its own problem.
6. Spare parts and repair — when point 5 does not apply
Point (v) is the fallback, and it has two conditions: it applies where point (u) is not applicable and provided that the producer makes the information available to you. Then you give what you were given — the availability, estimated cost and ordering procedure for the spare parts needed to keep the goods in conformity, whether repair and maintenance instructions exist, and any repair restrictions.
And what has to come off the page
The same Directive adds to the blacklist of commercial practices that are unfair in all circumstances — no balancing test, no "but it was true in context". The ones that live on product pages:
- Generic environmental claims without demonstrated excellent environmental performance: "eco-friendly", "green", "kind to the planet".
- A claim about the whole product when it is true only of one aspect of it.
- "Climate neutral", "carbon positive", "CO₂-reduced" where the basis is offsetting rather than the product's own lifecycle.
- Sustainability labels that are not based on a certification scheme or set by a public authority.
- Presenting a legal requirement as a distinctive feature — which is exactly what "2-year warranty included!" becomes on 27 September.
- Durability, repair and consumables claims (points 23d–23j): presenting a good as repairable when it is not, claiming a durability the product does not have under normal use, withholding that an update will degrade the product, or implying third-party consumables will break it when they will not.
The last two rows are why a store that adds the notice and stops is only part of the way there: the notice is a thing you add, and the blacklist is a thing you have to remove.
Doing it in Shopify
The mechanical part is smaller than the legal part. The notice is a theme app embed — switched on once, present on every page. The GARAN label is a block on the product template and one in the cart, reading per-product values. The update period, the reparability score and the spare-parts information are product metafields, rendered where your theme shows product details.
The part that takes real time is going through the catalogue: which products have a producer guarantee you were actually told about, which have an update period, and which descriptions carry a claim from the list above. That is the work, and it is the part no app can do for you — what an app can do is hold the answers, render them correctly, and show you the copy worth looking at.
PlainClaim does the notice and the label for free on every plan, keeps the info-duty fields alongside them, and — on the top plan — reads your product copy against the blacklist and proposes a rewrite you can apply or reject. It never decides that a product qualifies for the GARAN label: a person confirms that, on the record, and without that confirmation no label is rendered.
Sources: Directive (EU) 2024/825 (Article 4 amends Article 6(1) of Directive 2011/83/EU; the Annex amends Annex I to Directive 2005/29/EC), Regulation (EU) 2025/1960 for the notice and the label, and the European Commission's guidelines and official files.
The one-page checklist
Every duty on this page with its condition, the notice, the label and the banned claims — one page, every point sourced.
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Honest notes
This page is not legal advice. It reports what the Directive says and links it above, article by article, so you can read each claim yourself. Whether a duty applies to your particular goods is your call — and, if it is close, a lawyer's.
Several of these will not apply to you. Points 2, 4, 5 and 6 are all conditional, and the conditions are narrow on purpose. A shop that shows the notice, checks its copy against the blacklist, and honestly concludes the rest does not apply has done the work.