| 1. For a limited warranty (i.e., an extended manufacturer’s warranty, as distinct from a statutory warranty) provided to a consumer in your country, is there a requirement that the full text of the limited warranty appears in in‐box documentation for devices and accessories? |
No. The law requires that the supplier provides clear, accessible basic commercial information—including the warranty terms—but it does not mandate that the entire text be printed on the packaging. Alternative methods (e.g., a printed link or QR code to the full warranty online) are acceptable as long as the consumer can easily access the complete information. |
| 2. If yes, what is the risk of not complying with this requirement? |
If it were interpreted that a full printed warranty is required and a supplier fails to comply, this could be considered a breach of the duty to inform. This may expose the supplier to administrative sanctions and, potentially, to the nullification of contract clauses that restrict the consumer’s right to full information. However, if the law does not expressly require full printed text, the risk lies in not ensuring clear and immediate access to complete warranty details. |
| 3. If no, what is the minimum reference to the warranty that you recommend including in in‐box documentation (i.e., would it be sufficient to merely reference the limited warranty and its duration, and include a link to more details)? |
It is advisable to include a clear statement indicating the existence of a limited warranty, its limited nature, and its duration. Additionally, the documentation should provide clear instructions on how to access the full warranty text—such as a QR code, URL, or contact details—to guarantee transparency and compliance with the obligation to deliver basic commercial information. |
| 4. For countries where a print warranty is required, would it be sufficient to merely make the print warranty available upon request (as opposed to including a printed version in the box by default)? |
In jurisdictions that explicitly require a printed warranty, offering it only upon request may not meet the requirement for immediate and accessible information. However, if the law permits alternative methods provided that the consumer is clearly informed on how to obtain the warranty, then making it available upon request could be acceptable as long as the consumer’s right to access the complete warranty is not impeded. |
| 5. Would your responses to the above questions differ as between (i) new devices and accessories, (ii) refurbished devices and accessories, and (iii) spare parts? If so, please separately respond to the questions. |
While the principle of transparency applies to all products, for new devices and accessories it is expected that full warranty information is provided immediately. For refurbished devices, accessories, or spare parts, a minimal reference may suffice (indicating the existence of a limited warranty, its duration, and instructions for accessing full details), provided that consumers are fully informed of any differences in coverage compared to new products. |
| 6. Would your responses to the above questions differ if the customer is a business? If so, please separately respond to the questions. |
Yes. The consumer protection law primarily safeguards individual consumers. In business-to-business transactions, the informational and warranty requirements are generally less stringent, as business customers are presumed to have greater bargaining power and expertise. Nevertheless, transparency and clarity remain important, though the regulatory protections may not be as robust as for individual consumers. |