On September 27, 2026, two regulations will come into effect that affect every product page in German online shops. One is a new mandatory label, the other prohibits wording that has been used in many shops for years. Both stem from the same EU directive, and both can be implemented in WooCommerce—one with a plugin update, the other without.
The annoying thing is: the technical part can be done in a morning and therefore feels like the whole task. But it isn't. The second part is painstaking work on the product range, and that can't be made up for in the week before the deadline.
This article describes the technical requirements. It is a presentation of the current situation and not legal advice; whether and how these requirements apply to your product range should be reviewed by a lawyer if there is any doubt.
What will change on September 27th
The basis is Directive (EU) 2024/825, usually called the EmpCo Directive — “Empowering Consumers for the Green Transition”. It has been in force since 26 March 2024, Member States had to transpose it into national law by 27 March 2026, and it is applicable from 27 September 2026.
The exact design of the two labels is not specified in the directive itself, but in a separate implementing regulation: Implementing Regulation (EU) 2025/1960, published in the Official Journal of the EU, specifies templates, color values, fonts, and proportions. Anyone wishing to see what the final label will look like can find it in the annexes there—in all official languages.
For a shop, the matter falls into two very different tasks:
- A new label has been added to the product page. Technical work, clearly definable, solvable with plugin support.
- A ban on blanket environmental statements. Editorial work on the entire product range, which no plugin can take over.
The second point is the more complex one — and the one that most shops overlook because it doesn't look like a technical task.
The warranty label: mandatory for B2C shops selling physical goods
The warranty label informs consumers about their legal rights in the event of defective goods. It is not an advertising element or a seal of approval, but standardized information – its design and text are predetermined and may not be altered. It may not be adapted to corporate colors, reduced in size until it is inconspicuous, or integrated into a company's own icon set.
According to both major German WooCommerce legal plugins, all shops selling physical goods to consumers (B2C) are affected . Purely B2B shops and purely digital products are subject to different regulations—precisely where the line is drawn is the point at which legal review is worthwhile. And one more point that is often overlooked: the obligation doesn't end with your own shop. Those who also sell via marketplaces have the same obligation there as well.
Where the label must appear
The plugin manufacturers place it in three locations:
- on product page, near the price tag,
- im Cart, as soon as at least one affected product is contained therein,
- im Checkout, with the same condition.
German Market can also activate the output for selected customer emails.
The warranty label: voluntary — and easier to go wrong than right
The second label is something different and is regularly confused with it. It does not provide information about the statutory warranty, but rather about a commercial durability guarantee that the manufacturer or retailer voluntarily offers in addition.
In order for it to be shown at all, two conditions must be met:
- The warranty must the entire goods affect, not just individual components.
- she must longer than two years to run.
Herein lies the practical pitfall: Germanized points out that the warranty period must be at least 30 months because the label can only display six-month increments. A 27-month warranty, therefore, cannot be shown.
Furthermore, there's a point that shifts the effort from "tapping a box" to "data maintenance": The warranty label is n't a standardized design . It displays the brand, model identifier, warranty period, and a QR code that links to the warranty overview. This means it's generated anew for each product —and the QR code must be clearly legible under normal lighting conditions.
And the most important point: issuing a warranty label constitutes a legally binding commitment. If the product data record specifies a warranty period that is not honored in the customer's case, the label is not an advantage, but a risk. Before activation, it's essential to verify that the stored warranty periods are actually correct—not just whether the field is filled.
Green Claims: the issue that no software can solve
The second part of the directive concerns environmental claims. Blanket statements without evidence are prohibited—terms such as "environmentally friendly," "sustainable," "eco," or "climate-friendly"—if they are not substantiated. Also affected are climate neutrality claims based solely on offsetting.
That sounds like a handful of product descriptions. In practice, this kind of thing appears in many more places:
- in product and short descriptions,
- in category texts and on landing pages,
- in Shipping and packaging instructions (“climate-neutral shipping”),
- in icons, badges and homemade seals,
- in filters and attributes (“sustainable: yes”),
- in newsletter templates and order confirmations.
No plugin can find these spots for you. This is a product range review—and the reason why this part of the process takes longer than the technical one. Those who have already structured their product data have a clear advantage here; we described how much depends on clean data in our article about the product data feed before the season . And those who have already maintained their attributes in a machine-readable format can collect the suspicious terms in one pass instead of forty.
The difference to the Green Claims Directive
One point that's often confused in the reporting: The Green Claims Directive is a separate, independent legal act . According to the German Retail Federation (Händlerbund), its negotiations were paused in mid-2025, and its implementation remains uncertain. What applies on September 27th is the EmpCo Directive—not the Green Claims Directive. Anyone who confuses these is either planning too much or too little.
What Germanized and German Market deliver
Both German WooCommerce legal plugins delivered support at the end of August 2026 —about a month ahead of schedule. This is the real reason why hardly any shops are ready now: it simply wasn't technically possible before then.
- Germanized 4.1 brings an automatic output, plus the shortcode
For any desired location, there's an "EU Warranty Label" block for the product page in full-site editing themes, and a separate block for the checkout. The warranty label uses a shortcode.The settings are located under WooCommerce → Settings → Germanized → Price Labeling. Details can be found in the [document/section/etc.]. Vendidero manufacturer's documentation. - German Market 4.0 The labels are displayed on product pages and optionally in selected customer emails. In the shortcode-based shopping cart and checkout, the output is automatic. What's new in this version summarizes... MarketPress itself assembled.
One small detail that is frequently overlooked: Both labels are disabled by default after the update . Simply updating the plugin isn't enough—the shop ends up exactly where it was before, just with a new setting that no one has touched.
The block checkout is the crucial point.
If there are any problems with implementation, it's usually here. With version 8.3, WooCommerce made block-based shopping carts and checkouts the standard. German legal plugins work differently there than in the old, shortcode-based checkout—and the automatic output, which works seamlessly in the shortcode checkout, requires a separate block in the block checkout.
For shops, this means specifically:
- Check which checkout option you actually have. Many shops from the years 2018 to 2022 are still running on the shortcode checkout without anyone noticing.
- Set blocks individually during block checkout. — The product page, shopping cart, and checkout are three separate locations.
- Then place a test order. Don't check the setting, but go through the actual ordering process and see if the label appears in all three places.
Another stumbling block with Germanized: The WooCommerce standard block for the terms and conditions is supposed to be replaced by Germanized's own checkbox block in the block checkout. If both remain, the notice is displayed twice.
How much is involved in the German checkout process can be clearly seen in our free Smart Checkout for WooCommerce — legal information, mandatory fields and order completion are more closely linked than it appears in the backend.
What multilingual shops also need to consider
If WPML or another translation solution is involved, testing should be performed in every language. With the cancellation button, which became mandatory in June 2026 , missing or incorrectly assigned translations were one of the most frequent problems reported in the support forums. There is no reason to assume that the warranty label will be any different.
The checklist until September 27th
- Update plugin. Germanized on 4.1, German Market on 4.0 — first a backup that can also be restored.
- Determine checkout type. Shortcode or block? Everything else depends on that.
- Activate warranty label and make it visible in all three places: product page, shopping cart, checkout.
- Only activate the warranty label there. where a genuine 30-month durability guarantee applies to all goods — and check the stated times against the actual commitment beforehand.
- Review the product range for environmental claims. Product texts, category texts, shipping instructions, icons, attributes, email templates.
- Collect evidence, where an environmental statement should remain. Without evidence, it's better to delete it than to rephrase it.
- Completed a test order — in every language, on mobile and desktop.
- Save a screenshot of the three locations, with the date. This saves time and effort in case of a dispute.
How much does that cost?
The technical aspect is manageable: For a well-maintained shop with an up-to-date legal plugin and a shortcode checkout, the label can be applied in a morning, including a test order. It becomes more expensive if the shop is still using an older plugin version, if the theme interferes with the product page, or if the block checkout has been heavily customized.
What really drives up the scope is the second task. The inventory review scales with the number of items and the number of entries that need to be maintained—attributes and email templates are almost always overlooked in the process. With several thousand items, this isn't a manual operation, but rather an evaluation run through the database followed by an editorial decision for each entry. That's why we start with the inventory, not the product listing.
How we implement
First, measurements are taken, not installations: Which legal plugins are running and in what version, which checkout type is active, which languages are available, and how many hits does the search for environmental terms actually return? Only then is it clear whether it will take a morning or a week.
Customizations are developed as a separate plugin according to WordPress coding standards, update-proof and without interfering with the theme or core—ensuring nothing changes with the next Germanized update. If it turns out that your existing plugin already supports everything after the latest update, we'll let you know. Those who prefer to outsource the entire process can find the necessary support from our WooCommerce team in Hamburg.
Why this is not purely a compliance issue
Two things argue in favor of not treating the effort as a bothersome obligation.
First, the pressure of cease-and-desist letters is real. According to the German Retail Federation (Händlerbund), the German Competition Authority recorded 644 cases concerning price transparency in 2025 —an increase of 11,6 percent compared to the previous year—and 241 legal proceedings, an increase of 18,1 percent. Experience shows that new labeling requirements are precisely the area that is scrutinized in the first few months after a deadline. How easily such a deadline can be overlooked in everyday business has already been demonstrated this year: the mandatory use of a cancellation button, which came into effect on June 19, simply escaped the notice of many online shops.
Secondly, a review of the product range is long overdue anyway. Anyone who systematically examines their product range for unsubstantiated claims regularly finds more than just environmental claims: outdated delivery times, prices that are no longer accurate, product descriptions that refer to variants that no longer exist.
The IT law firm has prepared detailed information on the design requirements for both labels—colors, proportions, language versions . However, the legal classification of your specific product range remains the responsibility of a lawyer or trade association.
The most important points in three sentences
The warranty label will be mandatory from September 27, 2026, and Germanized and German Market have been providing the necessary technology since the end of August—but it's not activated automatically. Block checkout is where implementations often fail, so a real test order is essential, not just a glance at the settings. And the part that really takes time is reviewing the product range for unsubstantiated environmental claims—don't wait until mid-September for that.
What about you?
I'm particularly interested in one thing: How many hits does a search for "sustainable," "eco," and "climate-neutral" return in your shop? Experience shows that everyone underestimates the numbers—and everyone forgets these attributes anyway. If you'd like, send us your figures and your checkout type; we're collecting feedback because the status of both plugins is changing rapidly, and the manufacturer's information isn't always up-to-date. If, instead, you'd like to know where your shop stands, we'd be happy to review the three search terms and your product range together.
Frequently asked questions about the warranty label
From what point exactly does the warranty label apply?
These regulations apply from September 27, 2026. They are based on EU Directive 2024/825, which entered into force on March 26, 2024, and had to be transposed into national law by March 27, 2026. Affected shops should have implemented the necessary features by then.
Does this also apply to purely B2B shops?
The warranty label is aimed at consumers. According to the plugin developers, shops that sell exclusively to business customers are affected differently than B2C shops. For shops with mixed product ranges or those serving both customer groups, each case must be examined individually—this is a legal question, not a technical one.
Can I visually customize the label to match my shop design?
No. The design and text are predetermined and may not be changed. What you can influence is the placement—not the appearance.
Is it enough to update the plugin?
No. Both labels are disabled by default after the update and must be activated. This is usually sufficient for shortcode checkouts; for block-based checkouts, the blocks must also be set, and for multilingual shops, each language must be checked individually. The green claims aspect is not covered by the plugin at all.
What happens if I put the warranty label on incorrectly?
A warranty label is a legally binding commitment to the customer. If it includes a durability guarantee that isn't honored in the event of a complaint, that's a separate problem—independent of the labeling requirement. Therefore: better no label than a false one.
Why does the warranty label need a QR code?
Because it not only indicates the warranty but must also provide details. The label includes the brand, model identifier, and duration, while the QR code links to the warranty overview. This means it's generated anew for each product—and the code should actually be legible under normal lighting conditions.
How can I find unsubstantiated environmental claims in a large product range?
A full-text search of the database for relevant terms—environmentally friendly, sustainable, eco, climate-neutral, CO2-neutral, green, resource-saving—is performed across product texts, short descriptions, category texts, attributes, and email templates. With several thousand items, this is a single evaluation run, not manual work.
What is the difference between the EmpCo Directive and the Green Claims Directive?
These are two separate legal acts. The EmpCo Directive (EU) 2024/825 applies from September 27, 2026, and regulates, among other things, the two labels and the ban on blanket environmental claims. The Green Claims Directive is a separate project, the negotiations for which, according to the German Retail Federation (Händlerbund), have been paused since mid-2025. Anyone confusing the two is planning for the wrong date.
Conclusion: The technical part is small, the editorial part is not.
Setting up the warranty label in WooCommerce can be done in a morning—provided the plugin is up to date, the checkout type is known, and someone remembers to activate the output. What does take time is reviewing the product range for environmental claims, and that can't be left until the last day.
Those who tackle both aspects together will not only have another label on September 27th, but also a product range that is clear and transparent in its messaging. That's the part that will still be valuable even after the deadline.






















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