ECGT 2024/825 Guarantee Label: A Practical EU Guide

24-06-2026

Why the ECGT 2024/825 guarantee label matters

The ECGT 2024/825 guarantee label refers to the new EU consumer-information label introduced under the Empowering Consumers for the Green Transition Directive, formally Directive (EU) 2024/825.

It is important to clarify one point from the start: this is not a packaging sorting label, recycling label, or waste-disposal marking. It is a consumer guarantee and durability information label for goods sold to EU consumers.

The label is part of a wider EU shift toward clearer consumer information, stronger protection against greenwashing, and more transparent product durability claims. For businesses, this means product claims, guarantee statements, marketing messages, online product pages, and in-store consumer information will need to be reviewed with much more care.

The new framework is especially relevant for companies selling consumer goods in the EU, including electrical and electronic products, household appliances, furniture, tools, textiles, toys, digital goods with software updates, and other product categories where durability, repairability, spare parts, and sustainability claims influence consumer choice.

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What is the ECGT 2024/825 guarantee label?

The ECGT 2024/825 guarantee label is best understood as the EU’s harmonised label for a commercial guarantee of durability.

In practical terms, the label tells consumers that a specific product benefits from a producer’s commercial guarantee of durability. This guarantee must be linked to the durability of the good and must meet specific conditions.

The label is connected to goods where the producer offers a commercial guarantee of durability that is:

Requirement	Practical meaning
Offered by the producer	The guarantee comes from the producer, not merely from a retailer’s optional service plan
Free of additional cost	The consumer does not pay extra for the durability guarantee
Covers the entire good	The guarantee must apply to the whole product, not only one component
Lasts more than two years	The guarantee must go beyond the minimum two-year legal guarantee framework
Made available to the trader	The seller must have the relevant guarantee information from the producer

The European Commission’s practical materials also refer to this label as the EU GARAN label. Businesses may see both terms used in practice: “harmonised label for the commercial guarantee of durability” in legal language, and “EU GARAN label” in practical implementation materials.

ECGT guarantee label vs packaging sorting label

One of the most common misunderstandings is to treat the ECGT 2024/825 guarantee label as another packaging label. That is not correct.

The ECGT guarantee label is about consumer rights and product durability, not waste sorting.

Label type	Main purpose	Example use
ECGT 2024/825 guarantee label / EU GARAN label	Shows that a product has a qualifying producer commercial guarantee of durability	Displayed on product packaging, product pages, shelves, checkout pages, or digital product information
Legal guarantee notice	Reminds consumers of their legal guarantee of conformity rights	Displayed at shop level, online or offline
Packaging sorting label	Tells consumers how to sort or dispose of packaging	Recycling, waste sorting, or national packaging instructions
Sustainability label	Promotes environmental or social characteristics of a product, process, or business	Ecolabels, sustainability marks, certification-based labels

This distinction matters because compliance responsibility sits with different business functions. Packaging sorting labels are often managed by packaging, EPR, or environmental compliance teams. The ECGT guarantee label requires coordination between legal, product compliance, sustainability, e-commerce, marketing, customer service, and supplier management teams.

What Directive (EU) 2024/825 changes

Directive (EU) 2024/825 amends two major EU consumer protection laws:

The Unfair Commercial Practices Directive 2005/29/EC
The Consumer Rights Directive 2011/83/EU

Its objective is to empower consumers to make better-informed purchasing decisions during the green transition. The Directive focuses on two main areas:

1- Better protection against unfair practices, especially misleading environmental claims, unreliable sustainability labels, and practices linked to early obsolescence.

2- Better consumer information, especially on durability, repairability, legal guarantees, commercial durability guarantees, software updates, spare parts, and repair restrictions.

For businesses, this is not only a legal update. It is also a product governance and communication challenge. Claims that were once treated as marketing language may now require structured evidence, internal review, and ongoing monitoring.

When will the rules apply?

The Directive requires EU Member States to adopt and publish national implementing measures by 27 March 2026. The measures are expected to apply from 27 September 2026.

For companies, this timeline should not be treated as distant. Product data, guarantee terms, e-commerce templates, packaging artwork, supplier declarations, marketing claims, and retail display materials often require long preparation cycles.

A practical preparation plan should begin well before the application date, especially for businesses with large product portfolios or multiple sales channels.

Who needs to pay attention?

The ECGT 2024/825 guarantee label and related consumer information rules are relevant to several business roles.

Business role	Why it matters
Producers	They decide whether to offer a commercial guarantee of durability and must define the exact guarantee terms
Sellers and retailers	They must display required consumer information clearly when relevant information is available
Importers and distributors	They may need to collect producer information and pass it through the supply chain
E-commerce teams	Product pages, checkout pages, confirmation emails, and digital label placement may need updates
Marketing teams	Environmental and durability claims must be accurate, specific, and supported
Compliance teams	Evidence, documentation, supplier data, and claim approvals must be managed consistently
Customer service teams	Consumer-facing guarantee explanations must match the official guarantee terms

The key risk is inconsistency. A product page may say one thing, a guarantee statement another, and a marketing banner something broader. Under the new consumer protection framework, that kind of inconsistency can create compliance exposure.

What businesses must show consumers

Directive (EU) 2024/825 expands the type of information consumers should receive before they buy. Depending on the product and the information made available by the producer or provider, businesses may need to communicate:

The existence of the legal guarantee of conformity for goods
The existence and duration of a qualifying commercial guarantee of durability
The minimum period for software updates for goods with digital elements, digital content, or digital services
The reparability score where established at EU level
Information on spare parts, estimated costs, ordering procedures, repair instructions, maintenance instructions, and repair restrictions where applicable
Environmentally friendly delivery options where available

This means that businesses should start treating consumer-facing product information as controlled compliance data, not only as marketing content.

Practical display guidance for the ECGT guarantee label

The harmonised durability guarantee label must be presented in a way that allows consumers to identify clearly which specific product benefits from the qualifying commercial guarantee of durability.

In a physical retail environment, this may include placing the label:

On the product packaging
Directly on the product
On a shelf next to the specific product
As a tag or adhesive label
Inside the package as a leaflet or in the user manual, where appropriate

In an online environment, businesses should consider displaying the label:

On the product page
In the product image gallery
Near the product description
Through an approved nested digital label where space is limited
Directly before the consumer places the order
In the order confirmation email, where relevant

The core principle is simple: the label must stay clearly connected to the product it refers to. It should not create the impression that a whole range, category, bundle, or brand is covered unless that is truly the case.

What the label should not be used for

The ECGT 2024/825 guarantee label should not be used as a general marketing badge.

Businesses should avoid using the label for:

Paid warranty extensions
Retailer-only service packages that do not qualify as a producer commercial guarantee of durability
Guarantees covering only a single part or component
Products with guarantees of two years or less
General quality claims
Sustainability claims unrelated to the commercial guarantee of durability
Packaging recyclability or waste sorting instructions
Product categories where the producer has not made the qualifying guarantee information available

Using the label too broadly may mislead consumers and undermine the purpose of the EU harmonised format.

How Directive (EU) 2024/825 affects green claims

Although this article focuses on the guarantee label, Directive (EU) 2024/825 is also a major anti-greenwashing update.

The Directive introduces stronger rules around environmental and sustainability claims. Businesses should review claims such as:

“Eco-friendly”
“Green”
“Climate neutral”
“Carbon neutral”
“Sustainable”
“Biodegradable”
“Environmentally friendly”
“Reduced climate impact”
“Made with recycled material”
“Repairable”
“Long-lasting”
“Built to last”

The Directive restricts generic environmental claims where the trader cannot demonstrate recognised excellent environmental performance relevant to the claim. It also addresses claims based on greenhouse gas offsetting, future environmental performance claims, sustainability labels, and claims that exaggerate an environmental benefit.

For example, if only the packaging contains recycled material, a company should avoid wording that gives the impression that the whole product is made from recycled material. Similarly, climate-related claims based only on offsetting require careful review.

Sustainability labels must be credible

Under the new rules, displaying sustainability labels that are not based on a certification scheme or not established by public authorities is treated as a prohibited unfair commercial practice.

This does not mean that sustainability labels disappear. It means businesses must verify that labels are credible, transparent, and properly supported.

A compliant sustainability label should be linked to a valid basis, such as:

A public authority label
A certification scheme with transparent requirements
Independent third-party monitoring
Publicly available terms
Procedures for non-compliance, suspension, or withdrawal

This is particularly important for companies using private sustainability marks, in-house eco badges, supplier-provided green labels, or marketplace icons.

Early obsolescence and durability claims

Directive (EU) 2024/825 also targets practices associated with early obsolescence.

Businesses should review whether they make claims or use product features that could mislead consumers about:

Product durability
Repairability
Software updates
Spare parts
Consumables
Accessories
Compatibility with non-original parts

The Directive prohibits practices such as:

Withholding information that a software update will negatively affect product functionality
Presenting a software update as necessary when it only enhances functionality
Communicating about goods with features introduced to limit durability when relevant information is available
Falsely claiming a product has a certain durability under normal use
Presenting a product as repairable when it is not
Encouraging replacement of consumables earlier than technically necessary
Hiding functionality limitations when non-original consumables, spare parts, or accessories are used

For product manufacturers and retailers, this means durability and repair-related claims must be aligned with technical evidence.

Practical compliance checklist for businesses

Use this checklist to prepare for the ECGT 2024/825 guarantee label and related consumer information duties.

Action	Practical question to ask
Map affected products	Which goods are sold to EU consumers?
Identify durability guarantees	Does the producer offer a commercial guarantee of durability for more than two years?
Check guarantee scope	Does the guarantee cover the entire good, or only specific components?
Verify cost	Is the guarantee offered at no additional cost to the consumer?
Collect guarantee statements	Are the guarantee terms documented clearly and consistently?
Review product pages	Is the label shown clearly next to the relevant product where required?
Review checkout flow	Is the consumer informed directly before placing the order where required?
Review confirmation emails	Does the post-purchase communication reflect the guarantee information accurately?
Audit sustainability claims	Are environmental claims specific, evidence-based, and not exaggerated?
Validate sustainability labels	Are labels based on an accepted certification scheme or public authority?
Review software update information	Are update periods and impacts communicated clearly where relevant?
Review repair information	Are repair scores, spare parts, instructions, and restrictions managed where applicable?
Train teams	Do sales, customer support, marketing, and compliance teams use consistent language?
Maintain evidence	Can the company prove the basis for claims, guarantees, and product information?

Common mistakes to avoid

Businesses should avoid these common errors when preparing for the new EU consumer information rules.

Mistake 1: Treating the ECGT label as a recycling label

The ECGT 2024/825 guarantee label is not a waste-sorting or packaging disposal label. It relates to a commercial guarantee of durability for goods.

A practical roadmap to prepare before 2026

Companies can prepare in four practical phases.

Mistake 2: Using the label as a general quality badge

The label should only be used when the product meets the specific conditions for a producer commercial guarantee of durability.

Mistake 3: Applying the label to an entire product family

If only some models are covered, the label must be linked only to those products. A general banner may mislead consumers if it implies broader coverage.

Mistake 4: Confusing legal guarantee and commercial guarantee

The legal guarantee of conformity and commercial guarantee of durability are different. The legal guarantee is a consumer right. The commercial guarantee of durability is an additional producer commitment that may qualify for the harmonised label when the conditions are met.

Mistake 5: Making vague sustainability claims

Generic claims such as “green” or “eco-friendly” should not be used unless the company can demonstrate recognised excellent environmental performance relevant to the claim.

Mistake 6: Forgetting e-commerce touchpoints

Compliance is not limited to packaging. Product pages, checkout pages, product galleries, confirmation emails, digital carousels, and promotional banners may all need review.

How ComplyMarket can support your ECGT 2024/825 readiness

ComplyMarket helps businesses manage complex product compliance, sustainability, ESG, and product information requirements in one structured workflow.

For Directive (EU) 2024/825 and the ECGT guarantee label, ComplyMarket can support companies by helping teams:

Map affected products and product families
Organise producer guarantee information
Manage supplier and producer documentation
Track evidence for product durability, repairability, and sustainability claims
Review product data needed for consumer-facing disclosures
Support internal compliance workflows across legal, product, marketing, and e-commerce teams
Maintain a centralised record of claim substantiation and regulatory evidence
Connect product compliance data with broader sustainability and Digital Product Passport readiness

This is especially valuable for companies managing large product portfolios, multiple suppliers, and several EU sales channels. Instead of handling guarantee information, sustainability claims, repair data, and product evidence in separate spreadsheets or disconnected systems, ComplyMarket helps teams build a more transparent, auditable, and scalable compliance process.

As the EU continues to strengthen consumer information, sustainability, and product transparency requirements, companies need more than a one-time label update. They need a reliable compliance management approach that keeps product data, regulatory requirements, supplier evidence, and market-facing claims aligned.

Phase 1: Product and claim mapping

Create a central list of products sold to EU consumers. Identify which products have durability guarantees, sustainability claims, repairability claims, software update commitments, or environmental labels.

Phase 2: Evidence and documentation review

Collect producer guarantee statements, technical files, supplier declarations, test evidence, repair information, spare part information, and claim substantiation. Make sure all evidence is current, product-specific, and traceable.

Phase 3: Consumer-facing content update

Update product pages, packaging, retail displays, guarantee wording, product descriptions, checkout content, confirmation emails, customer service scripts, and marketing templates.

Phase 4: Governance and monitoring

Create an internal approval process for sustainability claims, durability claims, label use, and guarantee information. Assign clear ownership across compliance, product, legal, marketing, and e-commerce teams.

Why this matters for market access and consumer trust

The ECGT 2024/825 guarantee label is more than a visual label. It reflects a broader compliance trend: EU product information is becoming more evidence-based, more standardised, and more visible to consumers.

Companies that prepare early can benefit from:

Stronger consumer trust
Lower greenwashing risk
Better product data governance
More consistent sustainability communication
Clearer guarantee information
Improved coordination between compliance and commercial teams
Stronger readiness for future EU product transparency requirements

Companies that delay may face last-minute packaging changes, inconsistent e-commerce updates, weak evidence for marketing claims, and higher regulatory risk.