E-Commerce Operations and Legal Considerations – Part III: User Manual and Warranty Certificate

Articles 55 and 56 of the Consumer Protection Law apply to e-commerce sales just as they do to retail. The headline obligation: provide a user manual and a warranty certificate with each product sold. The often-missed point: sellers using their own brand or logo on a product carry the manufacturer’s obligations, even if they did not manufacture it.

User Manual

General Requirement

A user manual is required for all products sold via e-commerce, with the following categories exempt:

• Metal, PVC and polyethylene pipes and fittings
• Stationery (paper, pens, erasers)
• Agricultural tools (spades, hoes, scythes)
• Hand tools (pliers, screwdrivers, hammers)
• Clothing accessories (handkerchiefs, belts, buttons)
• Kitchenware (forks, spoons, plates, glasses)
• Handicrafts and jewellery
• Mechanical measuring instruments (tape measures, calipers)
• Spare parts replaced by service stations
• Packaged consumables (machine oil, antifreeze, cosmetics, paint, cement, food and beverages, cleaning products, fuel)

Delivery Format

The user manual may be provided as:

• A printed copy on paper, or
• Digitally — via SMS, email or the internet

If supplied digitally, access information must be printed on the product or its packaging. Where a permanent data storage device is used, the information must also appear on the manufacturer’s or importer’s website. A printed copy must be provided free of charge on request — or if a website is not available.

The Real Function

A user manual’s most important job is defining what falls outside the warranty. Manuals should be drafted with the actual misuse scenarios in mind — not just to meet minimum form requirements.

Warranty Certificate

Scope and Term

The Warranty Certificate Regulation sets out which products must be sold with a warranty certificate. The standard warranty term is two years, although sellers may offer longer terms as a differentiator.

Delivery Format

A warranty certificate may be provided:

• In print
• By SMS
• By email
• Via the internet or similar digital means

A printed copy must be provided if the consumer requests it.

Consumer Rights

If the product malfunctions within the warranty period, the consumer is entitled to free repair. If the product cannot be repaired within the maximum repair period, or breaks down again within the warranty term, the consumer may demand:

• A refund;
• A proportional price reduction; or
• Replacement with an equivalent product.

The seller is obliged to comply.

The Disproportion Test

If replacement creates disproportionate hardship for the seller, the consumer is entitled to terminate the contract or take a proportional reduction. The test weighs product value, severity of the defect, and the practical difficulty for the consumer.

Not Optional

The obligation to issue a warranty certificate is not at the seller’s discretion. Both certificate issuance and the defect-response steps are governed by strict timeframes — and missing them can produce significant exposure.

Conclusion

Warranty and user manual requirements extend the legal architecture of a physical store into the e-commerce channel. E-commerce sellers should draft guidance and documentation tailored to the products they actually sell, and structure after-sales services in line with warranty obligations. Where standard repair and turnaround times cannot be met, the after-sales function needs investment — not workarounds.