Starting September 27, 2026, you must inform consumers of their statutory warranty rights when offering many “physical” “thank-you” gifts. What matters is not the term “thank-you,” but whether you, as a business owner, are offering goods to consumers.
When do I need a warranty label for my thank-you gift?
Starting September 27, 2026, you will generally need the EU Guarantee Label if all of the following apply:
- In this project, you'll act as an entrepreneur.
- Supporters act as consumers.
- A "thank you" is a tangible, physical commodity.
- A binding contract for these goods is formed through your project.
This also applies to pre-orders, products that are still to be manufactured, and goods that you will produce only after the campaign ends.
For what kinds of thank-you gifts do I need the label?
For physical goods, you generally need the warranty label. Typical examples include:
- Books, coffee-table books, comics, and print magazines
- Posters, art prints, photos, postcards, and calendars
- Vinyl records and analog music cassettes
- Clothing, Shoes, and Textiles
- Jewelry, Accessories, and Watches
- Mugs, water bottles, bags, pins, stickers, and keychains
- Board games, card games, puzzles, and toys
- Furniture, Lighting, Ceramics, and Decor
- Tools, sporting goods, bicycles, and accessories
- Electronics, hardware, technical prototypes, and connected devices
- Cosmetics, soap, personal care products, and candles
- Food and Beverages
- Plants, Seeds, and Flowers
- used or refurbished goods
- Personalized products, custom-made items, and one-of-a-kind pieces
Even a low value or custom manufacturing does not, in principle, change the classification of an item as a good.
For which thank-you gifts do I not need a warranty label?
For purely digital content, services, and support that do not involve the exchange of goods, you generally do not need this graphic label. Examples include:
- donations only
- Acknowledgments and Special Thanks
- E-books, PDFs, and other downloads
- MP3 downloads, streaming, and podcast access
- Apps, software downloads, and digital games
- Online courses, webinars, and digital workshops
- Coaching, consulting, guided tours, and in-person meetings
- Tickets for concerts, theater performances, festivals, or exhibitions
- Overnight stays, travel, and dining out
- Memberships or community access without physical delivery
Different disclosure requirements may apply to digital products and services.
What are the rules for CDs, DVDs, and USB drives containing content?
For CDs, DVDs, Blu-rays, and USB drives containing music, movies, or software, you should verify their classification. If the storage medium is used exclusively to transfer digital content, the rules for digital products generally apply. An empty USB drive or memory card, on the other hand, is a physical good and generally requires a warranty label for B2C sales.
What are the rules for food and perishable products?
You generally need the warranty label when selling food and beverages online as well. This applies, for example, to coffee, chocolate, jam, juice, beer, and fresh food.
The label does not mean that a food product must have a two-year shelf life. It does not extend either the best-by date or the use-by date. What matters is whether the product has the agreed-upon and expected quality at the time of delivery.
What are the rules for personalized or used items?
Even personalized, handmade, and used goods generally require a warranty label. A possible exception to the right of withdrawal for custom-made items does not eliminate the statutory warranty rights.
For used goods, the time limit for claims for defects may be shortened under certain conditions. However, the provided warranty label must not be altered.
What are the rules for thank-you packages containing goods and digital services?
As soon as a package contains a physical product, you should include the warranty label for that product component. Digital content and services included in the same package are treated as separate items under the law and may trigger additional disclosure requirements.
How do I include the note with my thank-you message?
Until Startnext automatically integrates this information, you can add a clearly visible note at the end of the description for each relevant thank-you gift. Depending on the project language, use this template:
German: [url=https://www.startnext.com/media/public_002/labels/legal-guarantee-harmonised-notice_de.jpg]Your statutory warranty rights[/url]
English: [url=https://www.startnext.com/media/public_002/labels/legal-guarantee-harmonised-notice_en.jpg]Your Statutory Warranty Rights[/url]
The notice should appear directly on the respective physical thank-you gift and not just be hidden in the general project description. The linked image is a temporary solution; what matters is that supporters can clearly see the complete, full-color label before entering into a contract.
What is the difference between the warranty label and the GARAN label?
The warranty label provides information about legal rights and is generally required for relevant B2C sales of goods. You only need the additional GARAN label if the manufacturer offers a qualified durability guarantee that:
- is free for supporters,
- includes all the merchandise,
- is valid for more than two years and
- is provided along with the required manufacturer information.
A seller's warranty, a warranty covering individual components, or a warranty of no more than two years is not sufficient to qualify for the GARAN label.
Does the label mean that my thank-you gift has to last two years?
No, the warranty label is not a blanket guarantee of shelf life. The warranty covers defects and the agreed-upon or reasonably expected quality of the product. Normal use, natural wear and tear, or the expiration of a use-by date do not automatically constitute defects.
Who is responsible for proper labeling?
As a business owner offering a project, you are generally responsible for the proper classification and labeling of your thank-you gifts. Startnext provides the platform and technical capabilities, but does not automatically review your specific offer from a legal perspective.
If you're unsure whether your thank-you gift qualifies as goods, a digital product, or a service, have the specific case reviewed by a legal professional.
When does this requirement take effect, and does it apply to existing "thank you" gifts?
This requirement takes effect on September 27, 2026, with no general transition period. Even thank-you messages that have already been published must be correctly labeled as of that date if they are to remain available for selection.
Where can I find official information?
For more information and the official templates, visit the European Union's "Warranty Label" and "GARAN Label" pages.