Most DPP planning conversations end with someone saying “but that’s 2028.” Fair enough. Here is one that isn’t.
From 27 September 2026 — five and a half weeks away — every seller of consumer goods in the EU must display a harmonised legal guarantee notice, online and in store. Alongside it sits the new EU GARAN label for commercial guarantees of durability. This comes from Directive (EU) 2024/825, which inserted Article 22a into the Consumer Rights Directive, and Commission Implementing Regulation (EU) 2025/1960 of 25 September 2025, which sets the design and content. There is no transitional grace period.
What actually applies
The notice is mandatory for essentially every seller of consumer goods. Not fashion-specific, not size-gated. It explains that consumers have at least two years of legal guarantee protection, and it must be displayed prominently — a poster on the shop wall, next to the checkout, or a general reminder on your e-commerce site. There are narrow carve-outs in the underlying Consumer Rights Directive, and purely B2B sales are outside it, but nothing in there helps a clothing retailer.
The artwork itself cannot be altered at all. On top of that come the display rules: a scannable QR code, minimum A4 when printed, colour or black and white in store, and colour online — the Commission’s guidance treats the colour version as the one to use in a digital environment.
The GARAN label is voluntary to earn and mandatory to display. This is the bit that catches people, and the obligation does not sit where most people assume.
The producer chooses whether to offer a commercial guarantee of durability, and may place the label on the good or its packaging voluntarily, to get the commercial benefit. But once a producer offers one that is (a) at no additional cost, (b) covering the entire good, and (c) longer than two years, and makes that information available to the trader, the seller is required to display the GARAN label prominently, so consumers can see which goods it covers. If you sell your own product direct to consumers, you are both parties and the duty lands on you either way.
The label carries a real commitment: that the good will maintain its required functions and performance under normal use for the stated number of years, failing which the producer repairs or replaces it free.
The inverse also bites. If your durability guarantee covers only part of a product, you cannot use GARAN. You can still offer the guarantee, but the Commission’s guidance is that it must not be presented in a way that could confuse consumers with the producer durability guarantee GARAN signals — so be explicit that it covers a component only.
The label has a fixed design — the GARAN title, a tick mark, a calendar symbol, a reminder of the legal guarantee, and its own QR code. A producer edits exactly three things: the length in years, the brand or trademark, and the model identifier. Minimum 95 × 100 mm printed; colour online, where a nested format expandable on first click or roll-over is allowed. Separately, the commercial guarantee statement must reach the consumer in durable form no later than delivery.
Why a DPP brief is covering consumer law
Because look at what the GARAN label actually is: a model-level identifier, plus a QR code, plus a durability claim, resolving to EU-hosted information in the consumer’s own language, with a legal consequence if the claim is wrong.
That is the Digital Product Passport architecture in miniature, arriving two years early and through a completely different piece of legislation.
It gets more pointed. The JRC’s proposed textile information requirements put robustness at the centre — a durability signal, communicated digitally, substantiated on demand. GARAN is a durability commitment, communicated digitally, substantiated on demand. Same claim, same evidence problem, same awkward question about whether anyone in your business can prove the number.
So the practical question for the next five weeks is not only “are we compliant by 27 September.” It is: who owns this? If GARAN lands with legal or e-commerce while DPP sits with sustainability, you will build the durability evidence base twice.
Three things worth doing before the deadline
1. Audit your existing guarantee claims against the GARAN trigger. Somewhere in your marketing there is probably a “lifetime guarantee” or a “10-year promise.” Check whether it is free, whole-product and over two years. If it is, a label duty follows at the point of sale — including at every wholesale partner who stocks you. If it isn’t, check you are not implying otherwise.
2. Download the official vector files, don’t recreate the artwork. The Commission publishes practical guidelines and high-resolution editable vector files in all EU languages. The design is not modifiable and a redrawn approximation is a non-compliant label.
3. Name one owner for durability claims across both regimes. Whoever signs off the GARAN number in September should be the same person who owns robustness data when the textile delegated act lands.
Operator takeaway: this is consumer law, not ESPR, and nothing about it creates a DPP obligation. But it is the first time an EU-mandated, fixed-design data carrier will sit against your products — on the packaging, the shelf edge or the product page — pointing at a durability claim you have to stand behind. Treat the September scramble as a rehearsal, because that is what it is.