What does the law require?
From June 2026, any online store selling in the EU must offer an online withdrawal function: an express, clearly identifiable mechanism so the shopper can withdraw from the contract within the 14 calendar days following delivery, without having to register or sign in. Hiding a link on a policy page isn't enough: the obligation is active and symmetric to the one at checkout.
Directive (EU) 2023/2673 · online withdrawal function · amends Directive 2011/83/EU by introducing a withdrawal button accessible without registration.
In practice, the competent authority expects to see three things:
- A button or equivalent mechanism visible in the shopper's order area.
- Clear information about the 14-day deadline and the full refund.
- A downloadable model form (the statutory withdrawal form).
The withdrawal button, step by step
The button isn't a whim of the rule. It's the shopper-side equivalent of the earlier omnibus directive obligation: the consumer must be able to exercise their right in a single click, justifying nothing, without going through customer support.
The button text is “Withdraw from contract here”: the clearly identified label the rule requires. Vague phrases like “Request a return” or “Start a request” are not admissible — they do not identify the exercise of the right — and recent case law has called them into question.
Deadlines: 14 calendar days and a full refund
Two deadlines live in the rule, and both count in calendar days, not working days:
- Deadline to withdraw
- 14 calendar days from delivery of the product (not from purchase).
- Deadline to refund
- 14 calendar days from when the seller receives the withdrawal notice.
- Form of the refund
- Same payment method used for the purchase. You can't force a voucher or store credit.
- Return shipping cost
- Borne by the shopper, unless the seller failed to clearly inform them before purchase (in which case the seller pays).
Directive 2011/83/EU · art. 13 · “The trader shall reimburse all payments received from the consumer, including, where applicable, the costs of delivery.”
Mistakes that cost fines
These are the five failures most often seen in real audits:
Banned dark patterns
The DSA (Regulation EU 2022/2065) expressly bans designing interfaces that make withdrawal harder. National authorities have flagged three classic ecommerce dark patterns:
- Asymmetry: buying takes 2 clicks, returning asks for 7 screens.
- Hidden cost: “We'll have to charge you €5 in handling.”
- Confirm-shaming: “Are you sure? You'll lose your loyalty discount.”
Regulation EU 2022/2065 (DSA) · art. 25 · “Providers of online platforms shall not design […] their interfaces in a way that deceives or manipulates.”
Penalties and what they cost
Penalties scale with severity. Each country's transposition sets the tiers:
The competent body is each country's consumer authority. Exact fine ranges depend on national transposition and should be confirmed with local counsel.