The E-Warranty Act Explained: Can Product Warranties Be Digital?

Since October 2016, US brands have been allowed to post warranty terms online instead of packing a paper warranty into every box. Few brands use that option well. This guide explains what the E-Warranty Act allows, what still has to be printed, how product registration fits in, and what changes if you also sell in Europe.

This article explains the rules in plain language. It is not legal advice, so check your warranty wording with counsel.

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Open the box of almost any appliance, power tool or gadget sold in the US and you will still find a folded warranty leaflet. Most people throw it away with the cardboard. When something breaks two years later, nobody can find it, and the customer calls your support line to ask what is covered.

Congress changed the law to fix part of this problem ten years ago. The FTC updated its rules a year later. The leaflets stayed, partly out of habit and partly because the rules come with conditions that are easy to get wrong.

What is the E-Warranty Act?

The E-Warranty Act of 2015 is a US federal law that lets manufacturers meet their warranty availability duties by posting warranty terms on their own website instead of including a paper copy with every product. It was signed on September 24, 2015 as Public Law 114-51 and added a new paragraph to section 102(b) of the Magnuson-Moss Warranty Act, the 1975 law that governs written warranties on consumer products.

In its findings, Congress said that many manufacturers and consumers prefer to give and receive warranty information online, and that an electronic option would expand consumer access "in an environmentally friendly way."

The Act did not create digital warranties on its own. It told the FTC to update its rules within a year, and it set two conditions any online option has to meet:

1. The terms must be available "in an accessible digital format on the Internet website of the manufacturer" in a clear and conspicuous manner.
2. The product, its packaging or its manual must tell consumers the website where the terms can be reviewed and give a phone number, postal address or "other reasonable non-Internet based means" of getting them.

What the FTC rules require

The FTC published its final rule on September 15, 2016. It amended two rules: the Disclosure Rule (16 CFR Part 701) and the Pre-Sale Availability Rule (16 CFR Part 702). Both took effect on October 17, 2016.

Under the amended 16 CFR 702.3(b)(2), posting terms online is an alternative to the old methods: a printed copy with the product, a tag or label, terms printed on display packaging, or a poster in the store. A brand that chooses the online option takes on four duties:

The fourth duty is where many digital warranties fall short. A single "warranty" page with fifteen product lines, three regions and old and new versions of the terms is hard to navigate. If the customer can't tell which terms apply to the model in front of them, you haven't met the duty.

The rules apply to written warranties on consumer products that cost the consumer more than $15. The separate requirement to title a warranty "full" or "limited" applies above $10, according to the FTC's Businessperson's Guide to Federal Warranty Law.

The amendments also clarify what "on the face of the warranty" means online. Certain disclosures, such as limits on implied warranties, must appear on the face of the warranty. For terms posted on a website, that means "in close proximity to the location where the warranty text begins." The FTC was clear that the substance doesn't change: warranties posted online are held to the same rules as paper ones.

The retail catch: pre-sale availability

The Magnuson-Moss Act has always required that shoppers can read a warranty before they buy. The E-Warranty Act kept that. For products sold in a store, by catalog or door to door, the online option only applies if the seller makes the terms available at the point of sale, "through electronic or other means," before the purchase.

The amended rule lets the retailer meet this electronically if the brand has chosen the online method, either by displaying the terms near the product or by providing them on request with a sign telling shoppers they can ask.

For brands that sell through retailers, this is where the plan has to be practical. A store associate has to be able to show the terms. In practice that means:

• the warranty URL, a QR code, or both, printed on the packaging the shopper sees on the shelf,
• a page that works on a phone and loads fast in a store,
• warranty terms your retail partners can show, print or link to from their own product listings.

Digital warranty cards and product registration

The E-Warranty Act covers where the terms live. It says nothing about registration. That is covered by older FTC rules, and they affect how you design a digital warranty card. For the practical side of the form, see our warranty registration guide.

• Full warranties. Under 16 CFR 700.7, requiring a customer to return a registration card as a condition of a full warranty is an unreasonable duty. A line like "this warranty is void unless the registration card is returned" is not allowed. You can offer a card as an optional way to record the purchase date, as long as you say that not returning it doesn't affect warranty rights as long as the customer can show the purchase date some other reasonable way.
• Limited warranties. Under 16 CFR 701.4, if registration is a condition of coverage, the warranty has to say so. If it only looks like a condition but isn't, the warranty has to say that too.

The same logic applies to a QR code that opens a registration form. Digital registration is a better experience than a paper card: it takes seconds, it can attach a receipt photo, and the customer gets a confirmation they can find again. But it doesn't change what you can legally require. Most brands are better off with an honest message: "Register to keep your proof of purchase and warranty in one place. Your warranty applies either way."

That message also tends to get more people to register, because it doesn't feel like a trap.

Is a QR code enough?

QR codes are the obvious way to connect a box to a web page, and they are how most customers will actually reach your terms. But the law asks you to show the website where terms can be reviewed, and a QR code on its own is not human-readable. The cautious approach:

1. Print a short, readable URL next to the QR code, for example yourbrand.com/warranty.
2. Print a phone number or mailing address for people who can't or won't go online.
3. Make the QR code open the warranty for that exact product, not your homepage.

There is a second point that is easy to miss. The statute and the rule both refer to the warrantor's or manufacturer's own website. If your warranty lives on a third-party platform, the safest setup is to serve it from your own domain or link to it clearly from your site's warranty page.

If you are redesigning packaging anyway, it is worth looking at GS1 Digital Link QR codes. One code holds your GTIN (and optionally a serial number), works at retail checkout as GS1 moves toward 2D barcodes, and can open a product page with the warranty, the manual and registration. You can try it with our free GS1 Digital Link generator.

How the EU differs

If you also sell in Europe, don't assume the US rules carry over.

• Guarantee statements need a durable medium. Under Article 17 of the Sale of Goods Directive (EU) 2019/771, a commercial guarantee statement must be given to the consumer on a durable medium at the latest when the goods are delivered. A durable medium is one the consumer can store and reproduce unchanged, such as a PDF or an email. A web page that can change is generally not enough on its own. The statement must also say that the legal guarantee is not affected.
• Instructions are going digital, with conditions. The EU Machinery Regulation (2023/1230) allows digital instructions for use from January 20, 2027. Manufacturers must mark how to access them, keep them online for at least 10 years, and provide paper free of charge within one month if the user asks at the time of purchase. Essential safety information for non-professional users must still be on paper. More product rules are heading the same way, as we covered in the EU's move to digital-first manuals.

A practical setup for both markets: an online warranty page per product for the US, plus an automatic confirmation email with a downloadable warranty certificate for every registered owner. The email and PDF meet the EU's durable-medium idea and give US customers a record they won't lose.

A checklist for going digital

Use this before you drop the paper leaflet:

• Your warranty is titled "full" or "limited" (products over $10).
• The full terms are posted on your own website, one clear page per product or product family.
• Customers can tell which terms apply to their exact model, and older versions stay findable for products already sold.
• The packaging, product or manual shows the warranty web address in readable text.
• The same place shows a phone number, mailing address or other non-internet way to request a copy.
• Someone on your team owns sending free hard copies promptly when asked.
• Retail partners can show the terms before purchase (shelf-facing QR code or URL, product listing links).
• Registration is optional under a full warranty, and if a limited warranty requires it, the warranty says so.
• Required disclosures appear near the top of the online warranty, where the text begins.
• For the EU, every buyer gets the guarantee statement on a durable medium by delivery.

Where Veribl fits

Veribl gives every product a branded page that a QR code on the box opens directly. No app or account is needed. On the page you can show the warranty length, coverage details, and terms and exclusions for that product. Customers can register in seconds, attach a receipt photo as proof of purchase, and submit a warranty claim from the same page.

Registered owners get an email link to their product, where they can see their warranty status and download a warranty certificate. The pages can run on your own domain, so the terms sit on your website rather than someone else's.

It is one way to drop the paper leaflet without dropping the record. If you are comparing tools, our warranty management software guide covers nine options. You can also see how warranty management and product registration work in Veribl.

The bottom line

The E-Warranty Act made paper warranty leaflets optional for US brands, not obsolete. Going digital is allowed if you show the web address and a non-internet contact on the product or packaging, mail free copies on request, keep the right terms easy to find for each product, and make sure retailers can show them before purchase.

Brands that do this well remove the leaflet and build a better warranty experience: one scan to the right terms, an optional registration that keeps proof of purchase, and a record customers can find years later.