Marketplaces: who is responsible for the withdrawal button?

When you sell across several channels, the same question comes up every time: if I am on Amazon, Zalando, Etsy or a vertical marketplace, who has to install the withdrawal button that has been mandatory since 19 June 2026, me or the platform?

The rule is simple: the button is the obligation of the trader who contracts with the consumer. The platform, for its part, has distinct obligations that stack on top of the seller's, without replacing them.

The principle: the contract is concluded between the seller and the customer

The EU withdrawal-button rule (Directive (EU) 2023/2673) provides that "the trader makes available to the consumer" the withdrawal functionality. The "trader" is the one who sells, not the one who hosts the transaction.

On a third-party marketplace such as Amazon Marketplace, Zalando, Etsy, eBay or a vertical marketplace, the sales contract is formed between the third-party seller (the e-merchant who offers the product) and the customer (the consumer). The platform is, legally, only an intermediary bringing the parties together and a supplier of technical services. It is not a party to the sales contract.

The third-party seller is therefore the one who must make sure the withdrawal functionality exists for their sales, whatever the channel. Under Rome I (Regulation (EC) No 593/2008), the law that applies is the consumer's own national law, so the seller answers to each customer's home-country rules.

The three possible configurations

Configuration 1: the pure marketplace (third-party sellers only)

Examples: Etsy, Vinted, specialised vertical marketplaces.

The platform sells nothing of its own. All products are sold by third parties. Each professional seller must therefore, individually, set up the withdrawal mechanism required by Directive (EU) 2023/2673, either by using the tools the platform provides (returns form, integrated customer-service area), or by supplementing them if the native tool does not cover all the criteria of the directive (permanent visibility, unambiguous wording, acknowledgement of receipt on a durable medium, enforceable archiving).

If the platform does not offer a compliant tool, the third-party seller remains responsible. They must then find a way to expose a compliant button in their seller area, or stop selling through that platform.

Configuration 2: the hybrid platform (direct seller + marketplace)

Examples: Amazon, Zalando, Otto, Bol.

On these platforms, some products are sold directly by the retailer ("sold and shipped by Amazon", for example), others by third-party sellers ("sold by X, shipped by Amazon"). The two situations coexist on the same site.

• For its own sales: the platform is the trader. It has to install the button.
• For third-party sellers' sales: each seller is the trader for their own sales. They must make sure that withdrawal is effective.

The customer, though, sees a single interface, hence the need for the platform to guarantee that the withdrawal mechanism is uniform and accessible whatever the seller. This is what is known as the duty of fairness of the interface.

Configuration 3: dropshipping

The seller displays a product on their own site, but it is a third-party supplier (often abroad) who ships it. Typical question: who is the trader?

Answer: you, the reseller. The contract is formed between the customer and the site on which they placed the order. The supplier at the end of the chain is legally invisible to the consumer. It is therefore the reseller who must install the button, handle the withdrawal and send the acknowledgement of receipt. An often-forgotten point: they must also bear the refund even if their supplier is slow to take the goods back.

What the platform must nonetheless do

Not being the seller does not exempt the platform from all its obligations. It remains bound by several texts.

Fairness and transparency about the seller's status

Article 24 of Regulation (EU) 2022/2065 (the Digital Services Act) requires online platforms to identify clearly, for each offer, whether the seller is a professional or a private individual. Without this identification, the consumer may legitimately believe they are buying from a private individual, and therefore that no right of withdrawal applies. This is now clearly unlawful.

In practice, on the interface: a visible banner on the product page ("Professional seller") should remove any ambiguity.

Accessibility of the withdrawal function

The Directive (EU) 2023/2673 refers to a "withdrawal function that is easy to find". If the platform offers a unified purchasing journey, it must guarantee that this function remains accessible whatever the seller, including for third-party sellers. The platform cannot make do with a "contact the seller" page that would pass responsibility back to the third party without a coherent technical mechanism.

Informing the consumer about the identity of the contracting party

The pre-contractual information required by the Consumer Rights Directive (2011/83/EU, art. 6) must clearly identify the trader: company name, VAT number, address, telephone number, email. On a marketplace, this information is that of the third-party seller, not of the platform. If the platform does not surface this data on the product page or in the order, it exposes the seller to a breach of that information duty, and itself to a breach of the European rules on intermediary services.

Worked example: you sell on a marketplace and you also have your own Shopify site

You are the trader on both channels. The EU obligation applies to both.

• On your Shopify site: you install your own button (BackToMe or another).
• On the marketplace: you use the returns-management tool provided by the platform, making sure it does meet the four criteria set by Directive (EU) 2023/2673 (permanent visibility, clear wording, automatic acknowledgement of receipt, enforceable archiving).

If the marketplace's tool meets only part of the criteria, you remain responsible for filling the gap. Many platforms have announced changes to their internal tools for 19 June 2026, so check the communications from each marketplace on which you sell.

The classic mistake

"The marketplace takes care of everything for me." Almost always false. Marketplaces provide a framework, tools, an infrastructure, but the sales contract binds you directly to the customer, and the EU obligation follows you even when you sell through an intermediary.

When the platform is not compliant

You remain responsible for your sales. Either you supplement the platform's tool with an external mechanism (an automatic email on your side, independent timestamped archiving, manual handling if needed), or you stop selling through that platform until it becomes compliant, a radical option, sometimes the only realistic one for high-volume sellers.

To check whether the obligation concerns you, the diagnostic settles whether you fall within scope in a single question. If you manage several sites (agency, multi-store e-merchant, multi-instance SaaS), the multi-site console brings everything together in a single account with team roles and billing per activated site.