Installing the withdrawal button is only one part of compliance since 19 June 2026. This obligation is European (Directive (EU) 2023/2673), applicable across the 27 EU member states; in Ireland, the CCPC enforces it. The Consumer Rights Directive (2011/83/EU, art. 6) imposes, in parallel, complete pre-contractual information on the right of withdrawal, which must appear in black and white in the terms and conditions or on a dedicated page. Here is how to write it without falling into the traps that undo the whole mechanism.
Why a dedicated page or a terms-and-conditions section?
The Consumer Rights Directive (2011/83/EU, art. 6) sets out a long-standing requirement: the consumer must be able to consult, before ordering, the precise terms of their right of withdrawal. This includes the length of the deadline, its starting point, the procedure for exercising the right, the refund arrangements, and the location of the dedicated button.
Two formats are accepted: a dedicated section within the terms and conditions (recommended for classic e-commerce sites), or a standalone "Right of withdrawal" page accessible from the footer. The legal criterion is not the form but the accessibility of the information.
The recommended structure
A compliant page typically contains six sections, in this order:
1. The legal deadline
Fourteen calendar days from delivery of the goods (for a physical good) or from conclusion of the contract (for a service or digital content). State that these days are calendar days, not working days. If the last day falls on a Saturday, Sunday or public holiday, the deadline is extended to the next working day.
2. The applicable exceptions
List the cases where the right of withdrawal does not apply to your activity, with reference to the exceptions (Directive 2011/83/EU, art. 16). Of the exceptions listed there, you should detail only those that concern you. For example, a SaaS provider will detail the digital-content exception (digital content executed immediately with express waiver); a standard ready-to-wear shop will have no exception to mention.
3. The procedure for exercising the right
Since 19 June 2026, you must indicate three means of exercising the right, in this order of priority:
- The dedicated withdrawal button, permanently accessible on the site (mention of its location is mandatory).
- The model withdrawal form provided in the annex to the Consumer Rights Directive (2011/83/EU, Annex I(B)), downloadable or embedded.
- Any other unambiguous statement (email, letter, free-form).
Failing to mention the three channels is a frequent mistake. The presence of the button does not exempt you from offering the other means.
4. The refund arrangements
Legal deadline of 14 days from receipt of the withdrawal (the refund rule, Directive 2011/83/EU, art. 13). Specify the means of payment used for the refund: by default, the same as the one used for the initial purchase, unless the consumer expressly agrees to another means.
Also mention that, for a physical good, the retailer may defer the refund until the goods are actually recovered, or until the consumer has provided proof of dispatch (whichever comes first).
5. The costs of returning the goods
For physical goods, specify who bears the cost of return: the consumer (the most frequent case, provided this point is mentioned before the purchase, otherwise the cost falls on the retailer) or the retailer (a commercial argument of the "free returns" type). The information duty (Directive 2011/83/EU, art. 6) requires this transparency.
6. The official model withdrawal form
The Consumer Rights Directive (2011/83/EU, Annex I(B)) provides a model withdrawal form that you must embed or make downloadable. A full copy-and-paste is sufficient; case law does not require any adaptation. Our terms-and-conditions clause generator integrates this form into the clause it produces.
Three mandatory mentions that are often forgotten
Beyond the structure, certain precise statements are regularly omitted and cause disputes with the CCPC:
- The method of calculating the deadline: do not settle for "14 days". Specify "calendar", "from delivery" (or "from conclusion of the contract" as the case may be), with a worked numerical example recommended for the most complex purchases (multi-item order, staggered delivery).
- Clear identification of the recipient of the withdrawal: company name, full postal address, dedicated email. If you have a return address different from your registered office, state it explicitly.
- The fact that exercising the right is free of charge: no exercise fee may be charged to the consumer; only the direct costs of returning the goods may be (and only if announced before the purchase).
Four mistakes that undo compliance
Mistake 1, Page not accessible from every page of the site
Directive (EU) 2023/2673 requires the information to be "easily accessible". A well-written page hidden behind three clicks in a drop-down menu is not enough. The link must appear in the permanent footer, visible on every page.
Mistake 2, Mixing the withdrawal deadline with commercial policy
If you offer an extended commercial deadline (30 days, "free returns for up to 60 days"), it must be distinguished from the legal deadline. The customer must understand that the legal deadline of 14 days applies as of right, regardless of your commercial conditions. Mixing the two creates a legal confusion that can be penalised.
Mistake 3, Reusing a pre-2026 template
"Right of withdrawal" pages written before 2026 do not mention the dedicated button (which did not exist), nor the technical requirements of Directive (EU) 2023/2673. Reusing an old template as is (an official model, a chamber-of-commerce template, and so on) without updating it automatically drops you into non-compliance.
Mistake 4, Forgetting the standard form in the annex
The model withdrawal form is not optional. Its presence on the page (embedded or downloadable PDF) is an explicit requirement of the Consumer Rights Directive (2011/83/EU). Its absence is a shortcoming that can be observed during a CCPC inspection.
A template ready to adapt
Rather than starting from scratch, our terms-and-conditions clause generator produces a complete clause compliant with the six sections described above, with your company name, your contact details and the location of the button on your site. Five questions, copy-and-paste into your terms and conditions.
For a deeper analysis of the pre-contractual information obligation in the terms and conditions (and the penalties incurred in the event of a shortcoming), see the dedicated analysis of the three terms-and-conditions mistakes that undo compliance.
In summary
A compliant Right of Withdrawal page contains six mandatory sections: the deadline, the applicable exceptions, the three means of exercise (including the button), the refund arrangements, the return costs, and the official model withdrawal form. Four common mistakes (accessibility, mixing legal and commercial, obsolete template, missing standard form) are enough to bring the whole mechanism down. The BackToMe generator produces a complete compliant clause in five minutes, ready to paste.
Founder of BackToMe
Art. L.221-21 · 19 June 2026
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