Legal Guarantee, GARAN and green claims: the EU consumer rules now in force
Since 27 September 2026, every business that sells goods to consumers in the EU must tell them about their legal guarantee in the same way, using the same EU notice. From the same date, many of the environmental claims businesses have used for years are no longer allowed.
Both changes come from Directive (EU) 2024/825 on empowering consumers for the green transition. It amends two pillars of EU consumer law: the Unfair Commercial Practices Directive and the Consumer Rights Directive. The design of the new notice and label is set by Commission Implementing Regulation (EU) 2025/1960, which applies directly in every Member State.
In Cyprus, the Directive has been transposed by the Consumer Protection (Amendment) (No. 3) Law of 2026 (Law 122(I)/2026), which amends the Consumer Protection Law of 2021 (Law 112(I)/2021) and also took effect on 27 September 2026.
This article explains what the new notice and label are, which green claims are now off limits, how the rules apply in Cyprus, what is easy to overlook, and where to focus first.
New Consumer Rules
The Legal Guarantee notice: mandatory for every trader selling goods
Traders must now remind consumers, before the contract is concluded, that the legal guarantee of conformity exists. That reminder must be given prominently, through a single EU-wide notice headed "Legal Guarantee". The obligation applies to sales in shops as well as to online and other distance sales.
The notice tells consumers, in plain terms, that:
goods sold in the EU carry a legal guarantee of at least two years, and some countries provide longer;
for second-hand goods, a shorter period may apply, but not less than one year;
they can rely on the guarantee if, for example, goods do not match their description or do not work as intended;
the seller is liable and must offer free repair or replacement, and in some cases a price reduction or a full refund;
they should contact the seller and keep proof of purchase.
A QR code takes consumers to the EU's Your Europe portal, where they can find the rules that apply in their own country.
The format is fixed. None of the notice's content can be edited. In a shop, it can be in colour or black and white, at a minimum size of A4. Online, it must be shown in colour. Because the Implementing Regulation applies directly, the design is the same in every Member State.
The notice does not create new rights. Consumers already had the legal guarantee. What has changed is that every trader must now tell them about it, in the same way.
The GARAN label: voluntary for producers, mandatory for sellers to show
The second element is a label titled "GARAN", a word chosen because it echoes "guarantee" in several EU languages. It signals a commercial guarantee of durability: a producer's promise that a good will keep working as required through normal use for a set period.
No producer has to offer such a guarantee. But where a producer does so at no extra cost, covering the entire good and for more than two years, and the producer makes that information available to the seller, the seller must tell consumers about it, prominently and using the GARAN label. A producer offering such a guarantee is directly liable to the consumer for repair or replacement during the guarantee period.
The label shows the producer's name, the model and the number of years covered, with a QR code linking to further information. The rest is fixed. In a shop, the label must be at least 95 × 100 mm. Online, it must be in colour, and it may appear in a compact version that opens in full on click, hover or tap.
The notice and the label are designed to work together, and each refers to the other. This matters because consumers often confuse the two. The legal guarantee is a right under law against the seller. The durability guarantee is a voluntary promise from the producer, which applies on top of it. Commercial guarantees that do not meet the GARAN conditions can still be offered, but they should not be presented in a way that suggests they qualify for the label.
Green claims: what is now off limits
The same Directive adds new practices to the EU's list of commercial practices that are unfair in all circumstances. These are banned outright, with no case-by-case assessment of whether consumers were misled. Unlike the guarantee notice, which concerns goods, these rules apply to any product marketed to consumers, services included. They include:
Generic environmental claims, such as "eco-friendly", "green" or "climate-friendly", unless the trader can show recognised excellent environmental performance relevant to the claim;
Sustainability labels that are not based on a certification scheme with independent third-party monitoring, or set up by public authorities. Self-made "eco" badges are caught;
Claims that a product is climate-neutral, reduced or positive because of carbon offsetting, rather than its own life-cycle impact;
Claims about a whole product or business when they are true only of one part or activity.
Future-looking claims, such as "net zero by 2030", are not banned. But they may be misleading unless backed by a detailed, realistic implementation plan with measurable, time-bound targets, verified regularly by an independent expert.
The Directive also tackles durability and repair, for example false claims about how long a product will last, or presenting goods as repairable when they are not.
The European Commission's proposed Green Claims Directive, which would have set detailed rules for substantiating claims, was put on hold in June 2025. In practice, these rules are now the main EU framework for green claims made to consumers.
The Cyprus position
The Directive has been transposed by the Consumer Protection (Amendment) (No. 3) Law of 2026, which amends the Consumer Protection Law of 2021. It was published on 17 July 2026 and took effect on 27 September 2026.
The amending law adds the new definitions (environmental claim, generic environmental claim, sustainability label and certification scheme), the new rules on misleading claims, and the new practices banned in all circumstances.
Enforcement lies with the Consumer Protection Service of the Ministry of Energy, Commerce and Industry, which can impose administrative fines under the Consumer Protection Law. These fines are linked to the business's turnover.
The Implementing Regulation on the notice and label needed no transposition. It has applied directly in Cyprus since 27 September 2026.
In practice
The answers often depend on how a business is set up and how it sells.
Responsibility along the supply chain. Producers, importers and retailers do not carry the same obligations, and the line between them is not always where businesses expect.
What pre-dates 27 September 2026. Existing products, packaging and websites are not automatically safe.
Financial services. The guarantee rules do not apply to them. However, the green claims rules do, alongside sector rules such as the SFDR.
Guarantees that almost qualify. A producer warranty that falls just short of the GARAN conditions raises its own questions.
Priorities for businesses
In our experience, three areas deserve attention first.
What consumers see: the Legal Guarantee notice and, where relevant, the GARAN label, at every point of sale, in shops and online.
What the business claims: environmental wording, badges and labels, and the evidence that stands behind them.
Who signs off: a clear owner for consumer-facing claims. In most businesses, responsibility is spread across marketing, e-commerce and compliance, and rarely sits with one person.
What suppliers provide: the information behind labels and claims often comes from producers and suppliers, and contracts rarely say who is responsible for it.
Why this matters
The Legal Guarantee notice may look like an administrative detail. It is more than that. Every consumer in the EU now sees the same reminder of the same rights, wherever they shop, and better-informed consumers tend to use their rights.
The green claims rules shift the burden onto businesses. A claim that cannot be backed up should not be made.
The financial exposure is real. In Cyprus, the Consumer Protection Service can impose administrative fines of up to 5% of the business's turnover in the previous financial year or, where turnover cannot be established, up to €3 million, with additional daily fines for continuing breaches. In coordinated cross-border cases, EU law allows fines of at least 4% of annual turnover.
Fines are only part of the picture. Consumer complaints, competitor challenges and the reputational cost of a public finding of greenwashing can weigh just as heavily.
More information
Aptus Legal advises businesses on consumer protection and commercial law in Cyprus and the EU. We help businesses review their environmental claims and consumer-facing terms, and build the internal policies and approval processes these rules call for. We are happy to discuss how they apply to your business.
This article is for general information only and does not constitute legal advice. It reflects the position as at its publication date.