Informative Notes
Following the European Green Deal and the EU’s broader push towards a circular and resource-efficient economy, the European Commission has adopted a new Directive on Empowering Consumers for the Green Transition.
Its goal is to ensure that consumers are better informed and protected when making sustainable choices - and as a result, it introduces several new information and labelling obligations for businesses across both physical retail and online sales channels.
Below we send a brief overview of the measures most likely to affect commercial, marketing and after-sales practices.
🟠 WHAT WILL CHANGE FOR BUSINESSES
- Mandatory transparency on product durability and reparability – At the point of sale (both online and in-store), businesses will be required to provide clear and verifiable information on product lifespan and repair options.
- Obligatory display of the EU harmonised legal guarantee notice – From September 27th, 2026, all traders must display a standardised EU notice informing consumers of their minimum 2-year legal guarantee rights (to be adjusted where national law provides a longer period, as in Portugal – where the minimum legal guarantee period is 3 years)
- New voluntary EU label for extended commercial guarantees – If a manufacturer offers a guarantee longer than the mandatory 2 years (e.g. 3 years in Portugal), it must be communicated using a new standard EU label, covering the entire product and at no extra cost to the consumer.
- Restrictions on vague environmental claims (greenwashing) – Terms such as “eco-friendly”, “climate neutral” or “sustainable” will only be allowed if backed by certified evidence.
🟠 IMPLEMENTATION TIMELINE
- Transposition into national legislation by March 2026;
- Full application of all new rules (including the legal guarantee notice and extended guarantee label) from September 27th, 2026.
Additionally, the Commission Implementing Regulation (EU) 2025/1960, adopted on 25 September 2025, sets out the design and content rules for the harmonised legal guarantee notice and the harmonised durability guarantee label. The regulation enters into force 20 days after its publication in the Official Journal, but only becomes applicable from 27 September 2026, in line with the broader Directive. It establishes a standardised layout with non-editable core elements, requires the inclusion of a QR code giving access to country-specific information, and ensures that any additional commercial guarantee clearly references the consumer’s legal guarantee rights.
We will continue to monitor the national implementation process and are available to assist in assessing potential impacts on product labelling, and any other obligations imposed.