BackToMe is the compliance infrastructure for the withdrawal right (a European obligation, Directive (EU) 2023/2673, in force since 19 June 2026; in Ireland, enforced by the CCPC under the Consumer Rights Act 2022). Installed with a single line of code, it receives the customer's request, sends them an email acknowledgement of receipt they keep, and archives it, timestamped and impossible to alter afterwards, for 5 years. Installing the button covers what the law requires and provides solid proof for every request.

Are cosmetics subject to the withdrawal right?

Yes. Cosmetics, perfumes, skincare and make-up are standard goods: the customer has 14 days to withdraw and obtain a refund. The widespread idea that 'every cosmetic is non-returnable for hygiene reasons' is false. The exception only applies to a sealed product that the customer has unsealed after delivery.

When does the sealed-goods exception apply?

The exception under Directive 2011/83/EU (art. 16) requires three cumulative conditions: the item is sealed for reasons of health protection or hygiene, the consumer has unsealed it after delivery, and they were informed before purchase that unsealing it would forfeit the withdrawal right. If any one is missing, the withdrawal right applies as normal.

Are a perfume or a cream returned unopened refundable?

Yes. As long as the product has not been unsealed, the exception does not apply: a perfume, a cream or a serum returned in their original sealed packaging, intact, must be refunded within 14 days. It is the unsealing, not the cosmetic nature of the product, that extinguishes the right.

What should I do if I receive an opened product without having informed the customer?

If you did not inform the customer, before purchase, that opening the seal forfeits the withdrawal right, you cannot rely on the exception. This information must appear clearly in your terms and conditions and your pre-contractual information. Without it, the refund remains due even if the product has been opened.

Are subscription beauty boxes concerned?

Yes. A beauty box sold at a distance to a consumer opens a 14-day withdrawal right on the subscription. Be careful not to confuse withdrawal (cancelling within 14 days of subscribing) and termination (ending an ongoing subscription): these are two distinct rights. The sealed products inside the box follow the sealed-goods rule.

Cosmetics and hygiene sector

Withdrawal button for cosmetics and hygiene products

Last reviewed on July 22, 2026

Skincare, make-up, perfumes, hygiene products: contrary to a widespread belief, the withdrawal right applies in full. The sealed-goods exception does exist, but it is precise and often misused. Here is the exact rule in force since 19 June 2026, and how to avoid wrongly refusing a refund.

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The general rule: a cosmetic is returnable

A cream, a serum, a foundation, a perfume, a bottle of shampoo: these are standard goods. The customer has 14 days from delivery to withdraw and obtain a refund, without having to give a reason.

The most common mistake in the sector is to believe that ‘every cosmetic is non-returnable for hygiene reasons’. That is false. It is not the nature of the product that extinguishes the right, it is the fact that it has been unsealed by the customer, and only under certain conditions.

Systematically refusing returns ‘because it's a cosmetic’ exposes you: this is exactly the kind of wrongful refusal that the national regulator penalises (in Ireland, the CCPC). The right reflex is to start from the assumption that the product is returnable, then to check whether the sealed-goods exception really applies.

The sealed-goods exception (Directive 2011/83/EU, art. 16)

There is indeed a case where you can refuse the refund: a sealed product that the customer has opened after receipt. At EU level, it is an exception provided for by Directive 2011/83/EU (art. 16), which sets aside the withdrawal right for sealed goods that cannot be returned for reasons of health protection or hygiene. But it requires three cumulative conditions:

1. A good genuinely sealed for hygiene

The product must carry a seal whose function is sanitary (film, foil, cellophane, safety cap). A simple cardboard wrapper or an unsealed box does not constitute a hygiene seal.

2. Unsealing by the customer after delivery

As long as the seal is intact, the withdrawal right remains whole. A perfume or a cream returned sealed, unopened, must be refunded. It is the opening, not the purchase, that extinguishes the right.

3. Clear information before purchase

The customer must have been informed, before ordering, that opening the seal forfeits their withdrawal right. Without this information in your terms and conditions and your pre-contractual information, you cannot rely on the exception, even if the product has been opened.

The real issue: proving the state of the product

In cosmetics, disputes often revolve around a question of fact: was the product unsealed, yes or no, and had the customer really been informed? The day a customer challenges it, what matters is not your word, it is what you can prove.

Hence the importance of a system that, beyond the button, keeps proof that holds up (before a judge or the CCPC) for every request: an email acknowledgement of receipt that the customer keeps, then a timestamped trace that cannot be altered afterwards, archived for 5 years, verifiable even months after the purchase of a sealed product. This is the subject of our dossier on the evidential value of proof of withdrawal. For the detail of the exclusion cases, see also the 13 exceptions to the withdrawal right.

Your sector has its own rules

The withdrawal right applies differently depending on what you sell. See also:

Fashion and textile: trying on, made-to-measure, sealed underwear.
Food and perishables: perishable goods and sealed items.
Electronics and high-tech: unsealed media and digital content.
The 13 exceptions to the withdrawal right.

Your sector is concerned: the proof that protects you, set up in five minutes

The withdrawal button is a European obligation (Directive (EU) 2023/2673) in force since 19 June 2026. BackToMe sets it up, proves every request and applies the law of each EU country. 7-day free trial, 0 € today.

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