The EU's legal guarantee notice is now mandatory. Where to put it without hurting conversion

On 27 September 2026, two pieces of EU-designed artwork became mandatory on storefronts selling goods to European consumers. You cannot redesign either of them, you cannot pick where they sit entirely freely, and the rules reach companies with no EU presence at all. The good news, which most of the compliance guidance buries, is that the heavier of the two obligations is shop-wide rather than per-product. That one detail is the difference between a small build and a redesign of every product page you own.

Who this actually applies to

Start here, because a lot of merchants assume it misses them and a lot of agencies assume it hits everyone. Work down this list and stop at your first yes.

1. Do you sell or market goods to consumers located in the EU? If yes, you are in scope, regardless of where your company is registered. The directive follows the consumer, so a US or Indian business shipping to Germany is covered in the same way a German business is.
2. Do you sell only services, with no goods? The guarantee obligations attach to the sale of goods. Pure service businesses are largely outside the guarantee elements, though the green-claims restrictions reach any trader making environmental claims to EU consumers.
3. Do you operate a marketplace rather than selling directly? Online marketplaces are explicitly within scope for making the harmonised notice clearly available.
4. Do you sell B2B only, with no consumer sales? The guarantee requirements are B2C. Check whether your checkout actually prevents consumer purchases, because a lot of nominally B2B stores do not.

The common failure mode is a brand that geo-blocks nothing, ships internationally through a 3PL, and has never considered itself an EU retailer. If European consumers can complete a purchase on your site, the directive's view is that you are marketing to them.

The three obligations, and where each one goes

This is the table worth having open while you brief a developer. The placement column is where most guidance is vague, and the vagueness is expensive, because the default safe assumption — put everything everywhere — is the one that damages conversion.

Read the second column of the first row again if you have been quoted for a per-product implementation. A fixed notice placed once, prominently, within the purchase journey and before order submission, is the design the regulation contemplates. Shops that bolt the notice onto 4,000 product pages are doing more work than required and taking a conversion hit for it.

The GARAN label eligibility test

The commercial guarantee label trips people up because it does not apply to most guarantees. Four conditions have to hold simultaneously. Miss any one and the label is not required, and using it where it does not apply is its own problem.

A useful consequence: the label is a selling point, not just an obligation. A producer-backed, free, whole-product guarantee running beyond two years is a genuine differentiator, and the EU has now given you standardised artwork that communicates it at a glance in every member state. If you sell goods that qualify and you have been describing the guarantee in body copy that nobody reads, this is an upgrade rather than a tax.

Placing the notice without hurting conversion

Here is the tension. The notice has to be prominent and easily recognisable, and it carries fixed artwork you cannot restyle to fit your design system. Prominent legal furniture inside a purchase flow is exactly the kind of thing that costs conversion if placed carelessly, which is the same problem merchants worked through with the mandatory EU withdrawal button in June.

Four principles, in descending order of how much they matter:

1. Put it where it reassures rather than where it interrupts. A two-year guarantee is a trust signal. Shown beside delivery and returns information, it supports the purchase. Shown as a modal over the payment step, it is an obstacle. Same obligation, opposite effect.
2. Do not duplicate it. If it appears once, prominently, before order submission, adding it again on the PDP, in the cart and in the footer does not increase compliance and does measurably increase the chance someone reads three pieces of legal copy and leaves.
3. Never put it between the buyer and the pay button. The requirement is that it is available and shown before the consumer submits the order, not that it blocks submission. Those are different designs and only one of them converts.
4. Attach it to the order confirmation as well. Including it with the confirmation email is part of the expected implementation and costs you nothing in conversion terms, because the sale has already happened.

If you have the traffic to test, this is a reasonable candidate for a placement test rather than a guess, on the pattern we set out in why most A/B tests fail. What you are testing is placement, never presence: the notice is mandatory and there is no variant where it is absent.

Green claims: a substitution table

The green-claims piece generates the most work and the least discussion, because it is not a build task. It is an audit of every claim you have ever written, and the prohibition targets exactly the vocabulary that marketing teams reach for by default. Generic claims are out unless you can evidence recognised excellent environmental performance.

The instinct is to delete the claims and lose the persuasion. That is not necessary. A specific, substantiated claim is both compliant and more convincing than the vague one it replaces, which is the rare case where the regulation and the conversion objective point the same way.

Note what the right-hand column does. It replaces an adjective with a number and a source, which is the same move that makes a claim credible to a sceptical shopper and, increasingly, quotable by an AI assistant summarising your product. Specific claims survive both audiences; adjectives survive neither.

A four-week implementation sequence

The date has passed, so the useful question is what order to fix things in. Sequence by exposure, not by ease.

1. Week one: scope and the notice. Confirm whether EU consumers can complete a purchase on your site. If yes, implement the harmonised notice once, prominently, in the purchase journey before order submission, using the official artwork unmodified, and add it to order confirmation emails.
2. Week two: the green-claims sweep. Export every piece of customer-facing copy you can: PDP descriptions, collection pages, homepage, templates, automated emails, ad copy. Search for the generic terms. For each hit, either substitute a specific evidenced claim or delete it. This takes longer than you expect on a large catalogue, which is why it is week two and not week four.
3. Week three: GARAN data. Chase the supplier answers on producer guarantees, add the attribute to your product data, and apply the label conditionally only to qualifying products.
4. Week four: evidence and governance. File the substantiation behind every environmental claim you kept, somewhere a regulator or a journalist could be shown it. Then put a check into your product-launch process so the next 200 SKUs do not reintroduce the problem.

Week four is the one teams skip and the one that determines whether this stays fixed. A green-claims audit without a gate in the content workflow decays within two quarters, because the next product launch will reach for “eco-friendly” exactly as the last one did.

One honest caveat

The directive sets the obligation and Implementing Regulation (EU) 2025/1960 fixes the design and content of both artifacts, but member states implement through national law and enforcement practice will vary across the 27. Specific details that circulate in vendor guidance — including the use of a QR code pointing consumers to information in their own language — should be checked against the implementing regulation's own artwork and against your largest markets' national guidance before you ship. Use the official assets, not a recreation, and if you sell at meaningful volume into the EU, have the placement reviewed by someone who can read the national transposition rather than relying on a blog, this one included.

Frequently asked questions

What is the EmpCo directive and when does it apply?

EmpCo is Directive (EU) 2024/825, the Empowering Consumers for the Green Transition directive, which amends the Consumer Rights Directive 2011/83/EU. It applies from 27 September 2026 across the 27 EU member states. It introduces two mandatory EU-standardised information artifacts for business-to-consumer sales of goods, a harmonised notice about the statutory legal guarantee and a harmonised label for longer producer guarantees, and it prohibits generic environmental claims that a trader cannot evidence.

Does the EU legal guarantee notice have to appear on every product page?

No. The harmonised notice is shop-global rather than product-specific. Displaying it once per sales presence is treated as sufficient, provided it is prominent, easily recognisable and shown before the consumer submits the order, and that it is clearly available at the point of sale and in the online checkout. Adding it to every product page is more work than the rule requires and introduces an unnecessary conversion cost, which is why merchants quoted for a per-product implementation should question the scope.

Does EmpCo apply to businesses outside the EU?

Yes. The obligations attach to any trader selling or marketing goods to consumers located in the EU, including companies based outside the EU. A US, UK or Indian retailer that ships to EU consumers and does not prevent them from completing a purchase is in scope. Online marketplaces are explicitly covered as well. The practical test is whether a European consumer can complete a purchase on your site.

What is the GARAN label and when do I need it?

GARAN is the EU harmonised label for commercial guarantees of durability, and it is required when four conditions hold at once: the guarantee is offered by the producer of the goods, it is provided free of charge to the consumer, it covers the entire product rather than a single component, and it lasts more than two years. If any one of those is missing, the label is not required. Paid extended warranties, retailer-offered guarantees, component-only cover and guarantees of two years or less all fall outside it.

Can I redesign the EU guarantee notice to match my brand?

No. The design and content of both the harmonised legal guarantee notice and the GARAN commercial guarantee label are fixed by Implementing Regulation (EU) 2025/1960. They use official European Commission artwork that cannot be redesigned, recoloured or recreated to fit a design system. The only decisions left to the merchant are placement and surrounding context, which is where the conversion work sits.

Which environmental claims are banned under EmpCo?

Generic environmental claims are prohibited unless the trader can demonstrate recognised excellent environmental performance relevant to the claim. In practice that rules out unqualified use of terms such as eco-friendly, green, sustainable, carbon neutral, environmentally friendly and natural where they stand alone as a claim. The compliant and usually more persuasive alternative is a specific, evidenced statement naming the attribute, the figure and the standard, such as a certified recycled-content percentage rather than the word eco-friendly.

What should I fix first if I missed the 27 September 2026 deadline?

Sequence by exposure. First, implement the harmonised legal guarantee notice once in the purchase journey before order submission, using the official artwork, and add it to order confirmation emails. Second, run a green-claims sweep across all customer-facing copy including product descriptions, templates and automated emails, substituting specific evidenced claims or deleting the generic ones. Third, gather supplier data on qualifying producer guarantees and apply the GARAN label conditionally. Fourth, file the substantiation for the claims you kept and add a check to your product-launch process so new products do not reintroduce the problem.

The takeaway

Most of the panic around this directive comes from assuming it is a per-product build. It is not. One prominent notice inside the purchase journey, applied once and attached to your order confirmation, discharges the heaviest obligation, and the GARAN label touches only products with a free producer guarantee over two years covering the whole item. The real work is the green-claims audit, because it reaches every description, template and automated email you own, and because fixing it properly means replacing adjectives with evidence. That is the part worth doing well rather than quickly: a claim with a number and a source behind it outperforms the vague version it replaces with shoppers and with the AI assistants now summarising your products, which makes this the rare compliance deadline that leaves your storefront better than it found it.