Overview
What changes on 27 September 2026 for Shopify merchants?
From 27 September 2026, every EU online shop faces new obligations on the product page. This overview explains what EmpCo actually requires, without the legalese.
Key takeaways
- From 27 September 2026, every EU B2C shop must show the statutory legal-guarantee notice on the product page.
- Offer a durability guarantee and you also show the official GARAN label.
- Blanket environmental claims like “klimaneutral” become actionable by a competitor, with cost recovery.
- EmpCo was not scrapped (that was the separate Green Claims Directive).
What is EmpCo, and why does it affect your shop?
“EmpCo” is the EU directive on empowering consumers for the green transition (Directive (EU) 2024/825). It adds concrete pre-purchase disclosures to consumer and fair-competition law, and an accompanying EU implementing regulation defines exactly what the legal-guarantee notice and the durability label look like.
For you as a Shopify merchant, that means the changes don’t live in a footer. They live on the product page, the exact page where the sale happens.
Legal basis
Directive (EU) 2024/825 (EmpCo) · Implementing Regulation (EU) 2025/1960 · German transposition: Third UWG Amendment Act (Federal Law Gazette I, 19 Feb 2026)
The directive amends, among others, the Consumer Rights Directive and the Unfair Commercial Practices Directive; Germany transposes it in the BGB/EGBGB and the UWG.
The three obligations from 27 September 2026
1. Legal-guarantee notice
Every product page must carry the notice about the statutory legal guarantee, as an embedded graphic to the official template, placed before the buy button. A mere link or a collapsible dropdown does not satisfy the information duty. This disclosure is mandatory and is enforced by consumer associations and bodies such as the Wettbewerbszentrale.
2. GARAN label
If you voluntarily offer a durability guarantee, the harmonised EU label (“GARAN”) must be shown correctly and consistently. It tells consumers at a glance how long you stand behind the product’s durability.
3. No misleading environmental claims (green claims)
Blanket, unproven environmental claims are expressly prohibited. Wording like “klimaneutral” without recognised proof counts as an unfair commercial practice. It’s the best-known example and far from the only one: whole classes of environmental claim are covered, right down to icons and self-made seals.
This is the sharpest cost risk
Who does this apply to?
To every trader selling to consumers (B2C) in the EU: in practice, essentially every German and EU Shopify shop. There is no small-merchant exemption. Pure B2B shops are not affected by the notice in the same way, but should review their environmental claims too.
What to do now
- Check whether the legal-guarantee notice appears as a graphic, before the buy button, on your product pages.
- Decide whether you offer durability guarantees. If so, you need the GARAN label.
- Scan your product copy for risky environmental claims and replace them with evidenced wording.
- Do it early: waiting means exposure from day one.
Konforma handles this automatically.
Konforma adds the legal-guarantee notice and GARAN label to every product page automatically, and finds the green claims that risk a cease-and-desist. No code, no customer data.
A quick note on scope
Questions on this topic
Does EmpCo apply to small shops too?
Yes. The obligations apply to any trader selling to consumers (B2C) in the EU, regardless of size. There is no de-minimis threshold.
What happens if I do nothing?
Without the legal-guarantee notice you risk challenges from consumer associations and bodies like the Wettbewerbszentrale. Unlawful environmental claims can additionally be met with a competitor cease-and-desist (Abmahnung) that recovers costs.
Do I always have to show the GARAN label?
No. The GARAN label is only relevant if you offer a commercial durability guarantee. The statutory legal-guarantee notice, by contrast, is mandatory for all goods.
Is EmpCo the same as the Green Claims Directive?
No. The Green Claims Directive was withdrawn. The EmpCo directive (2024/825) is independent of it and still applies, enforced from 27 Sep 2026.