Many companies believe that the new EU Implementing Regulation (EU) 2025/1960 only affects another label.
That is only partially true.
In practice, this means one thing above all else:
Product data is becoming a regulatory requirement.
In future, retailers and manufacturers across Europe will have to provide uniform information on warranties and durability guarantees, including standardized EU labels and QR codes.
And this is precisely where the real challenges begin.
What will change specifically:
The regulation introduces a harmonized information system for consumers.
Customers should be able to recognize immediately
• how long the statutory warranty applies
• whether there is a durability guarantee from the manufacturer
• where you can find further information
To this end, two standardized information tools will be introduced:
• a harmonized communication on statutory warranty rights (Annex I to the Regulation)
• An EU label for commercial durability guarantees
The harmonized notification (Annex I to the Regulation) shall include, in particular:
• Reference to the statutory warranty with a minimum duration of two years
• Explanations of typical consumer rights in the case of defective goods (e.g., repair or replacement)
• Indications that national warranty rights may be longer
• Practical advice on how to proceed with defective products
• a QR code linking to further EU information pages on consumer rights ()
In addition, a warranty label may be required if a manufacturer offers a warranty of more than two years. This label contains product-related information such as the warranty period, manufacturer, and model, as well as a QR code for further warranty information.
The underestimated part: product data
The real challenge lies not in the label, but in the data behind it.
In future, companies must ensure that:
• Structured warranty information for each product
• Automatic generation of EU labels
• QR codes with stable landing pages
• Linguistically consistent presentation in all EU markets
• Integration of information into online store product pages
For many organizations, this means adjustments in
• PIM systems
• Product data processes
• Content governance
• eCommerce systems
Deadline for implementation:
The most important deadline:
September 27, 2026
From this point on, retailers must comply with the new information requirements for consumers and display the harmonized notice and, where applicable, the warranty label before the contract is concluded.
That may sound like a long way off, but it isn't. Implementation often involves data models, product data quality, system integration, and content processes.
Why this is strategically important:
The new regulation is not an isolated case. It is one of a series of
• Digital Product Passport
• Right to Repair
• Ecodesign Regulation
• Increasing transparency requirements in trade
The common direction is clear:
Product information is becoming a central component of compliance.
How we support companies in this
At GoldbergUllrich Rechtsanwälte PartG mbB, we advise manufacturers, retailers, and platforms on
• correctly classify the new regulatory requirements
• Implement product data and information requirements in a legally compliant manner
• Structuring labeling and information processes (labels, QR codes, online presentation)
• Avoid legal risks in e-commerce at an early stage
Our goal is legal certainty for complex product and information requirements in digital commerce.
If you are currently working on implementing the new EU requirements, please feel free to contact us.
