Total:
$0.00
On 27 September 2026, two pieces of fixed EU graphic design became mandatory on product pages that sell to European consumers. That date has now passed. One of them you have to show on every store, whatever you sell. The other one you are probably not allowed to show at all — and if your frames arrive from the producer with it already printed on the box, glazing them may put a label on a good it no longer describes.
This is the same date as the green-claims ban we wrote about in “Eco-Friendly” Becomes a Banned Word in Europe, and it comes from the same directive. That is not a coincidence, and it is the reason almost nobody noticed this half. The Empowering Consumers Directive amends two different pieces of EU law. That post covered the amendments to the unfair commercial practices rules — what you must stop saying. This one covers the amendments to the Consumer Rights Directive — what you must start showing.
Two obligations, one date, and only one of them is yours to choose
Directive (EU) 2024/825 inserted a new Article 22a into the Consumer Rights Directive (2011/83/EU). Article 22a does two things. It says a harmonised notice must be used to give consumers the information about the legal guarantee of conformity already required by Articles 5(1)(e) and 6(1)(l). And it says a harmonised label must be used for the information required by the new Articles 5(1)(ea) and 6(1)(la) — a producer’s commercial guarantee of durability.
The designs themselves are set by Commission Implementing Regulation (EU) 2025/1960 of 25 September 2025, which has applied since 27 September 2026. Annex I is the notice. Annex II is the label, which the Commission calls GARAN. Member States had to have transposing measures adopted by 27 March 2026 and apply them from 27 September 2026 — which, as of that date, they now do.
The practical difference between the two is the thing to hold on to:
- The notice is not optional and not conditional. If you sell goods to consumers in the EU, it applies to you. There is no product category that escapes it and no size threshold that exempts you.
- The label is conditional, and the conditions are strict. If they are not met, you do not get to use it. It is a closed, prescribed design — not a badge you can adopt because your warranty is generous.
The notice: fixed artwork, and it has to be in colour online
The notice tells the consumer that goods sold in the EU carry a legal guarantee of at least two years. You do not write it. The text, the elements, the colours and the QR code are all prescribed by Annex I, and the Commission has published high-resolution vector files alongside practical guidelines from DG Justice and Consumers. You use the artwork as issued.
For an online shop, the Commission’s own guidance is that the notice sits as a general reminder on the seller’s website — not necessarily duplicated onto every product page. It can be reached from the product catalogue, the header or the checkout page, appearing in full on the first mouse click or roll-over. Two details matter more than they look:
- Online it must be the colour version. The black-and-white option in the Regulation is for print. A greyscale notice on a website is the wrong artwork.
- The guidelines also say it should go in the order confirmation email. That is guidance rather than the binding text of the Regulation, and it is worth keeping the distinction straight — but it is the cheapest thing on this list to do, and it is the Commission telling you where it expects to find it.
If you are wondering whether a general site-wide reminder is really enough, so is everyone else. The Regulation puts this information in the pre-contractual bucket, which argues for it being reachable before the buy button on any given product, and the guidelines describe a site-level reminder plus click-to-reveal access from catalogue and checkout pages. Those two readings are not in conflict so much as differently precise. The implementation that satisfies both is a single notice in colour, linked from the footer, reachable in one click from the product page and the checkout, and repeated in the confirmation email. Do that and you do not have to resolve the question.
The GARAN label: four conditions, and optical retail trips over one of them constantly
The label is only in play when a producer offers a commercial guarantee of durability that is:
- offered at no additional cost to the consumer,
- covering the entire good,
- of a duration of more than two years, and
- where the producer makes that information available to the trader.
All four. Miss one and the label does not apply — which in practice means you must not use it.
Run an ordinary eyewear catalogue through that list and the failures are not edge cases.
“More than two years” excludes two years. A two-year frame warranty — the single most common term in the industry — sits exactly on the threshold and does not clear it. A guarantee has to beat the legal minimum to be worth announcing, which is the entire logic of the provision.
“At no additional cost” excludes the paid extension. The scratch-protection plan or extended cover you sell as an add-on at checkout is a product, not a producer’s guarantee of durability. It never triggers the label, no matter how long it runs.
“Made available to the trader” is a condition, not a formality. The obligation to display is triggered by the producer actually telling you. If a brand’s lifetime guarantee exists on its own consumer website but has never been communicated to you as a stockist, the trigger has not been pulled.
The optical-specific problem: “the entire good” changes when you glaze
This is the part that is ours, and it has the same shape as every other line this blog has traced through European eyewear law. The decisive question is not what the warranty says. It is what the good is.
Sell a frame on its own, and the good is the frame. A producer’s free five-year or lifetime guarantee on that frame covers the entire good, and if the producer has told you about it, the label applies and you must display it.
Now glaze it. Take the same frame, fit prescription lenses, and sell a complete pair. The good you sold is the finished pair, and the producer’s guarantee covers the front half of it. The Commission’s guidance on this is about as blunt as EU consumer guidance gets: if a durability guarantee only covers part of a product, you cannot use the EU GARAN label. A frame guarantee on a glazed pair is a guarantee on part of the good.
So the same warranty, on the same frame, from the same producer, qualifies in one listing and is prohibited in the next — and the thing that moved is your lab bench, not the law. Readers of what glazing does to your regulatory position and how frames and lenses are classified in Europe will recognise the pattern. Glazing is the act that keeps redrawing the line, and it keeps redrawing it inside ordinary optical retail rather than at some boundary you can see from the shop floor.
There is a physical version of this problem too, and it is worth checking now rather than later. Producers are entitled to put the GARAN label straight onto the good or its packaging. Frames may now start arriving in boxes that already carry it. If you glaze that frame and sell the pair in the producer’s box, you are shipping a prescribed EU label describing a guarantee of the whole good, attached to a good that is only partly guaranteed. Nobody drafted that situation deliberately. It will still be sitting in your stockroom.
Is there an “old stock” grace period for a box that already carries the label?
This question got a partial answer in the summer, and the answer does not reach as far as most people shipping boxes would like.
In June 2026 the Consumer Protection Cooperation (CPC) Network published a Common Understanding on “old stock situations” under this directive — products or packaging that were manufactured, ordered, distributed or placed on retailers’ shelves before 27 September 2026. It opens by saying plainly that “Old stock situations do not exempt traders from complying with the new ECGT rules”, and then allows that authorities “may take a phased approach where old stock situations give rise to genuine and specific transitional difficulties”. It sets no end date, because “The exact duration of such transitional period cannot be determined as it may depend on specific circumstances”. And it is not law: the document says it “does not constitute a formal position of the CPC network or a legally binding interpretation”, though authorities “are expected to consider this approach when exercising their enforcement powers”.
Two limits on it matter to an online eyewear store, and both cut against you.
The first is that the Common Understanding is expressly about environmental claims and sustainability labels — the green-claims limb of the directive, covered in the other half of this pair. The Article 22a guarantee notice and the GARAN durability label are a different limb and a different kind of artwork. On our reading, that leniency does not extend to them at all, and we have found nothing that says it does. Treat the notice as due now, because it is.
The second is that even within its own subject matter, the document distinguishes online claims from offline ones on the express footing that online claims “do not face the same challenges as offline claims”. The whole rationale of an old-stock concession is that ink on a carton cannot be recalled. A line of copy on a product page can be changed this afternoon. A store whose entire selling surface is a website is the trader this concession was least written for.
Your own warranty is not a producer’s guarantee
Worth stating plainly, because it is the easiest mistake available here. Articles 5(1)(ea) and 6(1)(la) are about the producer’s guarantee. Most optical stores offer something of their own — a goodwill replacement window, a first-year breakage policy, a remake if the prescription is wrong. However good those are, they are not what the label describes, and dressing them in the GARAN artwork, or in anything designed to look like it, is a misuse of a harmonised EU mark in a context where the directive it comes from treats misleading guarantee information as an unfair commercial practice.
Keep advertising your own aftercare. Just keep it in your own words and your own design.
Contact lenses and consumables
Short section, because the answer is short. The notice applies — contact lenses are goods sold to consumers and the legal guarantee of conformity information duty is not disapplied for them. The label will effectively never apply, because a free producer guarantee of durability of more than two years covering an entire good is not a thing that exists for a consumable with an expiry date on the blister.
The honest open question: if you glaze it, who is the producer?
Here is the question we are not going to pretend to answer. If the good is the finished glazed pair, and you are the one who assembled it, then on one reading you are the producer of that good. And if you were to offer a free guarantee of more than two years covering the whole pair, the trigger in Article 5(1)(ea) would be met by your own guarantee — making you a trader displaying a label on the strength of a guarantee you gave yourself.
We have found no guidance and no decision addressing that. The Commission’s practical guidelines do not discuss customised or made-to-order goods at all, which for an industry that makes every second sale to order is a conspicuous silence. What we can say is that the argument is not fanciful: the question of whether glazing makes you the producer of the finished article is already live in a different European regime, and it has the same answer-shaped hole in it there.
Do not resolve this by guessing in the direction that lets you use the label. The conservative position — no label on glazed pairs — costs you a graphic. The other error costs you a prohibited practice.
What to do now
- Download the official artwork. Vector files and the DG JUST practical guidelines are published by the Commission. Do not recreate the notice from a screenshot in a law firm briefing.
- Put the colour notice up site-wide, reachable in one click from product pages and checkout, and add it to your order confirmation email. This was due on 27 September. If it is not up, it is the first thing to fix.
- Audit your producer guarantees against all four conditions. A spreadsheet column each for term, cost, coverage scope and whether the producer has actually told you. Most rows will fail on term or scope.
- Split your catalogue by whether you glaze. Frame-only listings and complete-pair listings are different goods for this purpose even when they share a product record. If your store sells the same frame both ways, that is a template problem, not a copy problem.
- Check incoming packaging for producer-applied GARAN labels, and decide what you do with a labelled box you are about to glaze into.
- Take the GARAN design out of any mockup where it is decorating your own aftercare policy.
Where none of this reaches
It does not touch your prescription capture. Sphere, cylinder, axis, PD, lens choice, upload-your-script — none of that is in scope here, and nothing about the notice or the label requires you to change how you collect a prescription. It does not apply to your US customers; this is EU consumer contract law. It does not create a new guarantee, extend an existing one, or change what a consumer can claim — the legal guarantee of conformity is the same two years it was last month, and this is an information duty about it. And it is not a product-safety or liability rule: for those, see the new Product Liability Directive deadline in December.
One thing it does reach that you might not expect: if your product pages are hard to operate with a screen reader, a click-to-reveal notice is exactly the kind of element that fails, and the accessibility deadline described in what happened to Carrefour already applies. A notice nobody can open is not displayed in a prominent manner.
Frequently asked questions
Do I need the notice on every product page? The Commission describes it as a general reminder on your website, reachable from the catalogue, header or checkout, with the full notice appearing on first click or roll-over. A single site-wide notice linked from the footer and reachable in one click from the product page and checkout satisfies that, and also satisfies the stricter pre-contractual reading. Build it once, that way.
Can I use a black-and-white notice online to match my theme? No. The monochrome option is for print. Online it is the colour version.
My best-selling frame has a lifetime guarantee. Can I use the label? If you sell that frame unglazed, the producer offers the guarantee free and covering the whole frame, and the producer has told you about it — yes, and you must. If you glaze it and sell a complete pair, the guarantee covers part of the good, and the Commission’s guidance says you cannot use the label.
What about a two-year producer warranty? Two years does not clear “more than two years.” No label.
The date has passed and my notice is not up. How bad is it? The duty bit on 27 September 2026. There is no grace period in the Regulation, and the CPC Network’s old-stock Common Understanding is about environmental claims and sustainability labels rather than the guarantee notice. Put it up; it is an afternoon of work and it is the single most clearly owed item on this page.
We are not established in the EU. Does this apply? These are duties attached to consumer contracts with EU consumers, and the reach of the directive over sellers outside the EU is the same question we worked through in the green-claims post. If you are actively selling into EU member states, plan on being in scope.
Is there a small-business exemption? None that we have found. The notice duty is not scaled by turnover or headcount.
What is the penalty? There is no single EU figure — enforcement runs through national consumer authorities and, in several member states, through competitor and consumer-association injunctions. The realistic near-term exposure for a small online seller is a complaint or a cease-and-desist over missing or misused guarantee information, not a headline fine.
This article is general information about EU consumer law as it stood on 27 September 2026, not legal advice, and it does not describe VisioncarePro’s own compliance status. Implementing Regulation (EU) 2025/1960 has applied since 27 September 2026 and national transposing measures differ; the treatment of made-to-order and glazed goods under Articles 5(1)(ea) and 6(1)(la) is, as set out above, not addressed by the Commission’s published guidance, and our reading that the CPC Network’s old-stock Common Understanding does not extend to the Article 22a notice and label is our reading rather than a stated position. Check the position for your own products and markets with a qualified adviser before changing what you display.
