The withdrawal button does not concern only financial services

A misconception is spreading among online sellers: the withdrawal button obligation would only concern financial services. Some read an official page, see "financial services" on it, and conclude that they are not concerned. This is a mistake, and it can prove costly.

The obligation applies to any online sale to private individuals. A piece of handmade jewellery, some pottery, a candle, a garment, a training course, a workshop booking: everything is concerned. Here is where the confusion comes from, and what the text really says.

Where the confusion comes from

The first EU rules to give a consumer a withdrawal right for services bought at a distance were aimed at financial services: the Directive 2002/65/ECEUR-Lex ↗ on the distance marketing of consumer financial services. That is a special regime, targeting banking, insurance and similar products.

But the online withdrawal-button obligation does not stop at financial services. It is Directive (EU) 2023/2673 that extends it to all contracts concluded at a distance with consumers, across the 27 EU member states. The result lives in the ordinary-law right of withdrawal (Directive 2011/83/EU), not in a regime reserved for banking or insurance.

Hence the misunderstanding. Someone who lands on a page dedicated to financial services thinks they are reading the general rule. In reality, they are reading a special case. The general rule is broader.

What the text really says

The obligation is set out in Directive (EU) 2023/2673:

The text speaks of "contracts concluded at a distance by means of an online interface". Not "financial services". The scope is that of distance consumer law (Directive 2011/83/EU): any contract concluded between a trader and a consumer, without their simultaneous physical presence, via a website or an application.

Directive (EU) 2023/2673 itself requires, on online interfaces, a withdrawal function that is easy to findEUR-Lex ↗. The spirit of the European text targets all distance sales to consumers, not a single sector.

In practice, who is concerned

The criterion is not your sector, it is your situation: do you sell to private individuals, at a distance, via a website or an application? If so, you are concerned.

• A ceramicist who sells her pieces on her online shop: concerned.
• A jewellery maker on Shopify, WooCommerce or Wix: concerned.
• A cosmetics or candle brand: concerned.
• A coach who sells an online training course: concerned.
• A workshop offering online course bookings: concerned (a supply of services remains a distance contract).

There is no size threshold. A very small business, a sole trader or a large chain: the same rule applies. On this point, see very small businesses and the withdrawal button.

Certain sales fall outside the right of withdrawal (a product unsealed for reasons of hygiene, a bespoke made-to-order item, a perishable good). But these are case-by-case exceptions, not a sector exemption. They are detailed in the exceptions to the right of withdrawal (Directive 2011/83/EU, art. 16).

Why getting this wrong is costly

Wrongly concluding that you are not concerned means selling without a compliant mechanism. Yet, without a compliant mechanism, the withdrawal period goes from 14 days to 12 months and 14 days (Directive 2011/83/EU, art. 10). Every order then remains cancellable for more than a year.

An example. A customer buys a handmade decorative piece. A year later, they change their mind and demand a refund. Without a button and without correct information about their right, you cannot refuse them. With a compliant mechanism, that same customer has only 14 days. The button, far from being a constraint, reduces your exposure from twelve months to two weeks.

Add to this the risk of a fine. Sanctions are set nationally: in Ireland, the CCPC can seek fines of up to €60,000, and for widespread infringements up to 4% of annual turnover under the EU Omnibus Directive (EU) 2019/2161.

How to remove the doubt

Rather than interpreting official pages designed for other cases, settle your situation in two minutes. The "am I concerned" diagnostic asks one question and gives a clear verdict.

And if you are concerned, installation takes only a few minutes: one line of code to paste, on any website, without a developer. The complete guide goes through the obligation article by article.