From 1 January, 2022, contracts governed by French or German law for the sale of digital content and services, and goods with digital elements, will be subject to harmonised European rules that grant additional legal protections to consumers, and impose additional obligations on sellers and professional service providers. In Germany, the new provisions apply to agreements entered prior to that date, where the services under the agreement are provided on or after 1 January 2022. Moreover, in Germany the rules on the information obligations will change on 28 May 2022. In the United Kingdom, consumer law primarily reflects harmonised EU law that was in effect before the end of the Brexit transition period at the end of 2020. The EU rules provide that a legal guarantee of conformity will now explicitly apply to the supply of digital content and services (such as videos, music files, software, live streaming events, and social media), and to goods with an integrated digital element (such as a smartphone or connected device). The French and German changes are the result of the transposition across Europe of EU Directives 2019/770 (the “Digital Content Directive”, “DCD”) and 2019/771 (the “Sale of Goods Directive”, “SDG”). Since the source of the rules is a directive, individual Member States have been left to implement the requirements into national law, which can give rise to national variations. However, in comparison to other European directives, the risk of variations from the Directives may be limited since, according to Art. 4 DCD and Art. 4 SGD provide that the Member States shall not maintain or introduce national rules that diverge from the DCD and SGD, unless otherwise provided for in the directives.