The harmonised notice on the two year guarantee, the label for a durability guarantee, the update period and the repairability score, owed before the consumer is bound.
The Consumer Protection Law of 2021 has been amended, most recently by Law 122(I)/2026, and the amendments reach the part of a business that is hardest to change quietly: what has to appear on the page, on the shelf edge and in the confirmation email, before the consumer is bound.
Most commentary on consumer law in Cyprus is about what happens after a sale goes wrong. This is about what has to be said before it happens at all, and the obligations are now specific enough that a template written three years ago will not satisfy them.
The reminder that is no longer optional, and no longer free-form
Two provisions carry the same duty for the two kinds of contract. Under section 16(1)(e) of Law 112(I)/2021, before the consumer is bound by a contract other than a distance or off-premises contract, the trader gives a reminder that a legal guarantee of conformity for goods exists and what its main elements are, including its minimum duration of two years as laid down in the Law on certain aspects concerning contracts for the sale of goods. The reminder has to be given in a prominent manner and by using the harmonised notice provided for in section 17A. Section 17(1)(ib) imposes the same duty for distance and off-premises contracts.
Two things in that are new in substance rather than in wording. The duty is not satisfied by a sentence buried in the terms, because the Law requires it in a prominent manner. And it is not satisfied by your own form of words, because the Law requires the harmonised notice.
What the harmonised notice and the harmonised label actually are
Section 17A(1) explains why they exist: so that consumers are well informed and can easily understand their rights throughout the European Union, a harmonised notice is used for the information under section 16(1)(e) and section 17(1)(ib), and a harmonised label for the information under section 16(1)(e1) and section 17(1)(ib1).
Section 17A(2) fixes the content of the notice. It contains the main elements of the legal guarantee of conformity, including its two year duration.
Section 17A(3) fixes the qualities of both. They are easily recognisable and understandable for consumers, and convenient and easy for traders to reproduce, and, by the proviso to that subsection, the notice and the label meet the conditions and requirements laid down in Implementing Regulation (EU) 2025/1960. That is where the actual artwork and its rules come from, which is the practical answer to the question every business asks first: you do not design this yourself.
The durability guarantee, and the label that goes with it
The label is not for every product. It is triggered by a particular commercial offer, and the trigger is worth reading closely.
Under section 16(1)(e1), where the producer offers the consumer a commercial guarantee of durability at no extra cost, covering the whole of the goods, for a period longer than two years, and makes that information available to the trader, the trader gives information that the goods carry that guarantee, its duration, and a reminder that the legal guarantee of conformity exists. Section 17(1)(ib1) is the same for distance and off-premises contracts.
Four conditions therefore have to be met together: no extra cost, the whole of the goods, more than two years, and the information actually made available to you by the producer. A guarantee that covers the battery but not the device, or that is sold as an add-on, is not the guarantee this provision is about, and describing it with the harmonised label would misdescribe it.
Software updates, repairability, and spare parts
Three further paragraphs matter to anyone selling anything with a chip in it.
- Section 16(1)(e2) requires a reminder that a legal guarantee of conformity exists for digital content and digital services.
- Section 16(1)(e4), and section 17(1)(ib3) for distance contracts, require the minimum period during which the producer or provider supplies software updates for goods with digital elements, digital content and digital services, expressed either as a period of time or by reference to a date, where the producer or provider makes that information available to the trader.
- Section 16(1)(ia) requires the repairability score of the goods, where applicable. Where it is not, section 16(1)(ib) requires instead, and again only where the producer makes the information available, the availability, estimated cost and ordering process for the spare parts needed to keep the goods in conformity, and the availability of repair and maintenance instructions.
The recurring condition is the same in each: the duty attaches where the producer or provider makes the information available to the trader. That makes this a supply chain question before it is a website question. A retailer that has never asked its suppliers for an update period or a repairability score will not be able to answer, and the place to fix that is the supply agreement.
What this means in practice
The work divides into three, and only the last of it is legal drafting.
Ask the producers. For every product line, the trader needs to know whether a durability guarantee is offered at no extra cost over the whole of the goods for more than two years, what the minimum software update period is, and whether there is a repairability score or, failing that, spare parts and repair information. None of that is knowable from the product page. It comes from the supplier, and it belongs in the supply contract rather than in an email that will not be found next year.
Fix the presentation, not just the text. The reminder about the legal guarantee has to be prominent and has to use the harmonised notice, and where a durability guarantee applies the harmonised label goes with it. That is a change to the product page, the checkout and the point of sale, and it has to survive a theme update.
Keep the record. Information duties are proved by what the consumer was shown on the day, not by what the current version of the site says. A business that changes its terms and its product pages without retaining the earlier versions cannot show what was displayed at the time of a sale it is later asked about, and under section 21(1) the consequence of an information failure about the right of withdrawal is a withdrawal period that ends twelve months after the original one.
The provisions above are taken from the consolidated text of Law 112(I)/2021 as it stood when this article was written. The Law has been amended more than once and the amending Law's own commencement provisions govern when each duty bites, so the dates for a particular obligation are confirmed before a compliance date is promised to anybody.
Questions we are asked
What is the harmonised notice?
It is the prescribed way of giving one piece of information: the reminder that a legal guarantee of conformity exists and what its main elements are, including its minimum duration of two years. Section 16(1)(e) of Law 112(I)/2021 requires that reminder to be given in a prominent manner using the harmonised notice provided for in section 17A, and section 17(1)(ib) does the same for distance and off-premises contracts. Section 17A(3) requires the notice and the label to be easily recognisable and understandable for consumers and easy for traders to reproduce, and provides that both meet the conditions and requirements set out in Implementing Regulation (EU) 2025/1960.
When does a trader have to use the harmonised label?
Where the producer offers the consumer, at no extra cost, a commercial guarantee of durability that covers the whole of the goods and lasts more than two years, and makes that information available to the trader. Section 16(1)(e1) and section 17(1)(ib1) of Law 112(I)/2021 then require the trader to give information about the existence of that guarantee and its duration, together with the reminder of the legal guarantee of conformity, and section 17A requires the harmonised label for it.
Do we have to publish how long software updates will be supplied?
Where the producer or provider makes that information available to you, yes. Section 16(1)(e4) and section 17(1)(ib3) of Law 112(I)/2021 require the minimum period, expressed either as a period of time or by reference to a date, during which the producer or provider supplies software updates for goods with digital elements, digital content and digital services.
What is the repairability score, and what if there is not one?
Section 16(1)(ia) requires the repairability score of the goods to be given where applicable. Where it does not apply, section 16(1)(ib) requires instead, provided the producer makes the information available to the trader, information about the availability, estimated cost and ordering process for the spare parts needed to keep the goods in conformity, and about the availability of repair and maintenance instructions.
Does any of this change the fourteen day right to withdraw?
It does not shorten it, and it can lengthen it. The fourteen days under section 20(1) are unchanged, as is the thirty days under section 20(1A) for a contract made during an unsolicited visit or an organised excursion. What matters is section 21(1): where the trader has not given the information about the right of withdrawal required by section 17(1)(h), the withdrawal period ends twelve months after the end of the original period. Information duties and the withdrawal clock are the same subject.
Sources
This article is provided for general information purposes only and does not constitute legal advice.
Klitos Platis
Advocate, Partner
Kleanthous & Platis LLC, Nicosia · Published 23 August 2026
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