Selling to EU Customers? You Need an Online Withdrawal Function

If you sell to consumers in the EU, there's a new rule on the books that's easy to miss and costly to ignore. It doesn't change what EU shoppers can return — they've had a 14-day right to change their mind for years. What it changes is how they have to be able to exercise that right, and as of June 19, 2026, “email us” or “see our returns policy page” no longer cuts it.

Here's what's actually different, who it affects, and what a compliant setup looks like.*

The short version

EU Directive (EU) 2023/2673 now requires online stores to offer a dedicated, built-in withdrawal function — not just a policy page or a support inbox. Think of it as the difference between telling customers about their rights and giving them a button to use them.

A policy page, a PDF, or a “contact support” instruction is no longer enough on its own. The law wants a structured, two-step online process that confirms itself automatically.

Who needs to care about this

This isn't about where your business is registered, it's about where your customers are. If you sell physical products, digital products, services, subscriptions, or bookings to ordinary consumers located in the EU, this applies to you, regardless of your store's home country.

B2B sales are excluded, and a handful of product categories (like fresh food, or digital content a consumer chose to start using right away) have exemptions. It’s important to note that these carve-outs aren't limited to those examples and the details vary by member state. If your store serves both businesses and consumers, only the consumer side is in scope. When in doubt about your specific catalogue, a legal professional who knows your markets is the right call here, not a blog post.

What a compliant withdrawal function actually looks like

There are five pieces, and the directive treats them as a set. Missing one is what creates exposure.

1. A clearly labelled entry point. This means you must feature a visible link or button, something unambiguous like “Withdraw from contract here,” that's available everywhere, all the time. Most stores put it in the footer so it's never more than a click away.

2. No login wall. If you offer guest checkout, the withdrawal flow can't require an account. A short form that identifies the order by reference number is the standard pattern.

3. A form that captures the basics. Name, order reference, contact email — nothing exotic. You likely don't need to build this from scratch.

4. A two-step confirmation. The consumer fills in the form, then takes a second, deliberate action to confirm. This guards against accidental submissions and is part of the legal requirement itself, not just good UX.

5. An automatic confirmation email. Once submitted, the consumer needs an acknowledgment that records what they submitted and exactly when. A generic “thanks, we got your message” doesn't satisfy this — a timestamp is critical because it serves as proof the withdrawal was exercised on time.

You probably already have most of this

If you're running a modern store, the building blocks are likely already in your stack: order management, refund handling, order notes, maybe even a contact-form tool that could become the basis of the form. For most merchants, this is less “build something new” and more “assemble what you have into one guest-accessible flow and bolt on the confirmation email.” The guest-access piece is usually where stores need to look hardest.

Don't confuse withdrawal with returns

This is the mistake the directive seems most aimed at preventing: making withdrawal conditional on a reason, photos, approval, or a fee. A withdrawal is simply the consumer's legal notice that they're unwinding the purchase — full stop. Capture and acknowledge it as its own event first, then route it downstream based on the order's status: if nothing's shipped, it resolves as a cancellation; if it's already been delivered, it becomes a return and refund.

Either way, the clock starts the moment the consumer submits the notice, and the refund is due within 14 days of that notification.

Why this is worth getting right

Here's the part that should get your attention: the most likely consequence of getting this wrong isn't a fine. If the required withdrawal information or function is missing, the consumer's 14-day cooling-off period can automatically extend to 12 months and 14 days — no regulator complaint or enforcement action required to trigger it. A short return window can quietly become a year-long one for affected orders.

Fines exist on top of that, set independently by each EU member state, ranging from administrative penalties in the tens of thousands of euros up to a percentage of annual turnover for serious cross-border cases. The specifics depend on which national markets you're selling into.

A practical checklist

• Add a “Withdraw from contract here” link, visible on every page — footer is the common placement

• Make sure it works without requiring login, for guest consumers

• Use a form that captures name, order reference, and contact email

• Add a second confirmation step before the form submits

• Send an automatic confirmation email with the submitted details and a timestamp

• Treat the request as its own event, then route to cancellation or refund based on order status

• Localise the label for each market: Germany uses “Vertrag widerrufen,” France uses “renoncer au contrat ici,” Italy uses “recedi dal contratto qui”

Where BigCommerce fits in right now

The company doesn't offer a native withdrawal function yet, so this is something to set up at the store level for now. The good news is that the checklist above leans heavily on tools most merchants already have. Depending on your setup, you may be able to cover the requirement with what's already in your toolkit, or fill specific gaps with a third-party option. 

We're actively exploring ways to make this more seamless for merchants and will share updates as that work progresses. In the meantime, since the deadline has already passed, putting an interim solution in place now is the most practical next step if this applies to your store.

* The information provided is for general informational purposes only and relates to EU Directive 2023/2673 and the right of withdrawal requirement for online stores selling to EU consumers. It is not legal advice and should not be relied upon as such. You remain responsible for understanding and complying with the laws applicable to your business and your customers' location. 

Legal requirements vary by EU member state and by the nature of your products and services. If you have questions about your specific obligations, we recommend consulting a qualified legal professional.