New information obligations
Do you run an Amazon shop or sell via other e-commerce channels? Then this blog post is important for you, because new information and labeling obligations are coming soon. They will affect your product pages, packaging, and customer communication.
The legal basis for this is Directive 2011/83/EU (“CRD” – Consumer Rights Directive), which has regulated consumer protection in the EU internal market for years. For you as a seller, this has so far meant: clear information about online sales, the right of withdrawal, delivery obligations, and more. Now, however, Directive (EU) 2024/825 (“EmpCo Directive”) introduces a new level. You will have to provide even more comprehensive information. This affects, among other things, warranty and guarantee information, often even via a QR code on a label.
Why is this happening? Consumers are demanding more transparency, especially in e-commerce. And the European Commission wants to strengthen consumer rights, particularly in digital sales channels, which are central for you as a seller. In this blog post, you will learn what exactly is changing, what it means for you, and how you can implement the requirements in practice.
Background on the Consumer Rights Directive
Directive 2011/83/EU (CRD) regulates the conditions under which consumer contracts may be concluded, especially in distance selling and outside brick-and-mortar stores. It sets out which information obligations a seller must fulfill before the contract is concluded, how the right of withdrawal works, and how warranty and guarantee conditions must be communicated.
Over the years, the CRD has been amended multiple times, for example with regard to digital content, additional transparency obligations, or improved consumer information prior to concluding a contract. For e-commerce, it has been the key legal basis.
What this has meant for you: so far, you have already ensured that your product pages contain a large number of mandatory disclosures, such as information on withdrawal, delivery terms, prices, and quality. Now comes another step. The information requirements become more detailed, documentation becomes stricter, and labeling becomes clearer. Particularly relevant for e-commerce: your packaging, your website notices, and your customer communication must meet the new requirements, otherwise sanctions may follow.
The EmpCo Directive 2024/825 – what’s new?
The EmpCo Directive supplements the Consumer Rights Directive and introduces two major new elements: increased transparency obligations and new harmonized labeling requirements. These are aimed at strengthening consumer protection for digital and physical products.
Overview of the changes:
- Expansion of information obligations for B2C contracts in e-commerce.
- Focus on environmental transparency, product durability, reparability, and software updates.
- Introduction of an obligation for “harmonized labeling” with a QR code or other digital access points (e.g., Article 22a), so consumers can quickly and easily access key warranty and guarantee information.
For you, this means very concretely: you must adjust your processes, from product packaging to the online shop to customer-facing information. The timeframe is not unlimited. The directive entered into force on March 27, 2024. EU Member States have until March 27, 2026 at the latest to implement it, and as of September 27, 2026, the requirements will be binding.
New mandatory information on statutory warranty rights and guarantees
As an online seller, in the future you will have to not only communicate statutory warranty rights correctly, but also clearly label commercial guarantee promises.
Statutory warranty rights:
In the EU, a minimum period for liability for defects typically applies, usually two years for new goods. You must clearly inform the consumer before the contract is concluded in what form and for what duration statutory warranty rights apply.
Commercial durability guarantee:
If you voluntarily provide a guarantee that goes beyond statutory warranty rights, for example a “5-year guarantee”, special requirements apply. The guarantee must be transparent, unambiguous, easily accessible, and understandable. In the future, it must also be labeled accordingly.
Differences between brick-and-mortar trade and distance selling:
E-commerce triggers special information obligations because the consumer does not enter a physical store. That is why it is no longer sufficient to place guarantee terms somewhere on your website. They must be clear, prominent, and easy to access.
For your Amazon product page, for example, this means: guarantee provisions in the description, a notice about labeling via QR code or link, and a visible presentation of guarantee and statutory warranty rights within the mandatory information.
Article 22a: harmonized notices and labeling
A core element of the EmpCo Directive is Article 22a, which introduces a harmonized notice and labeling requirement, including QR code labels. The goal: consumers should clearly and uniformly understand which warranty and guarantee conditions apply, and be able to access this information in a digital or physical product context.
Content and purpose of the new QR code labels:
The draft label provides that QR codes present information about guarantees or statutory warranty rights in a compact way, even when space is limited. The code includes, among other things:
- Minimum duration of statutory warranty rights (at least 2 years).
- Voluntary manufacturer guarantee beyond two years, including its duration and conditions.
- Links to action areas such as FAQs, complaint forms, or national statutory warranty law.
Where must the label appear?
- In brick-and-mortar retail: clearly visible and legible on the product or on the shelf.
- In online/e-commerce: mandatory on product detail pages, in checkout, and in product ads.
- On packaging and delivery notes: the QR code legally covers all sales channels. Only relevant if a voluntary guarantee is provided.
Technical design framework:
- Uniform pictogram plus QR code for a clear EU-level statement.
- Implementing Regulation (EU) 2025/1960 sets out mandatory design, text, and minimum size.
- The QR code must be reliable: easy to scan, must lead to the correct page, and may need to be multilingual depending on the place of delivery.
For you as an e-commerce seller, this means: start implementing the QR code label early. Build the infrastructure, including the label, link/platform, and content, so you are compliant in time.
Impact on companies
What does this mean for you in practice? Here is an overview of the most important fields of action:
Adapting product labels and information materials:
- Redesign packaging and product labels and integrate the QR code.
- Update online product pages, such as Amazon listings, so warranty and guarantee information is clearly visible.
- Maintain internal documentation for promises and conditions and make it available digitally.
Integrating the QR codes into packaging and online offers:
- Place the QR code on the packaging or include it in the shipment contents.
- Behind the QR code: a landing page with guarantee and statutory warranty terms, contact information, and, if applicable, additional service.
- Amazon and other marketplaces: add a QR code notice in the description and in the mandatory information.
Compliance risks if you do not comply:
- Fines and sanctions may be imposed in the future if mandatory information is missing or not provided correctly.
- In addition to legal risks, you face reputational damage. Especially in e-commerce, transparent communication is key for trust and conversion.
- So: act early, reduce complexity, and set up clean processes.
Conclusion
The new rules show that consumer protection and transparency are becoming even more important in the EU, including in e-commerce. For you as a seller, these requirements create obligations, but also opportunities. Those who start early can position themselves as a trustworthy provider that guides customers safely through the purchase and ownership process.
Opportunities for transparent communication:
- A well-implemented QR code label can serve as a quality feature.
- Customer loyalty is strengthened because you show clearly and easily: guarantee and statutory warranty rights are defined, and we are transparent and service-oriented.
- Your listing stands out from competitors who have not adapted yet.
Next steps for you:
- Review your current product pages, packaging, and guarantee terms.
- Create a list: which changes are necessary, such as labeling, QR code, or landing page?
- Start implementation. We recommend: now, not shortly before the deadline.
- Inform your customers early that you meet the new requirements. This builds trust.
We at Tradavo can help you
If you do not want to navigate the implementation jungle alone: at Tradavo, we support Amazon and e-commerce sellers comprehensively, from analysis to label designs to QR code integration.
You need assistance?
Who wrote this article?
As an author, Christina fills the blog section of our website with exciting and informative articles, so that our readers can always take care of product compliance in their company in the most well-informed way.
