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E-commerce compliance,
the right of withdrawal, DGCCRF.
Legal news, decree breakdowns, practical guides and field notes to navigate the withdrawal button obligation in force since 19 June 2026. Written by Anis Mokadym, founder of BackToMe.
53 articles
Bought from a non-EU site: is there a right of withdrawal?
You ordered from a site based outside Europe and you want to cancel. In theory, the right of withdrawal can apply if the seller targets EU consumers. In practice, enforcing it is another matter. What you need to know, and your real remedies.
Can a single tool protect both seller and buyer?
The objection is logical: a tool the merchant pays for should work for the merchant. Here's why a neutral third party protects both sides at once, and what it takes for that to be true and not just a slogan.
Travel, flight tickets, hotels: a button to manage?
A dated transport, accommodation or hire service escapes the right of withdrawal. But gift vouchers, undated services and products sold alongside are subject to it. What this changes for a travel site.
Online ticketing: do you have a right of withdrawal to manage?
A dated concert, show or match ticket falls outside the right of withdrawal. But gift vouchers, undated tickets and merchandise are subject to it. What that really changes for your ticketing.
Will the withdrawal button slow down my website?
Asynchronous script, CDN, native JavaScript: what a withdrawal tag changes (or not) for the speed of your e-commerce site and your Core Web Vitals. And how to check it yourself.
The withdrawal button is not your enemy
Many merchants see the obligation as one more constraint. I see it differently: it finally makes a right that already existed enforceable, and it pushes out the shops that poison the market. The thinking behind BackToMe.
Is a free withdrawal button enough to be compliant?
A free form, a plugin, a simple contact link: technically, that displays a button. But the obligation does not stop at the button. What free tools really cover, what they leave out, and why the difference shows up the day a dispute arises.
The withdrawal button does not concern only financial services
A misconception is going around: the obligation would only target financial services. Wrong. It applies to any online sale to private individuals. Here is why.
Handmade creations: withdrawal or made-to-measure exclusion?
Ceramics, jewellery, soaps, handmade textile pieces: the right of withdrawal applies to most of your sales, but certain creations fall under exceptions (made-to-measure, personalisation, sealed products). How to sort honestly, product by product, without getting the side wrong.
Very small businesses and the withdrawal button: no exemption
Many sole traders and small workshops hope for some leniency for small structures. EU law provides none: the withdrawal button obligation (Directive (EU) 2023/2673) applies with no turnover threshold and no minimum number of orders. Here is what that means in practice when you sell on a small scale.
Return costs on withdrawal: who pays for sending it back?
When a customer withdraws and sends their parcel back, who pays for the return? The Consumer Rights Directive (2011/83/EU, art. 14) places return costs on the customer, but a failure to inform can make you bear them. A clear look at outbound costs, return costs and the case of large parcels.
Gift cards and e-gifts: can the customer withdraw?
Does selling a gift card at a distance open a right of withdrawal? Yes by default, with nuances depending on whether it is physical, digital or already used.
Withdrawal button: what merchants correct most
The obligation has been in force since 19 June 2026. The mistakes that come up most often on withdrawal buttons put in place in a hurry, and how to correct them.
Waiving withdrawal on a SaaS or digital content
A customer can waive their right of withdrawal if performance begins right away, but on strict conditions. How to obtain it, and how to prove it.
Withdrawal in B2B: the two conditions to qualify
"B2B has no right of withdrawal." False in one specific case: small headcount and a purchase outside the main activity. The two conditions that can flip a B2B sale into the consumer regime.
Right of withdrawal and returns policy: do not confuse them
"I already have a 30-day returns policy, so I am compliant." No. The legal right of withdrawal and your commercial returns policy are two distinct things. What separates them, and why it matters.
How long must you keep proof of withdrawal?
A withdrawal request can be proved, but for how long must you keep that proof? The answer comes down to the limitation period and evidential value, in tension with GDPR minimisation. What to keep, and for how long.
Withdrawal request received: what to do, step by step
Since 19 June 2026, withdrawal requests come in via the button. Here is the step-by-step for handling a request with no risk: acknowledge receipt, check eligibility, arrange the return, refund within 14 days and keep the proof.
Withdrawal button: 7 points to check compliance
Installing a button is not enough: it must also meet the EU requirements (permanent visibility, free of charge, unambiguous label, acknowledgement of receipt on a durable medium). The checklist to audit your own button in five minutes.
Withdrawal button in place: what about your other obligations?
The withdrawal button obligation has been in force since 19 June 2026. If you have installed it, well done, but it is only one of the B2C e-merchant's obligations. An overview of what an inspection also checks: statutory guarantee of conformity, pre-contractual information, mediator, legal notices and terms and conditions.
The ODR platform has closed: check your mediator and notices
Many online shops still display a link to the European online dispute resolution (ODR) platform. That platform has no longer been operational since 2025. What that concretely changes for your legal notices, and why your consumer mediation obligation, for its part, has not moved.
Sale items and promotions 2026: does the right of withdrawal apply?
The sales season is on, and the question comes back every year on the merchant side: can a customer withdraw from a discounted item bought online? Short answer: yes, exactly as at full price. What this means for refunds, and what really changes in 2026.
A consumer-regulator inspection of the withdrawal button: how it works
Many retailers dread an inspection by the national consumer regulator without knowing how it unfolds. How the regulator spots a non-compliant site, what it checks on the withdrawal mechanism, what it asks you to produce, and the procedure through to the penalty. A concrete walkthrough so you know what to expect and how to be ready.
How much non-compliance costs you: calculating your exposure
The headline regulator fine makes the news, but it is not the most likely cost. The real bill is the extension of the withdrawal deadline to 12 months on every uncovered sale. How to concretely estimate your exposure, and compare it with the trivial cost of getting compliant.
Used product: can you reduce the refund?
A customer withdraws but has clearly used the item. You cannot refuse the refund, but you can sometimes withhold part of it on account of depreciation. What the Consumer Rights Directive (2011/83/EU) really allows, on what conditions, and how to document it without exposing yourself.
Can you test the withdrawal button for free?
Try before you pay? Legal mode is free for 7 days (card required, 0 € today). No separate 'demo mode': from day 1, your button has full legal value.
Not compliant with the withdrawal button? Fix it fast
The withdrawal-button obligation has been in force since 19 June 2026. If your site has no compliant mechanism today, you are no longer in time, but all is not lost. What kicks in right now, what does not apply retroactively, and the plan for putting things right without leaving any sale exposed.
When does the 14-day withdrawal period begin?
Most merchants count the 14 days from the order. That is wrong. The starting point depends on the type of sale: receipt of the goods, the last parcel, the first parcel of a subscription, conclusion of the contract for a service. The detail of Directive 2011/83/EU (art. 9), with the calculation rules, so you never get it wrong again.
Withdrawal: refund before the product comes back?
It is the question that comes up most on the retailer's side: a customer withdraws, asks for their refund, but has not yet sent anything back. Do you have to pay straight away? No, and the law protects you on this precise point. The right to withhold the refund, the return deadline, and who pays the costs.
GDPR and withdrawal: what to do with the form data?
The withdrawal button collects personal data: name, email, order reference, timestamp. What legal basis, what data to collect, how long to keep it, how to reconcile archiving the proof with the right to erasure. The GDPR point that many forget.
Click and collect: a right of withdrawal in store?
A customer orders online but comes to collect in store: do they have the right to withdraw, as with home delivery? The answer depends on a single criterion, and it is not where the customer collects the product. What triggers (or not) withdrawal in click and collect.
A customer is abusing the right of withdrawal: what to do
Orders used then sent back, repeat withdrawals, 'wardrobing'… The right of withdrawal is exercised without giving a reason, but it is not a right to free use. What you can lawfully do when a customer abuses it, and what you cannot.
Partial withdrawal: sending back a single item?
A customer ordered three items and only wants to send one back. Are they entitled to? Yes. Withdrawal can cover all or part of an order. What exactly you refund, and the special case of delivery costs.
Withdrawal: refund in a voucher rather than in money?
A classic temptation for retailers: turning a withdrawal refund into a credit note or voucher to keep the revenue. It is prohibited. The means by which you must refund, within what deadline, and what a late refund costs.
Instalment payments and withdrawal: what happens to the credit
Do you offer payment in 3 or 4 instalments, or financing (Alma, Klarna, linked credit)? When a customer withdraws from a financed purchase, the payment plan does not carry on by itself. What happens automatically, and what you must do on the refund side.
Withdrawal acknowledgement: why the screen is not enough
EU law requires you to acknowledge receipt of the withdrawal on a 'durable medium'. A 'your request has been sent' message shown on screen is not one. What the notion of durable medium really covers, what European case law says about email, and the proof you must be able to produce.
The withdrawal button: installing it depending on your platform
Shopify, WooCommerce, Wix, PrestaShop or a bespoke site: the obligation is the same, the installation method changes. The common principle, the specifics of each platform and the pitfall that shows up everywhere.
Web agency and freelancer: your liability for the button
Since 19 June 2026, the withdrawal button has been mandatory on e-commerce sites. For agencies and freelance developers, the question is not only about their clients: their duty to advise and their contractual liability may be engaged. What you need to know, and how to cover a whole portfolio of sites in time.
Recommending withdrawal compliance as recurring income
For a web agency or a freelancer, the withdrawal button obligation is not just a constraint to handle for their clients: it is a line of recurring income. You recommend BackToMe, the client manages their own account, and you earn 25% of their subscription for life. A guide to the referral programme.
How to write a compliant withdrawal page in 2026
The Right of Withdrawal page is the second cornerstone of your compliance, after the button. Required structure, mandatory information, a template to adapt, and common mistakes.
Withdrawal form template: what actually works
The Consumer Rights Directive (2011/83/EU) provides an official model withdrawal form (Annex I(B)). Here is how to use it correctly, the pitfalls of customised versions and how it compares with the 2026 withdrawal button.
The withdrawal button: where to place it on your e-commerce site
EU rules require easy, permanent access. Footer, header, dedicated page, customer account: the four possible placements, best practice and the pitfalls that break compliance.
Withdrawal button vs cancellation button: 5 differences
The two mechanisms look alike but should not be confused. Use cases, labels, penalties, case law: a comparison table so you don't mix everything up.
The withdrawal button: what Directive (EU) 2023/2673 really requires
The rules that turn the legal obligation into concrete technical requirements. A requirement-by-requirement reading of Directive (EU) 2023/2673, applicable across the 27 EU member states since 19 June 2026.
Made-to-measure or personalised: the withdrawal-exception nuance
The right of withdrawal does not apply to goods 'made to the consumer's specifications'. But where does made-to-measure end and the mere choice of options begin? Decoding a treacherous boundary.
Withdrawal button in your terms and conditions: 3 mistakes that undo everything
Installing the button is not enough. EU law (Directive (EU) 2023/2673) requires you to announce it in your terms and conditions, along with its location. Three common mistakes that bring down your whole set-up.
Withdrawal infrastructure, not a customer-service tool
BackToMe secures the regulatory entry point of withdrawal (Directive (EU) 2023/2673) and stops there. No refund handling, no returns, no customer service. Here is why this narrow scope is an asset.
Selling into the EU from abroad: which consumer law applies?
German, American, Canadian, Belgian, Swiss company… If your commercial activity targets EU consumers, the consumer's own national law may apply to your sales even when your registered office is abroad. The Rome I Regulation and EU Directive 2023/2673 explain why.
Marketplaces: who is responsible for the withdrawal button?
On Amazon, Zalando, Etsy, eBay… who has to install the withdrawal button: the platform, or each of the third-party sellers? The answer depends on who contracts with the consumer. An overview of the cases and the overlapping responsibilities.
The 13 exceptions to the right of withdrawal (Directive 2011/83/EU, art. 16)
Article 16 of the Consumer Rights Directive (2011/83/EU) lists precisely the contracts with no right of withdrawal. In these cases, the button is not mandatory, but the inventory is shorter than many online retailers think. An overview of the 13 cases, with the classic pitfalls.
Withdrawal: the 14-day deadline to refund the customer
Once the customer has clicked the button, the clock is ticking. The Consumer Rights Directive (2011/83/EU, art. 13) gives you 14 days to refund, but with important nuances depending on the payment method, the return of the goods and the type of service. The operational how-to.
The 5 most common mistakes with the withdrawal button
The EU rules are explicit, but many e-merchants misread them. Here are the five most common mistakes, spotted in the first implementations observed, and how to avoid them.
19 June 2026: everything that changes for EU e-merchants
Since 19 June 2026, the withdrawal button has been mandatory across the whole EU (Directive 2023/2673); in Ireland, enforced by the CCPC.