The 8 things your store needs before the withdrawal-button law takes effect
A new EU directive requires every online store selling to EU consumers to provide a simple, digital cancellation flow — often called 'the withdrawal button'. Use this checklist to find out where your store stands, and tick off the boxes in 8 minutes.
Based on EU directive 2023/2673
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A dedicated cancellation button — not a contact form
The button must link directly to something that initiates the cancellation process — not a general contact form, email address, or phone number. The customer must be able to complete the entire withdrawal digitally without human involvement.
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✓ Compliant- A "Cancel order" button in the customer account that opens a withdrawal form
- A dedicated returns portal (e.g. Returbo) linked from order confirmation emails
✗ Not compliant- A "Contact us" form where the customer writes a message requesting cancellation
- An email address labelled "for returns and cancellations"
- A phone number to call customer service
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Findable from every customer touchpoint
The withdrawal flow must be easy to find. A good rule of thumb is that the customer should be able to reach it within two clicks from any natural place they'd look — not buried in a FAQ or only accessible from the homepage.
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✓ Compliant- Link in order confirmation email and shipping notification
- Accessible from the customer account order history
- Linked from the footer and the returns/refund policy page
✗ Not compliant- Only mentioned once in the terms and conditions document
- Accessible only via a search in the help centre
- Not linked from any transactional emails
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Fully digital — no human handling required
The customer must be able to complete the entire cancellation process online without needing to speak to anyone, wait for a reply, or take any offline steps. If your process requires staff approval before the customer receives a confirmation, it does not meet the requirement.
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✓ Compliant- Customer submits a withdrawal form and immediately receives a confirmation — no staff involved
- Automated returns portal that registers the request and sends a return label without manual steps
✗ Not compliant- Customer submits a form but must wait for staff to approve the return before receiving confirmation
- Process requires the customer to print and include a physical return slip
- Customer must call to get a return authorisation number
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Automatic confirmation sent to the customer
As soon as the customer submits a withdrawal, they must receive an automatic confirmation — by email. The confirmation must include the date and time the withdrawal was received. This confirmation is also your proof that the customer exercised their right within the 14-day window.
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✓ Compliant- Automated email sent immediately after form submission with a timestamp and order reference
- Confirmation includes the customer's name, the items being returned, and the date received
✗ Not compliant- Confirmation email is sent manually by staff after reviewing the request
- No confirmation is sent — customer only sees a success message on screen
- Confirmation email does not include a timestamp
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Cancellations are logged and stored on your end
Your store must be able to document that a withdrawal was received, when it was received, and what it covered. This matters if a dispute arises — you need to be able to show that the customer's request was logged and acted upon within the legal timeframes.
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✓ Compliant- Each withdrawal is stored with: order ID, customer ID, timestamp, items covered, and refund status
- Records are searchable and accessible to your customer service team
✗ Not compliant- Withdrawal requests come in via email and are not logged in a system
- Only the customer's message is stored — no structured timestamp or order reference
- Records are deleted after the return is processed
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The button stays active throughout the withdrawal period
The withdrawal button or link must remain available for the full 14-day period after delivery. It must also be possible to initiate a withdrawal from the moment the order is placed — not just after delivery. You may withhold the refund until goods are returned, but the button itself must always be accessible.
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✓ Compliant- The cancellation link is active in the order confirmation email immediately after purchase
- The withdrawal flow remains accessible in the customer account until 14 days after the delivery date
✗ Not compliant- The returns portal only activates after the order is marked as delivered
- The cancellation link expires or is removed after 7 days
- The button is disabled for orders that haven't been shipped yet
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Standardised, unambiguous labelling
The button or link must use clear, unambiguous language. Customers — including those unfamiliar with legal terms — must immediately understand that clicking it will initiate a cancellation or return. Creative naming that obscures the purpose is not acceptable.
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✓ Compliant- "Cancel order"
- "Return or cancel my order"
- "Exercise my right of withdrawal"
- "Withdraw from purchase"
✗ Not compliant- "Having second thoughts?" (vague)
- "Get help with your order" (too general)
- "Start a conversation" (does not imply cancellation)
- Using only an icon with no text label
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Free for the customer
Using the withdrawal button must cost the customer nothing. You cannot charge a fee for initiating a cancellation request, require payment to access the flow, or deduct an administration fee from the refund. Return shipping costs may be passed to the customer — but only if they were clearly informed before purchase.
Show examples
✓ Compliant- The cancellation flow is free to use and no fees are deducted from the refund
- Return shipping costs are charged but were clearly disclosed before checkout
✗ Not compliant- A "processing fee" or "restocking fee" is deducted from the refund without prior disclosure
- The customer must pay to access the returns portal
- Return shipping is charged but was never mentioned in the terms or at checkout
Your store has significant gaps. Before the law takes effect, you'll need to set up a compliant digital cancellation flow. Returbo can get you there — plans from $89/month, installed as a one-off.
You're on the right track, but a few requirements still need attention. Review the unchecked items above and make sure your store is fully covered before the deadline.
Your store meets all 8 requirements. You're compliant with the EU withdrawal-button directive. Keep this checklist handy — we offer free updates for the first year should the law change.
Returbo handles all of this automatically.
Returbo is a Shopify app that gives your store a compliant withdrawal and returns flow — fully automated. Plans from $89/month, installed as a one-off by us. Free updates for the first year should the law change.
Frequently asked questions
The questions merchants most often ask about the new withdrawal button — grouped by topic.
Timing & withdrawal period
From what point does the customer's right of withdrawal apply?
For physical goods, the customer has the right to withdraw from the purchase from the moment the order is placed until 14 days after the goods have been delivered.
If an order is delivered in multiple shipments, the 14-day withdrawal period starts when the final item has been delivered.
Can the customer withdraw from the order immediately after placing it?
Yes. The customer has the right to withdraw from the purchase from the moment the order is placed. However, the statutory 14-day withdrawal period does not begin until the goods have been delivered.
In practice, this means the customer may cancel the order at any time from when the order is placed until 14 days after delivery.
Shipping & refunds
Can the merchant wait to refund until the goods are returned?
Yes. The merchant may withhold the refund until either the goods have been returned, or the customer has provided proof that the goods have been shipped back — whichever happens first.
Once either condition has been met, the refund must be issued within 14 days.
Does the merchant have to refund the original shipping cost?
Yes. The merchant must refund the standard delivery cost paid by the customer. If the customer selected a more expensive shipping option, the merchant only needs to refund the amount corresponding to standard delivery.
Can the merchant charge for return shipping when a customer withdraws?
Yes — but only if the customer was clearly informed about this before the purchase was completed. The information should be clearly stated in the terms, checkout, or return policy.
If the customer was not informed in advance, the merchant must bear the return shipping cost.
Pre-purchase information & condition of goods
What information about the right of withdrawal must be shown before purchase?
Before the customer completes the purchase, the merchant must clearly inform them about: the existence of the right of withdrawal, how it can be exercised, the duration of the withdrawal period, who bears the return shipping cost, where the digital withdrawal flow can be used, and any exceptions to the withdrawal right.
The information must be easy to find and clearly presented before checkout is completed.
Can the merchant deduct value if the item has been used or damaged?
Yes, but only to a limited extent. The customer is only liable for diminished value caused by handling beyond what is necessary to examine the product's nature, characteristics, and functionality — comparable to what would be allowed in a physical store.
The merchant may only make deductions if the customer was informed about this before the purchase.
Practical implementation
Does the withdrawal button need to be included in the order confirmation email and order status page?
What matters is that the withdrawal flow is easy to find from the places where customers naturally look. In practice, the link should be accessible from: terms and conditions, order confirmation emails, shipping and tracking emails, the order status page, customer accounts, and a permanent location on the website such as the footer.
A good rule of thumb is that the customer should be able to reach the withdrawal flow within a maximum of two clicks.
Where on the website must the withdrawal flow be available?
The directive does not specify exact placement, but the functionality must be easy to find and use. In practice, it should be available in natural customer touchpoints such as the customer account, order history, help centre, or return portal.
What information must be saved when a customer withdraws from a purchase?
The directive does not explicitly regulate storage format, but burden-of-proof requirements and GDPR mean merchants should store: order ID, customer identifier, timestamp of the request, products covered, confirmation sent to the customer, and refund status. The information should be searchable and internally accessible.
Special cases & exceptions
Do the rules apply if the customer is a business?
As a general rule, the right of withdrawal applies only to consumers (B2C) and not to pure business-to-business (B2B) transactions. However, since the rules are based on an EU directive, implementation may vary slightly between member states. In practice, pure B2B purchases are generally considered outside the scope of the withdrawal rules.
Are there exceptions for custom-made or personalized products?
Yes. Products made specifically for the customer or customized according to the customer's instructions may be exempt. Examples include engraved products, made-to-measure clothing, custom-printed items, and other goods personalized specifically for the customer.
Standard products are generally still covered by the right of withdrawal, even if the customer selected a colour or size.
Are there exceptions for sealed hygiene or beauty products?
Yes. Sealed products unsuitable for return for health or hygiene reasons may be exempt if the seal has been broken after delivery. Examples include cosmetics, underwear, earrings, contact lenses, and certain supplements.
If the product is still sealed and unopened, the standard right of withdrawal generally still applies.
The answers above are practical guidance based on EU directive 2011/83 and are not legal advice.