The EU guarantee notice and your checkout: the rules already apply

Is the guarantee notice already Dutch law?

Yes. Since 16 July 2026, not from 27 September. That is the first correction in this article and the most important one, because it moves the conversation from "we still have time" to "we are two months behind".

The obligation sits in article 6:230m paragraph 1 item l of the Dutch Civil Code, in the version in force from 16 July 2026. It requires a reminder of the legal guarantee of conformity and its main elements, provided in a prominent manner using the harmonised notice referred to in article 22a of the directive. The same list carries item v: the GARAN label for a producer's commercial guarantee of durability.

The second correction is about placement. The guarantee notice does not belong in your checkout. The GARAN label does. That is the reverse of what most articles on this subject say, and it saves you from building the wrong thing into your templates. Article 6:230v paragraph 2 names five items that have to be repeated immediately before the order button: a, e, o, p and v. Item l is not among them.

What does start on 27 September 2026 is the design. Implementing Regulation (EU) 2025/1960 fixes the design and content of both elements, and article 3 says it applies from 27 September 2026. The duty is already here. The prescribed artwork arrives later.

One caveat belongs up front rather than in a footnote: we are a brand agency, not lawyers. What follows is what the published texts literally say, with the passages included so you can check them yourself. What it means in your situation is a question for your own legal adviser.

Why does everyone say 27 September while the Staatsblad says 16 July?

Because those are two different dates, and both are correct for different things. 27 September 2026 comes from article 4 of Directive (EU) 2024/825: member states adopt the provisions by 27 March 2026 and apply them from 27 September 2026. That is a deadline aimed at member states. It is not a ban on starting earlier, and the Netherlands started earlier.

The chain is fully public and takes about fifteen minutes to walk through. The Dutch implementing act is the act of 27 May 2026, published as Stb. 2026, 152. Its article I amends Book 6 of the Civil Code: part D extends the blacklist in article 6:193g with the sustainability claims, part G rewrites item l of article 6:230m paragraph 1 and adds item v, and part H replaces the list "a, e, o and p" in article 6:230v paragraph 2 with "a, e, o, p and v". Article III leaves entry into force to a royal decree.

That decree exists too. The decree of 9 July 2026, Stb. 2026, 204, consists of a single article stating that the act enters into force on the day after the date of publication of the Staatsblad in which the decree appears. That Staatsblad was published on 15 July 2026. The explanatory note adds that the government deliberately departed from its fixed commencement dates because binding European legislation is being implemented.

Three things you will not find in that decree, and they complete the picture. There is no differentiated commencement, even though article III expressly allowed it: the whole act came into force at once. There are no transitional provisions; besides article I the act contains only a coordination clause, a commencement clause and a citation title. And there is no provision postponing application until 27 September.

So there is daylight between the statutory text and the communication around it. The Dutch consumer authority, the ACM, writes on its own guidance page on sustainability claims that the new rules apply from 27 September 2026. As a summary of the European timeline that is defensible. It is not the date on which the Dutch provisions started to apply. The point is not that the regulator got it wrong. The point is that the gap between those two dates is not the regulator's problem but yours, because the Civil Code works without anyone enforcing it: a competitor, a consumer or a foundation can already rely on it.

The same reflex produces a second misreading in this file, and you can correct it for free. "The EU withdrew the greenwashing rules" refers to the Green Claims Directive, a different instrument: a proposal on substantiating environmental claims in advance. In the European Parliament's Legislative Observatory that proposal still sits at "Awaiting Council's 1st reading position". Announced for withdrawal, stalled in practice, formally still pending. It has no effect at all on the directive this article is about, which was adopted, transposed and brought into force.

What does article 6:230v paragraph 2 actually say?

This is the provision the whole piece turns on, so here is the substance as it has stood in the consolidated Book 6 since 16 July. Before a distance contract is concluded by electronic means and involves a payment obligation, the trader must draw the consumer's attention, in a clear and prominent manner and immediately before the consumer places the order, to the information in article 6:230m paragraph 1, items a, e, o, p and v.

Count them off in article 6:230m paragraph 1. Item a is the main characteristics of the goods or services. Item e is the total price. Item o is the duration of the contract. Item p is the minimum duration of the consumer's obligations. And item v has been added: the label. Item l, the notice, is absent. That is not an omission you may helpfully fill in. It is a list to which the legislator deliberately added one item and not the other.

Put the European text beside it and you see the same construction under different labels. That difference in numbering is why this subject gets retold so badly, so here is the key.

For a Dutch webshop the left column is the workable one. Your developer gets nothing out of "point la" when the reference has to be found in the Civil Code, and your legal adviser works with the Dutch numbering too. You need the European column only when you want the source behind the source.

Why are the notice and the GARAN label two different things?

Because they come from two different items and do two different jobs. One covers a right the buyer always had. The other covers a voluntary promise by a manufacturer that for most products does not exist at all.

Item l is about the legal guarantee of conformity: the rule that goods must conform to the contract, with the two-year minimum from Directive (EU) 2019/771. That reminder has to be given prominently using the harmonised notice. The right itself does not change. The notice makes it visible.

Item v is new and describes the case where the producer offers the consumer, at no extra cost, a commercial guarantee of durability covering the entire product for more than two years, and makes that information available to the trader. Then you state that the product is covered, how long the cover runs, plus a reminder of the legal guarantee. For that you use the harmonised label.

Does the GARAN label apply to your webshop?

Probably not, and for most readers that is the most useful sentence here. The label is conditional, and the conditions are spelled out one by one in item v. No extra cost to the consumer. The entire product. More than two years. And the producer must actually have handed you that information. All four at once.

If the guarantee covers only a component, it falls outside. The European Commission gives that example itself in its practical guidance: where a durability guarantee applies to only part of a product, you may not use the label and you must make clear to the buyer that the cover is limited to that part. If the extension costs money, it also falls outside. That is exactly the case for the overwhelming majority of extended warranties webshops sell themselves.

So walk your assortment past four questions, per producer:

1. Does the manufacturer offer a durability guarantee that costs the buyer nothing?
2. Does it cover the whole product rather than a component?
3. Does it run longer than two years?
4. Has the manufacturer actually supplied you with that information?

Four yeses means the label is mandatory, and therefore also in the checkout. Otherwise not. The notice has to be shown either way, and for most shops that is the only action left. This kind of per-producer inventory resembles what you already do for legally required product information on marketplaces, except the source here is the manufacturer rather than the channel.

Note one detail from the same amendment that nobody connects to the checkout: article 6:230m paragraph 1 also gained items x, y and z, on the minimum period for software updates, the reparability score and the availability of spare parts. Those have applied since the same 16 July and they need the same product data from the same supplier. If you are going to your manufacturers anyway, collect those fields in one pass.

What are the design rules for colour, size and typeface?

This is where it becomes a design problem, and it is stricter than most people assume. Implementing Regulation (EU) 2025/1960 of 25 September 2025 fixes form and content in two annexes, and those annexes are prescription rather than guidance. They apply from 27 September 2026; this is the part of the file where that date is the right one.

The reference colours are the same four in both annexes: Pantone Reflex Blue C at hex #003399, Pantone Yellow C with RGB values 255, 237 and 0, Pantone Black 6 C as #000000 and Pantone 000C as #FFFFFF. A detail for anyone reading the source: the Dutch language version in the Official Journal prints the yellow hex with two capital letter O characters instead of zeros. The RGB values on the same line give the intended value, so #FFED00.

The rule that will hit webshops sits in Annex I point 5: for distance contracts concluded through an online interface, the notice must be in colour (RGB). Annex II point 5 imposes the same requirement on the label, there without the RGB qualifier. Black and white is allowed only outside that online context. Anyone planning a monochrome footer icon to keep things calm is building something that is not allowed.

Look hard at those last two rows, because summaries generalise straight over them. The word "typeface" appears exactly once in the whole regulation, in Annex II point 6, and it concerns the label. Annex I prescribes no typeface for the notice. Passing "everything has to be in Inter" to a developer means passing on a requirement that is not there.

The same goes for editability. Annex I point 1 is absolute: none of the elements of the notice can be edited. The label is meant to be filled in, but in exactly three places. The letters XX are replaced by the duration in years, the words brand or trademark by the producer's name, and the word type designation by the type name. Title, tick mark, calendar symbol, QR code and translations are fixed.

For online display of the label the regulation offers one escape that matters in practice. The label may be shown nested, in which case the full label appears on the first mouse click, mouse-over or expansion of the image on a touchscreen. So you do not have to wedge a postage stamp into your order button area; a compact rendering that opens on interaction is enough.

That the design rules only apply from 27 September raises a question the texts do not answer: how do you satisfy, between 16 July and 27 September, an information duty that points at a notice whose form is not yet applicable. We solve that for clients in a practical way, by showing the substantive reminder now and preparing the official artwork. The information has then been provided, and on 27 September you wrap the prescribed element around it without changing the structure.

Where does each element land in your template?

This is the translation we make, and it is why this is a template question for us rather than a legal one. The provisions say something about the moment the consumer sees the information, and that moment turns into a concrete block in a concrete file.

The notice belongs in the pre-contractual layer: where the buyer sees information before being bound. Article 6:230m paragraph 1 literally begins with "before the consumer is bound". On a product page that is the information block near the price and the delivery time, or a guarantee block directly beneath it. For e-commerce the European Commission explicitly names a general reference on your website as a suitable form, alongside the poster on the wall and the spot next to the till for physical shops. A fixed section in your product page template, plus a permanent place on your guarantee page, covers it.

The label belongs in two places: with the product itself, because that is where product information lives, and in the checkout immediately before the order button where it applies. That second one is the addition that creates real work, because your checkout template has to know conditionally whether the product in the basket carries a qualifying guarantee.

In practice that is three pieces of work. An asset pack with both elements as vector files in the prescribed colours, for which the European Commission supplies high-resolution files in every EU language through Your Europe. A conditional block in the checkout template that shows the label when a line in the order contains a qualifying product. And a data structure that records per product whether a qualifying producer guarantee exists and how long it runs, because without that field the template cannot decide anything.

That last point gets underestimated. It is the same pattern we saw with sustainability attributes in marketplace data and with what has to appear on your packaging: the visible requirement is small, but it forces a field into your product data that does not exist yet. Filling that field for a few hundred items is the real work, not placing an image. Your existing checkout structure does not need rebuilding for it; one element joins a place where an information block already sits.

What does this mean for your brand and your design system?

A non-editable EU element in fixed blue and yellow, in the middle of a carefully built product page, is a design problem. You are allowed to say that out loud. The regulation leaves no room to alter the element itself, so all the room you have is around it.

What you may decide: where the block sits, how much white space surrounds it, what background lies underneath, and whether the label opens nested. That is enough to stop your page looking like someone pasted in a banner. Our approach is to treat the element as a certification block, the way you already handle payment logos and delivery icons: its own zone with its own rhythm, not embedded in your brand components.

What you must not do is hide it. The statutory text requires both elements to be provided in a prominent manner, and for the checkout it says in a clear and prominent manner. A collapsible that is closed on load with a button that does not say what it contains is a risk. The nested display the regulation permits is a different thing: it has to be visible and open on first interaction.

This is the same trade-off that comes up with accessibility requirements in a webshop and with substantiating sustainability claims. An external requirement does not have to break your brand, but it does ask that somebody spends design attention on it instead of adding it as a loose block at the end of the sprint.

What we got wrong twice

On 15 September our own internal note said the GARAN label belonged on the product page and in the checkout, and that the notice followed the same route. The reasoning looked sound: two mandatory elements, one date, so one place. What it missed was the list that applies immediately before the order button. Only when we put the text itself next to the summaries and counted the items did it become clear that the notice is not on it and the label is.

The second mistake was in the first version of this article, and it was the bigger one. We built the whole piece around 27 September 2026, because that is the date everywhere. A week later we opened the Staatsblad instead of the articles about it, and the Dutch act had been in force since 16 July. This article is that second correction, written out, including why it was needed.

We mention it because it says something about how subjects like this go wrong. Nobody invents these mistakes. They come from reading a summary that was itself summarising a summary. We described the same reflex when we traced brand statistics back to their source and half of them changed meaning on the way. With a requirement that has fixed artwork and a hard date, that is not an academic point: it decides whether your developer puts the right block in the right place, and when.

The lesson is simple enough to copy. When an obligation names a date, find the commencement decree. When an obligation names a place, find the provision that names that place and read the list. In both cases: the source, not somebody else's conclusion about the source.

What do you do this week?

In this order. Do not start with the artwork, because that is the smallest part.

Start with the inventory, because it sets the size of everything else. Walk your suppliers through the four questions above and record per producer whether a qualifying durability guarantee exists. Ask in the same email for the update period, the reparability score and the spare parts information. For most assortments you are done within a day and the answer is no everywhere, which keeps your checkout out of it entirely.

Then put the notice in your product page template and on your guarantee page. This is the step that touches everyone, it is the least work, and it has been due since 16 July. When testing, check that the element also renders in colour on mobile, and that it does not sit in a lazy-loaded block that only loads below the fold.

Next, fetch the official files. The European Commission supplies the vector files in all EU languages through the practical guidance on Your Europe. Use those files and do not rebuild the element, because a rebuilt version will differ somewhere it is not allowed to differ. Have the official rendering live by 27 September at the latest, because from then the form is prescribed.

If there is a qualifying guarantee in your assortment, add the conditional block in the checkout plus the product data field that feeds the condition. Do not schedule that for the week of 27 September. A checkout change is the riskiest change you can make to a webshop, and you want to be able to read the following week's conversion data without three things having moved at once.

Finish with a verification round against the source text rather than against a blog. The relevant texts are the consolidated Book 6 of the Civil Code as at 16 July 2026 for the obligation and the placement, and Implementing Regulation (EU) 2025/1960 for form, colour and dimensions. Both are online in English and in Dutch.

How we handle this for clients

We build webshops and product pages for brands that already sell, and a requirement like this reaches us as design work with a deadline attached. Not as legal advice, because it is not and we do not want it to be. It arrives as a set of questions: where does this land in the template, in which colour space, who delivers the asset, and which field in the product data feeds the condition.

The approach that has proved itself in comparable rounds, for instance with the packaging rules that took effect in August 2026, is to build it as a reusable component rather than from scratch per client. One component with the official assets, the nested variant for the label, the right QR targets per language and a clear place in the template. After that it is a matter of wiring it in per shop and filling the product data.

That saves time, but the real gain is that it prevents the two mistakes we made ourselves: putting the element in the wrong place, and planning it for the wrong date. A component built on a verified source text only has to be placed correctly once.

If you are running into this on your own webshop or a custom site, the first two questions are always the same. Is the notice already on your product page, because it should have been there in July. And do you sell products with a free producer guarantee of more than two years on the whole product, because that answer decides whether this is an afternoon of work or a sprint.

Frequently asked questions