In short and in plain language
This is about new notices on product pages. They concern buyers' rights when goods have faults and how long goods last.
The article explains which notices these are and where they must appear. It also says when they apply.
The notices are fixed graphics in fixed places. An update to the shop can move or remove them. So you check them after every update.
We add this check to your maintenance contract. We report errors and where we found them.
On 27 September 2026 (Publications Office of the European Union), what a product page has to show changes. Two elements arrive: a harmonised notice on the statutory warranty rights that applies to every item, and a harmonised label for the manufacturer's commercial durability warranty that only applies under a narrow condition. Neither is a legal text in the footer. Both are graphics with a prescribed shape in a prescribed position. That moves them out of the legal department and into daily operations: they depend on the theme, on product data, on translation and on caching - and on every update that touches one of those four things.
Key takeaways
- The amended consumer rights provisions apply from 27 September 2026 (Publications Office of the European Union); national transposition measures had to be adopted and published by 27 March 2026 (Publications Office of the European Union).
- The harmonised notice states the minimum duration of two years (Publications Office of the European Union) and points out that national law may provide for longer periods.
- The label applies only where the manufacturer offers a free durability warranty of more than two years (Publications Office of the European Union) covering the whole item and passes the details to the retailer.
- Layout, colour values and typeface are prescribed: blue #003399 (Publications Office of the European Union), typeface Inter (Publications Office of the European Union), in colour rather than black and white for online sales.
- Information duties derived from Union law count as material information under German unfair competition law (German Federal Ministry of Justice) - a missing item therefore becomes a starting point for warning letters.
- Three zones carry the notice: category listing, product page and cart, each with its own checkpoint. Rolled out in four steps and taken into the maintenance cadence, the label survives a manufacturer changing its warranty.
What applies from 27 September 2026
The legal basis is Directive (EU) 2024/825, which amended both the Consumer Rights Directive and the Unfair Commercial Practices Directive. Its provisions apply from 27 September 2026 (Publications Office of the European Union). Member States had to adopt and publish their transposition measures by 27 March 2026 (Publications Office of the European Union) - six months that rarely feel like lead time, because between publication and product page sit shop system, theme and product data maintenance. A review by the Commission is only scheduled for 27 September 2031 (Publications Office of the European Union).
There are two separate elements. The first is the harmonised notice on statutory warranty rights. It carries the main elements of those rights, explicitly the minimum duration of two years (Publications Office of the European Union) and a general reference to the fact that national law may set longer periods. The second element is the label for the commercial durability warranty. It comes with a condition attached: the manufacturer has to offer such a warranty at no extra cost, covering the entire item, with a duration of more than two years (Publications Office of the European Union), and has to make the relevant details available to the retailer.
Two elements, two conditions
Three zones in the shop, three checkpoints
The first zone is the product detail page. For online sales the legislator names the position explicitly: the label should be placed directly next to the image of the goods (Publications Office of the European Union) so consumers can easily see which item the warranty covers. A graphic in the downloads tab or a reference in the footer does not serve that purpose. In practice it collides with everything themes already place there: availability, review stars, shipping note, payment methods, energy label. If nobody assigns that space deliberately, the next theme update decides it.
The second zone is the path to the order. Immediately before the consumer places the order, the shop has to draw attention, clearly and prominently, to a fixed selection of items - there are five items (Publications Office of the European Union), and since the amendment they include information on the durability warranty. That turns the order confirmation step into a surface carrying information duties rather than a pure calculation step. A deliberately shortened layout there still has to fit the items in - prominently, not as grey small print below the button.
Product detail page
Notice and, where applicable, label within the visible area next to the image. Test with one item per category, not only with the development sample.
Cart and intermediate steps
Every line item carries its own statement. Mixed carts reveal whether the output was built per line item or per page.
Checkout
A prominent repetition of the mandatory items immediately before the order is placed. This zone is the first to break when checkout extensions change.
Theme and shop updates
After each update, look at the same three zones. An overwritten block reports itself in no log file and no error report.
Product data maintenance
Manufacturer warranty, duration and conditions belong in a dedicated field. Free text in the description cannot be evaluated and cannot be checked.
Language versions
The notice exists in the official languages. A missing language version does not show up in a German test run, because the page looks correct there.
The third zone starts after the purchase. Order confirmation, customer account and help centre are where the notice turns into a case: a customer reports a defect and wants to know what they are entitled to. What the notice deliberately leaves out sits in national law - for instance the rule on the burden of proof, under which a defect appearing within one year (German Federal Ministry of Justice) of delivery is presumed to have existed from the start. Those answers in the help centre save more service time than the element costs.
What the design template prescribes
How the notice and the label look is not left to the designer. The corresponding implementing regulation of 25 September 2025 (Publications Office of the European Union) sets out content, format and design; it applies from the same day (Publications Office of the European Union) as the amended information duties. That leaves roughly a year between adoption and application - not long for a shop with several thousand items, two language versions and a custom theme.
The annexes are specific. Outside online sales the label must not fall below 95 × 100 mm (Publications Office of the European Union); for that minimum size the regulation prescribes the font sizes, among them 7 pt (Publications Office of the European Union) for the multilingual statement and 80 pt for the number of years. In print the notice has a minimum size of A4 (Publications Office of the European Union). For screens the regulation names no millimetre value, but the proportions stay fixed - an element shrunk to postage-stamp size on a phone misses the point as much as one filling half the page.
| Requirement | Value from the regulation | What works against it in the shop |
|---|---|---|
| Blue | #003399 (Publications Office of the European Union) | Theme variable recolours embedded graphics during the build |
| Yellow | Pantone Yellow C, RGB 255-237-0 | The hex value in the official journal cannot be copied |
| Typeface | Inter (Publications Office of the European Union) in three weights | Font substitution by the theme typeface during bundling |
| Version for online sales | colour rather than black and white | Print asset without colour copied into the image folder |
| Nested display | complete on first interaction | Expander with a second step or a lazy load |
| QR code target | fixed page on the Your Europe portal | Short link or redirect through an in-house counter |
Three of those rows are pure operational faults and only surface after an update. The regulation requires a nested display to show the label in full on the first mouse click (Publications Office of the European Union), the first rollover or the first touch. For online sales the notice also has to be delivered as a colour version in RGB (Publications Office of the European Union); a black and white version from the print asset is not provided for. And the QR code is not editable: it points to a fixed page on the Your Europe portal (Publications Office of the European Union), not through a short link with a counter.
The yellow value cannot be copied
Why this is a maintenance task
A legal text ages quietly; a visual element disappears visibly. That is the difference from the classic mandatory statements: a withdrawal notice reads the same after an update, whereas the label can be missing, displaced, recoloured or cut off without an error. Anyone who already keeps the legal texts in the shop up to date knows the cadence; new is that the check is a visual inspection rather than a text comparison. The withdrawal button taught the same lesson: a legal function is a flow, not a paragraph.
The scale argues for planning early. German online retail most recently turned over EUR 92.3 billion (Handelsverband Deutschland) net, accounting for 13.5 percent (Handelsverband Deutschland) of total retail sales. In the mobile dataset of the crawl behind the Web Almanac 2025, 19.2 percent (Web Almanac 2025) of the sites examined were online stores; among the ten million most visited domains it is roughly one in five (Web Almanac 2025). Commercial warranties are widespread in retail: in the mystery shopping for the directive's impact assessment, at least one commercial warranty was offered in 66 percent (European Commission 2022) of the test purchases. How many of those meet the four criteria of the labelling duty - a manufacturer's warranty, at no extra cost, covering the whole item, for more than two years - is not something the survey reports.
The difference between a paragraph and an element
In practice that means a check that runs after every update without anyone having to think about it. A short script answers whether the element is delivered at all; whether it sits in the right place at the right size stays a visual inspection. Both together take a few minutes per shop, provided the identifiers in the markup are stable.
#!/usr/bin/env bash
# Basic check of the three zones: does the shop deliver the elements at all?
# Judging position and size stays a visual inspection.
set -euo pipefail
BASE="https://shop.example.com"
ITEM="/product/test-item-with-manufacturer-warranty"
OUT="$(mktemp -d)"
curl -fsS "$BASE$ITEM" -o "$OUT/detail.html"
grep -q 'data-element="statutory-warranty-notice"' "$OUT/detail.html"
grep -q 'data-element="durability-label"' "$OUT/detail.html"
# Colour version: the hex value has to appear in the built stylesheet
grep -q '#003399' theme/dist/label.css
# Zone 3: statement immediately before the order is placed
curl -fsS -b "$OUT/session.txt" "$BASE/checkout/confirm" -o "$OUT/checkout.html"
grep -q 'data-element="statutory-warranty-hint"' "$OUT/checkout.html"
echo "ELEMENTS_OK"Checkpoints per zone
The following list is the short form of what a maintenance run actually looks at. It does not replace legal advice, but it prevents the most common silent failures - the ones where everything works and something is still missing.
- The notice appears on every product detail page, including variants, bundles and items without an image.
- The label appears only where a manufacturer warranty running beyond two years is recorded in the data - and appears there reliably.
- Both elements sit in the visible area next to the image, not under the tab holding the technical data.
- The version used in the shop is in colour; the black and white version stays in the print folder at most.
- A nested display shows the complete area on first interaction, without a lazy load and without a second step.
- The QR code still points to the prescribed target page rather than through an in-house counter.
- Every language version of the shop shows the matching language version of the notice; translation gaps hit the mandatory statements first.
- After every update to theme, shop system and checkout extension the same run is repeated and recorded with a date.
The last point is where it fails in practice. A run without a record is not a check in a dispute, it is a memory. One screenshot per zone with date and item number costs three minutes and is the only evidence worth anything later. If the order flow is walked through after every update anyway, the three screenshots attach to the same regression test after updates.
The legal consequence: material information
Germany transposed the directive with two acts. The act amending consumer contract and insurance contract law was published as BGBl. 2026 I Nr. 28 (German Federal Ministry of Justice), and the third act amending the law against unfair competition followed two weeks later as BGBl. 2026 I Nr. 43 (German Federal Ministry of Justice). The second publication is the more uncomfortable one for operations: it concerns the unfair competition flank.
By the time you reach the top 10 million, roughly one in five sites is an online store.
Under German unfair competition law, information that Union regulations or national transposition rules require to be given to consumers counts as material information (German Federal Ministry of Justice). Withholding material information can amount to an unfair commercial practice, usually pursued by competitors or associations rather than by an authority. Reliable figures for the first months do not exist yet; the warning letter practice of recent years around price indications and withdrawal rights nonetheless argues against postponing the change.
For service cases it pays to look into sales law, because the notice only shows the baseline. Claims for defects in movable goods become time-barred after two years (German Federal Ministry of Justice). If a defect appears within one year of delivery, the presumption works in the consumer's favour (German Federal Ministry of Justice). And where a repair is carried out, the original limitation period for claims based on that defect is extended once by twelve months (German Federal Ministry of Justice). Those three sentences answer most of the questions that reach the service inbox once the notice is live.
Rolled out in four steps
Take stock
Which items carry a manufacturer warranty, which field records it, and how many items does that affect? Without that number neither the effort nor the test sample can be planned.
Anchor the template
Place notice and label as separate elements with stable identifiers in the product page, cart and checkout templates - in the template, not in the description text.
Test on a copy
The first run belongs on a copy of the environment, including a mixed cart, a variant item and the second language version.
Move it into the cadence
Add the checkpoints to the post-update routine, file the evidence per zone, name an owner. From here it is operations rather than a migration.
Which items carry a manufacturer warranty, which field records it, and how many items does that affect? Without that number neither the effort nor the test sample can be planned.
Place notice and label as separate elements with stable identifiers in the product page, cart and checkout templates - in the template, not in the description text.
The first run belongs on a copy of the environment, including a mixed cart, a variant item and the second language version.
Add the checkpoints to the post-update routine, file the evidence per zone, name an owner. From here it is operations rather than a migration.
The third step is the one people skip, because the change looks small. It is small - until the cart holds two items of which only one carries a manufacturer warranty and the output was built per page instead of per line item. On a copy that costs ten minutes; in production a complaint finds it.
What belongs in the maintenance cadence
A duty that depends on template, data and cache at the same time needs a fixed place in operations. In our maintenance services the visual inspection of the three zones sits in the same list as security updates and availability checks, because it has the same trigger - an update.
After security updates
Security updates often touch templates as well. The three zones therefore belong in the follow-up to every update rather than in a separate appointment.
After extension changes
Checkout extensions overwrite the confirmation page. To know when an extension will stop moving, track the licence expiry dates of extensions.
In ongoing monitoring
Monitoring sees whether the page responds - not whether an element is missing. A content check on fixed identifiers therefore complements the availability check.
Next to the index check
As with monitoring indexability, the rule holds: a silent failure is only found if somebody looks for it deliberately.
During shop system updates
Major steps in the shop system bring new templates. Afterwards the element has either been carried over or vanished - there is nothing in between.
On content pages
Maintaining the content system matters here too, as soon as product pages or advice articles come from a second system.
If you would rather not track those points yourself, attach them to a maintenance contract with a fixed cadence. For us the migration is a bounded package: stocktaking, elements in the templates, checkpoints in the update routine, evidence per run. After that it travels along in the maintenance cadence, and whether the statements still stand after the last update has a dated answer rather than an assumption. For questions about the migration you can reach us through the contact page.
Sources and studies
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