The button works, the customer has clicked, the acknowledgement of receipt has gone out. The technical part stops there; what follows is pure operations, and that is where most online retailers get caught out. Directive (EU) 2023/2673 and the button govern the receipt of the withdrawal. The handling is governed by the Consumer Rights Directive (2011/83/EU, arts. 13 and 14), harmonised across the 27 EU member states and in force since 2014. The changes of 19 June 2026 do not replace them, they stack on top of them.
A quick tour of the rules to know.
The principle: 14 days, unless a special case applies
The Consumer Rights Directive (2011/83/EU, art. 13) is explicit:
Consumer Rights Directive (2011/83/EU), art. 13
Where the right of withdrawal is exercised, the trader shall reimburse the consumer for all sums paid, including delivery costs, without undue delay and no later than fourteen days from the date on which it is informed of the consumer's decision to withdraw.
The rule seems simple: 14 days, from the moment you receive the withdrawal (so, in practice with BackToMe, from the click on the button). Except that three subtleties throw most retailers off.
The start date of the deadline
The deadline starts on the date of notification, not the date the goods are returned. If the customer clicks on the 1st of the month and the parcel comes back to you on the 20th, you do not have 14 days from the 20th, you had 14 from the 1st.
This is why the timestamp of the withdrawal has legal value. Without an enforceable timestamp, you cannot establish the date of notification, and the customer can claim to have informed you earlier. Settled doctrine, where there is doubt, adopts the date most favourable to the consumer.
The deferral for physical goods
The directive provides a major exception for physical goods:
Consumer Rights Directive (2011/83/EU), art. 13(3)
For contracts of sale of goods, unless the trader has offered to collect the goods itself, the trader may withhold reimbursement until it has received the goods back, or until the consumer has supplied evidence of having sent back the goods, whichever is the earliest.
Concretely: for a sale of physical goods, you can wait until the customer sends the item back to you or provides proof of dispatch (tracking number, photo of the drop-off receipt). When the first of the two events occurs, the 14-day deadline begins to run.
For physical goods, the deadline is therefore not necessarily 14 days after the click, it is 14 days after the return, or after the proof of dispatch. For services and digital content, the deadline does start at the click.
The refund method
On the refund method, the directive is strict:
The payment method
The trader shall carry out the reimbursement using the same means of payment as the one used by the consumer for the initial transaction, unless the consumer has expressly agreed otherwise.
If the customer paid by card, you refund to the card. No bank transfer "because it is simpler", no credit note, no voucher, unless the customer themselves explicitly asks for another method. And even then, you must keep written proof of that agreement.
This is the second most common mistake: converting the withdrawal into a credit note "to smooth out customer service". This turns a legal right into a commercial favour and exposes you to a breach of the refund rule (Directive 2011/83/EU, art. 13).
The penalty if you exceed the deadline
A late refund is penalised, and the consequences are set by national law (they are not harmonised across the EU). In France, for example, a late refund automatically generates a progressive increase of the sums due, with no formal notice required, rising the longer the delay runs, up to the price of the product. Other member states set their own consequences; whatever the market, refunding on time is the only safe course.
On top of any such increase, where a breach is found by the national consumer regulator (in Ireland, the CCPC), an administrative fine is added (in Ireland, up to €60,000 under the Consumer Rights Act 2022, and up to 4% of turnover for widespread infringements under the Omnibus Directive (EU) 2019/2161). And, in the event of a dispute, damages may be claimed by the consumer before the court.
The procedure on the retailer's side
Concretely, as soon as a withdrawal lands in your dashboard:
- D0: The customer clicks, the acknowledgement of receipt goes out automatically (BackToMe handles it), and the enforceable timestamp is set.
- D0 to D3: For a physical item, you tell the customer the return method (drop-off point at your expense or costs at theirs, depending on your T&Cs) and you generate the label if needed. For a service or digital content, skip straight to step 4.
- Dx: Receipt of the goods or proof of dispatch. Note this date: it is what starts your 14-day deadline.
- Dx + 14 maximum: Refund to the same means of payment as the initial transaction. Keep the record (screenshot of the Stripe / PayPal / bank back office) with its timestamp.
- Final archiving: The whole chain (withdrawal, acknowledgement, return, refund) must remain accessible for several years. The exact period is set by national law and varies by member state (the limitation period for commercial claims and the retention period for accounting records are commonly around 5 to 10 years). If you use BackToMe, the withdrawal and the acknowledgement are already archived on the platform side for 5 years; it is up to you to keep the log of the return and the refund on your side.
The most common trap
The disputes that come up almost never concern the 14-day deadline in itself, they concern the starting point of the deadline. The retailer thinks they are refunding on time because they count from the return of the parcel; the customer considers they were within time because they had supplied proof of dispatch a week earlier. The judge rules in the consumer's favour, and the delay is established.
Best practice
As soon as a withdrawal arrives: note the date of the click, the date of the return and the date of the proof of dispatch if one was supplied. The deadline runs from the earliest of the three for a physical item, and from the click for a service or digital content. Where in doubt, refund early: an early refund costs nothing, a late refund costs dearly.
In practice
14 days to refund, from the click for a service, from the return or the proof of dispatch for a physical product. To the same means of payment as the initial transaction, unless the customer themselves asks for something else. Automatic increase in the event of delay, and a regulator fine where a breach is found (in Ireland, up to €60,000). And an enforceable timestamp, without which the date of notification can be challenged.
BackToMe covers the technical part: button, form, acknowledgement of receipt on a durable medium, enforceable timestamp, archiving. The operational handling (decision on the return, checking the proof of dispatch, triggering the refund) remains in your hands, as provided for by the division of responsibilities set out in EU consumer law. This division is explained in detail in the product's scope (infrastructure, not customer service).
For the full sequence of handling a request, from acknowledgement of receipt to closure, follow the retailer's step-by-step; to know from when the withdrawal period itself runs, see the starting point of the 14 days; and for how long to keep the records, see how long to keep proof of withdrawal.
To check whether you are concerned, the diagnostic settles it in one question. To go further into the whole framework (button, form, penalties, exceptions), the full guide sets out the official texts article by article.
Founder of BackToMe
Art. L.221-21 · 19 June 2026
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