Do digital products need the EU legal guarantee notice?

The harmonised notice concerns the legal guarantee of conformity for physical consumer goods. Digital content and services are governed by a separate regime, so an ebook, a software licence, or a downloadable template is not what this notice is for. Showing it on a download is not a compliance win — it's misinformation about the buyer's rights.

Do gift cards need the guarantee notice?

No. A gift card is not a physical consumer good being sold with a conformity guarantee; it's a payment instrument. Shopify flags gift cards natively, so this is one of the easier exclusions to automate.

Does the notice apply to B2B orders?

The legal guarantee of conformity is a consumer protection, so it applies to B2C sales. Pure B2B or wholesale sales fall outside it. On Shopify the practical difficulty is that B2B and B2C often share a catalogue, so exclusion usually keys on tags or a B2B channel rather than the product itself.

How do I classify a large Shopify catalogue without tagging everything?

Use signals you already have. requiresShipping on the default variant is the strongest available proxy for physical versus digital. Shopify's native gift-card flag handles gift cards. Product type and tags catch the rest — services, subscriptions, bookings, wholesale-only lines. Hand-tagging is the fallback for genuine edge cases, not the starting point.

Which products need the EU guarantee notice?

Quick Answer

Short answer: the notice is for B2C sales of physical consumer goods. Digital downloads, services, subscriptions, gift cards, and B2B/wholesale orders sit outside it. On Shopify you can classify most of a catalogue automatically from requiresShipping, the native gift-card flag, product type, and tags — hand-tagging should be the exception.

From 27 September 2026, the harmonised legal guarantee notice is mandatory for EU B2C sales of physical goods under Regulation (EU) 2025/1960. The obvious reading is "put it on every product page". For most Shopify catalogues that's wrong, and wrong in a way that's worse than it sounds.

Over-showing is a real failure, not a safe default

There's a tempting instinct to slap the notice everywhere on the grounds that extra compliance can't hurt.

It can. The notice tells a consumer they have a legal guarantee of conformity on that purchase. Displaying it against a digital download or a service tells the buyer something about their rights that isn't accurate for that product. You've swapped one information problem for another, and you've made your storefront harder to reason about if a regulator ever asks why the notice appears where it does.

The notice is a statement about rights

It isn't a badge or a trust seal. Showing it where the legal guarantee of conformity doesn't apply is misinformation, not caution.

The four categories to exclude

Digital goods and downloads

Ebooks, software licences, templates, presets, downloadable audio. Digital content and digital services are covered by a separate EU regime from the sale-of-goods rules the harmonised notice is about.

Signal to use: requiresShipping on the default variant is the single strongest proxy you have. A product that doesn't ship is almost never a physical consumer good. Back it up with product-type matching on terms like digital, download, ebook, software, licence.

Services, subscriptions, and bookings

Consultations, installation, memberships, appointment bookings. Same reasoning — not a good being sold.

Signal to use: these usually also fail requiresShipping, but product type is the reliable tell: service, subscription, consultation, booking.

Gift cards

A gift card is a payment instrument, not a good with a conformity guarantee.

Signal to use: Shopify flags gift cards natively, so this is the cleanest exclusion available. No tagging required.

B2B and wholesale

The legal guarantee of conformity is a consumer protection. A pure B2B sale isn't a consumer sale.

Signal to use: this is the awkward one, because B2B and B2C frequently share a catalogue. The product itself is often identical — the same kettle sold retail and wholesale. So exclusion generally keys on tags (b2b, wholesale, trade-only) or on the sales channel, not on product attributes.

A classification order that works on real catalogues

Edge cases worth deciding deliberately

Bundles mixing physical and digital. A course with a printed workbook. The physical component is a good. Most merchants show the notice, on the basis that a physical good is genuinely part of what's being sold — but decide it once, deliberately, rather than letting it fall out of whichever rule happens to match first.

Made-to-order and personalised goods. Still physical consumer goods. Personalisation affects withdrawal rights, which is a different regime — it doesn't remove the conformity guarantee.

Pre-orders. A sale is a sale. The notice belongs on the product page at the point the consumer is deciding.

Marketplace or dropshipped stock. If you're the trader selling to the consumer, the obligation is yours regardless of who holds the inventory.

How we handle it

Our app ships these as configurable exclusion rules — digital, gift cards, and B2B each toggle independently, because the right answer genuinely differs by catalogue. The classification runs from requiresShipping, Shopify's gift-card flag, product type, and tags, so most stores get a correct split without tagging anything.

The rules are pure predicates, which matters more than it sounds: the same logic decides what renders on the storefront and what the admin reports as covered, so your compliance dashboard can't disagree with your product pages.

Frequently asked questions

Next: which language the notice must appear in — the part that breaks most often in production — and which products qualify for the GARAN label.

This guide is written by the team behind an EU guarantee compliance app for Shopify. It's a practical implementation guide, not legal advice — for a definitive read on your obligations, talk to a lawyer in your market.