November 2025
Consumer, Competition and Sustainability
Green transition: European Commission introduces EU-wide consumer guarantee notice and voluntary durability label
On 5 September 2025, the European Commission announced it had adopted an implementing regulation specifying the form and content of the new harmonised notice and label introduced by the Directive on Empowering Consumers for the Green Transition Directive (EU) 2024/825.
Traders must display the mandatory notice in all EU retail outlets, online and offline, and explain the minimum two-year legal guarantee and available remedies (eg, repair or replacement, partial or full refund). The new voluntary label may be used where businesses offer a durability guarantee beyond two years covering the entire product at no extra cost to the consumer. Where such a guarantee is offered, a label needs to be prominently displayed so that consumers are aware which products benefit from the guarantee – in online sales this may be a graphic next to the product image or listing.
Traders must display the legal guarantee notice prominently in all EU retail channels, online and offline. Where goods do not function as intended, sellers must repair or replace at no cost, with possible price reduction or reimbursement. If producers offer a free durability guarantee beyond two years for the whole product, a harmonised label must clearly identify covered goods and commit to free repair or replacement per the guarantee statement.
Member states must transpose the regulation by 27 March 2026 to apply from 27 September 2026. UK traders targeting EU consumers should align with the notice and label formats by 27 September 2026.
Learn more about the Directive in our ESG Legislation Tracker.
European Commission launches public consultation on evaluation of Geo-blocking Regulation
On 6 October 2025, the European Commission launched a public consultation to evaluate the Geo-blocking Regulation.
The Geo-blocking Regulation prevents businesses using geo-blocking to provide goods and services to consumers in different Member States on different terms, ensuring equal access to goods and services across the EU regardless of where the trader is based and preventing both direct and indirect discrimination. Traders are prohibited from blocking customers from a site or re-routing them to a different version of their website based on where the customer is located.
The consultation seeks evidence on implementation, application and enforcement, including territorial supply constraints and cross-border access to copyright content. It is relevant to all traders selling goods and services across borders in the EU.
The consultation closes on 29 December 2025, and an evaluation is expected in Q2 2026.
Find out about new EU digital laws in this overview from Dr. Axel Frhr. von dem Bussche.
CMA confirms Google has strategic market status in search services
On 10 October 2025, the CMA confirmed Google’s designation with strategic market status ('SMS') in general search and search advertising under the UK digital markets regime that took effect on 1 January 2025. The CMA found legal tests were met, citing substantial and entrenched market power and a position of strategic significance.
The designation’s scope includes general search and search advertising, AI Overviews and AI Mode, and Google’s Discover feed, results page Top Stories and the news tab. The Google News app and website are out of scope, as are syndication services used only for single site search. The Gemini AI assistant is currently out of scope but will be kept under review. The decision is separate from the CMA’s ongoing SMS investigation into Google’s mobile platform.
The designation is not a finding of wrongdoing and imposes no immediate requirements. It enables proportionate, targeted interventions. The CMA expects to consult on possible interventions later in the year. Businesses reliant on Google search or advertising should monitor and prepare to engage with consultations.
Read about the new powers of the CMA here.
