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:

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.

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.

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.

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.

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.

A practical roadmap to prepare before 2026

Companies can prepare in four practical phases.

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.

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.