EUREFAS Feedback on Consumer Guarantee Labels

EUREFAS welcomes the Commission’s initiative to develop a new visual identity (ie. the guarantee notice and label) aimed at enhancing consumer awareness to support sustainable consumption and purchasing. As a sector we are dedicated to building consumer trust in refurbished products and we believe the availability of transparent, harmonised guarantee information is essential to empower consumers to make informed, responsible choices, especially in the growing market for second-life electronics.

However, we wish to underline an important concern: the increasing complexity of pre-contractual information obligations risks having the opposite effect. For example, with the entry into force of energy and repair labels for smartphones and tablets in June 2025, consumers and businesses are already adapting to new labelling formats. Introducing another full-scale label at the point of sale, especially one containing detailed text, will result in information overload, be burdensome to administer, and risk confusing rather than informing consumers.

To address this, we encourage the Commission to explore a simplified guarantee symbol like a clear, recognisable visual indicator that a product benefits from a legal or commercial durability guarantee. The symbol could be accompanied by a number indicating the duration of guarantee coverage and come in different colors depending on whether it is the legal protection (blue) or the durability guarantee (green). To maximise the impact of such symbol, it is essential to pair its rollout with consumer education efforts. Without clear communication, even a simplified symbol risks being misunderstood or overlooked. An EU-wide awareness campaign explaining the label's meaning, its role in supporting more durable products, and how it differs from other labelling schemes would help ensure that consumers recognise and trust this indicator, ultimately reinforcing its effectiveness in guiding sustainable purchasing decisions.

This approach would promote clarity and visibility and be easier to implement across physical and digital retail environments. Such a symbol could be linked (via QR code or digital display) to additional details when needed, without overwhelming the consumer at the point of choice.

We thank the Commission for its efforts and remain available to contribute further on behalf of Europe’s refurbishment industry