Is the withdrawal button mandatory on mobile apps?
Do you publish a mobile app that sells to consumers in the EU? Yes, the withdrawal button is mandatory there, exactly as on a website: the obligation targets every online interface, iOS and Android included (Directive (EU) 2023/2673, across the 27 EU member states). What matters is that the contract is concluded at a distance, not the technology of the interface.
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Why the mobile app is not exempt
EU Directive 2023/2673 expressly targets ‘all distance contracts concluded by electronic means’, and the Consumer Rights Directive (2011/83/EU) harmonises the underlying withdrawal right across the 27 member states. The text does not distinguish between a website and an app. A contrary reading would amount to creating a legal grey area for m-commerce, which now represents a major share of e-commerce.
The national rules transposing it require that the button be ‘visible and permanently accessible from every page that lets the user view or modify their orders’. For an app, that means: home screen, product page, basket, order history, user profile.
Three ways to integrate it
- The page directly in the app: your app displays the button page hosted by BackToMe, without the customer leaving it. Nothing to change other than an address to point to. Ideal for hybrid apps (Cordova, Capacitor).
- A link to the browser: the button in the app opens the hosted page in Safari or Chrome. Compatible with every app, with nothing extra to install. The customer briefly leaves the app.
- A custom screen connected to BackToMe: to keep the customer inside your app, you connect your own screen to BackToMe (sending the request, returning the acknowledgement). A little more work, but the most fluid experience.
Special case: hybrid site + app sales
If the same company sells through a website and through an app, a single mechanism is enough provided it is accessible from both interfaces. The common practice is to point both interfaces to the same hosted page. Dated archiving then covers both channels in the same way, which simplifies matters in the event of an inspection by the national regulator (the CCPC in Ireland).
What about marketplace apps (Amazon, Zalando, Vinted)?
It is the marketplace operator that bears the technical obligation for the button, not each third-party seller. The third-party seller, however, remains responsible for actually processing the withdrawal (refund within 14 days). For ‘standard’ merchant apps (a single merchant), the technical and legal responsibility falls on the publisher.
Integrate the button into your app in five minutes
Page in the app, link to the browser or custom screen: BackToMe provides the hosted page and the documentation for all three integration modes. Compatible with iOS, Android and hybrids (React Native, Flutter, Cordova, Capacitor).
See the integration guides