EU Right of Withdrawal: Returns and Guarantees in Online Stores

Most online shoppers in the EU believe three things about returns that aren't quite accurate: that they need a reason to send something back, that they must use "the shop's return form," and that the shop can pay them back however and whenever it likes. None of that is right. What the law actually gives a consumer is more specific, and in one place more generous to shops than most owners realise — a trader can hold onto the refund until the goods are physically back on the shelf.

This article sets out the EU right of withdrawal the way Directive 2011/83/EU and its later amendments define it: how many days a customer has and from when, what the model withdrawal form actually says (in full, ready to copy), when a shop must pay money back, what it doesn't have to accept, and the new EU-wide requirement for an explicit "withdraw from contract" button that starts applying in 2026. We close with what a return actually costs a shop to process — not a number nobody has measured, but the list of steps that make up that cost.

The legal basis is Directive 2011/83/EU on consumer rights, consolidated to 28 May 2022 (CELEX 02011L0083-20220528), together with Directive (EU) 2019/771 on the sale of goods and the withdrawal-button amendment, Directive (EU) 2023/2673. EU directives are implemented into each member state's own law, so exact article numbers and some procedural detail can differ slightly from one country to the next — the deadlines and the overall structure described here are harmonised across the EU. This is a summary of the law, not legal advice; have your own terms and conditions checked by a lawyer in the country where you trade.

Withdrawal and the legal guarantee are two different things

Before the deadlines, it's worth separating two concepts that customer service teams often blur together:

The 14-day withdrawal period — when it actually starts

The right itself comes from Article 9(1) of Directive 2011/83: a consumer who has entered into a distance or off-premises contract has 14 days to withdraw from it without giving any reason and without any cost beyond what the directive allows.

The clock doesn't start on the order date or the dispatch date. Under Article 9(2)(a), for sales contracts it runs from the day the consumer, or a third party other than the carrier that the consumer has designated, takes physical possession of the goods. For deliveries made in several separate lots, it runs from the last one.

To meet the deadline, the consumer only has to send the withdrawal notice before it expires — not have it arrive at the shop. A notice posted on day 14 and received on day 16 is still in time.

Two things shops get wrong often enough to be worth naming:

• A longer return window — 30, 60, 100 days — is a business decision, not a legal requirement. The directive sets a floor of 14 days; a shop can offer more, never less.
• Not telling the customer about the right of withdrawal extends it by 12 months. Under Article 10, if the trader has failed to provide the required information about the right of withdrawal, the withdrawal period expires 12 months after the original 14-day period would have ended. A clear statement of the right to withdraw, given before the contract and repeated in the terms, isn't paperwork — it's what keeps a shop from facing withdrawal claims more than a year after delivery.

The model withdrawal form — and whether you need one

Using a form isn't mandatory. Directive 2011/83 lets the consumer withdraw by "any unequivocal statement" — a model form in Annex I(B) is offered as an option, not a requirement. A shop that refuses a withdrawal because the customer emailed "I don't want order #1234 any more" instead of filling in "the shop's form" is on the wrong side of this.

The current text of Annex I(B)

Below is the official English text of the model withdrawal form, after the fax line was dropped by the 2019/2161 "Omnibus" amendment. You can paste it into your terms and conditions, hand it out with the parcel, or offer it as a download — just fill in the trader's details in the first field.

> MODEL WITHDRAWAL FORM

>

> (complete and return this form only if you wish to withdraw from the contract)

>

> — To [here the trader's name, geographical address and, where available, his fax number and e-mail address are to be inserted by the trader]:

>

> — I/We(\) hereby give notice that I/We(\) withdraw from my/our(\) contract of sale of the following goods(\)/for the provision of the following service(\*),

>

> — Ordered on(\)/received on(\),

>

> — Name of consumer(s),

>

> — Address of consumer(s),

>

> — Signature of consumer(s) (only if this form is notified on paper),

>

> — Date

>

> (\*) Delete as appropriate.

A shop's own form — collecting an order number, a refund account, a note on the product — is a convenience, not a condition. A customer can still use the model form, write their own, or simply say so by email.

The refund: 14 days from the notice, not from the parcel

This is where most confusion sits, because two deadlines run in parallel, counted from two different events.

Article 13(1): the trader refunds all payments received from the consumer, without undue delay and in any event not later than 14 days from the day on which it is informed of the consumer's decision to withdraw.

Article 14(1): the consumer sends the goods back without undue delay and in any event not later than 14 days from the day on which they communicated the withdrawal; sending the goods before that deadline is enough.

So a customer can send the withdrawal notice and only post the parcel back more than a week later. If a shop had to refund within 14 days of the notice regardless, it could end up paying before it has even seen the goods. That's why Article 13 also lets the trader withhold the refund until the goods are back, or until the consumer has supplied evidence of having sent them back, whichever is the earlier — a right plenty of shops either don't use, or use loosely.

What exactly comes back

The refund covers the price and the cost of standard delivery — but only up to the cheapest standard delivery option a shop offers. If the customer chose a faster, pricier option, the trader is not required to refund the difference. Article 13(2) requires the trader to use the same means of payment the customer originally used, unless the customer has expressly agreed to a different one.

Who pays to send the goods back

Under Article 14, the consumer bears only the direct cost of returning the goods, unless the trader has agreed to bear it, or failed to inform the consumer that they would have to. Free returns aren't a legal requirement — but if a shop's terms are silent on who pays for the return shipment, the shop does.

Article 14 also covers the case of a customer who used the goods beyond what was necessary to establish their nature, characteristics and how they work: a trader can be entitled to a deduction for that diminished value. It doesn't let a shop refuse the return outright — only claim a reduction.

What a shop doesn't have to take back

Article 16 of Directive 2011/83 lists contracts where the right of withdrawal doesn't apply at all. Among the examples it gives: goods made to the consumer's specifications or clearly personalised, goods liable to deteriorate or expire rapidly, and — the one that trips up cosmetics and personal-care shops most often — goods that are sealed for health protection or hygiene reasons and were unsealed by the consumer after delivery.

The European Commission's own guidance on the directive (2021/C 525/01) gives concrete examples: "cosmetic products, for example lipsticks; toothbrushes, razors and other personal hygiene items," noting that the exception applies only where the goods have become, after unsealing, "definitively unsuitable for resale for health protection or hygiene reasons."

The Court of Justice drew the line in a case that answers the "what about clothing or mattresses?" question directly. In C-681/17 (slewo), judgment of 27 March 2019, the Court held that the hygiene exception doesn't cover a mattress whose protective film the consumer removed after delivery — the mattress "may be equated with a piece of clothing," which can be tried on in a shop and still be returned even after contact with the body. A trader can restore such goods to a resaleable condition "by cleaning or disinfecting it," and the Commission's guidance echoes this: a consumer's liability for diminished value "may arise if cleaning or disinfection of the mattress (or clothing and comparable goods) is required for health protection or hygiene reasons." In other words: a "no returns on underwear" clause doesn't survive this case law on its own — the exception applies to goods that were genuinely sealed for hygiene reasons and opened after delivery, not to a product category.

The legal guarantee: two years, EU-wide

Alongside withdrawal, Directive (EU) 2019/771 gives consumers a right to goods that conform to the contract, independent of whether they've changed their mind.

Article 10(1): the seller is liable for any lack of conformity that exists at the time of delivery and becomes apparent within two years of that date.

Article 11(1): for one year from delivery, a lack of conformity that becomes apparent is presumed to have existed at delivery already — the seller has to prove otherwise, not the consumer.

Article 11(2) lets member states extend that reversed-burden-of-proof period to the full two years, and Article 10(3) lets them keep or introduce an even longer liability period. This is one of the places where "EU-wide" still means "check the local transposition" — the two-year liability floor is the same everywhere, but how long the burden of proof favours the consumer can differ by country, which matters if you're selling into more than one.

The withdrawal button: an EU-wide requirement from 2026

Directive (EU) 2023/2673 adds a new obligation to the consumer-rights directive: an explicit "withdrawal function" in the shop's own interface, not buried in an email thread.

Under the new Article 11a, that function has to be "prominently displayed," "continuously available" throughout the withdrawal period, and labelled with the words "withdraw from contract here" or an unambiguous equivalent. It's followed by a separate "confirm withdrawal" step, and the trader has to send an acknowledgement of receipt on a durable medium without undue delay.

Member states had until 19 December 2025 to transpose the directive, and the rules themselves apply from 19 June 2026. That date has now passed, but whether a given country's implementing law is actually in force, and how it reads in detail, varies — we found no EU-wide tracker confirming the rollout country by country. If you're redesigning a customer account area or a returns flow, this is worth building room for now rather than retrofitting later.

How many orders actually come back

There's no single EU-wide statistic for the share of orders that get returned — Eurostat doesn't measure it, and neither does any EU body we found. What does exist measures something adjacent.

Eurostat, 2025 survey (isoc_ec_iprb21, EU27, share of individuals aged 16–74 who bought online in the previous 3 months and reported a problem): 35.43% had at least one problem with an online purchase. The most common was slower delivery than promised (19.92%), followed by a site that was hard to use (11.49%) and goods that arrived wrong or damaged (10.36%). Further down the list: trouble finding information about guarantees and rights (8.19%), a complaint that was hard to resolve or got no satisfactory answer (6.33%), a foreign retailer that wouldn't sell to the buyer's country (5.36%), a final cost higher than shown (4.5%), and fraud (3.85%). These are declared problems, not a returns rate.

NRF and Happy Returns, "2025 Retail Returns Landscape" (report, press release): retailers expect 15.8% of 2025 annual sales to come back, and 19.3% in the online channel; they classify 9% of returns as abuse. Three caveats apply every time this figure gets quoted: it's the US retail market, it's a retailer estimate, not a measurement, and the survey covers 358 large companies with over $500 million in revenue. Don't read the 19.3% against the EU problem-rate figures above — one is a share of sales value, the other a share of people reporting an issue.

The only number genuinely worth building a decision on is your own: returned units divided by sold units, in the same period, broken out by product category. That's what tells you whether the issue sits in a product description, a size chart, or the product itself.

What a return actually costs — the components, not an invented average

There's no reliable published EU-wide average cost per return, and figures that circulate online for this rarely carry a source — so instead of a number, here's the list of what to price into your own.

1. Refunding the original delivery cost. You give back the price of the cheapest standard delivery you offer (Art. 13), even though you may have paid your carrier more to ship it.
2. A return label, if you cover the cost of sending the goods back. Carrier and broker rates vary by country and by volume — see your own carrier's current terms rather than a figure quoted here.
3. Refund fees on the original payment. Whether your payment provider returns, or keeps, the fee it charged on the original transaction when you issue a refund is set out in its own pricing terms — check this in your contract rather than assuming either way. Current EU payment-gateway rates are compared in our payment gateway fees article.
4. Receiving and unpacking — matching the parcel to the right order and withdrawal notice.
5. Checking condition — complete, not used beyond what's needed to inspect it, fit for resale. Photos and notes help if you intend to claim a deduction for diminished value (Art. 14).
6. Returning it to resaleable condition — cleaning, repackaging, relabelling; sometimes outlet pricing or write-off instead.
7. Putting it back into stock — updating inventory on your site and on any marketplace, so it's available to sell again.
8. Processing the refund and the books — issuing the payment, correcting the sale, reconciling against the statement.
9. Customer service — status questions, the acknowledgement on a durable medium (where the withdrawal was notified electronically), and handling any dispute.

The cost of returns is one line in a shop's monthly running cost alongside payments and shipping — our e-commerce TCO calculator lets you add your own figures for each of these.

Returns in practice: policy, labels and parcel lockers

What a returns policy should say

Most of this follows directly from the law above:

• the withdrawal period and when it starts (from taking possession of the goods);
• that the model withdrawal form is optional, with the form itself filled in with your own details;
• your return address and how to send goods back;
• who pays for the return shipment — leave this out and it defaults to you (Art. 14);
• the cost of returning goods that can't reasonably go by post;
• when and how refunds are paid, including the right to withhold until the goods or proof of return arrive (Art. 13);
• the exceptions, limited to what Article 16 actually covers;
• a separate section on the legal guarantee, with the deadline your country's implementing law sets for a response.

Put the policy where customers actually look for it: on the product page, in the basket, and in the order-confirmation email. How to design those touchpoints is covered in our UX/UI in e-commerce content area; a UX checklist for your store helps too.

Returns through parcel lockers

Automated parcel-locker networks have become one of the default ways customers send a return, and they're genuinely EU-wide rather than a single-country phenomenon: InPost Group reported 62.0K active automated parcel machines at the end of 2025, up 30% on 2024, across multiple EU countries (InPost Group, 2025 highlights). If your platform or carrier integration supports generating a return label for a locker network directly from your admin panel, it removes a manual step for both sides. Carrier and broker comparisons are in our shipping: parcel lockers and couriers article.

Returns on a SaaS platform or a marketplace

On subscription platforms, returns handling is sometimes bundled into the plan and sometimes a paid add-on — check this before you commit to a platform, and check specifically whether the built-in flow sends the durable-medium acknowledgement the law requires for electronic withdrawal notices. If you sell through a marketplace rather than, or alongside, your own store, the marketplace's own returns rules apply on top of EU law; we cover that in our marketplace integration article.

Returns from customers in other EU countries

If you actively sell into other EU member states, a customer there keeps the consumer protection of their own country's law, and your terms can't contract around it. What that means for returns, VAT and shipping is covered in our cross-border EU selling article.

Summary: what a shop must do, and what it can choose

• Must: accept a withdrawal notice in any clear form, acknowledge an electronic one on a durable medium, refund within 14 days of the notice (including the cheapest standard delivery cost), and meet whatever response deadline its country's law sets for a conformity claim.
• May: pass the return-shipment cost to the customer (if it said so upfront), withhold the refund until the goods or proof of return arrive, skip refunding the difference for a pricier delivery option the customer chose, claim a deduction for diminished value on a used return, and refuse a genuinely sealed, opened hygiene item under Article 16.
• Will need to add: a labelled, always-available "withdraw from contract here" function once its country's transposition of the 2023/2673 button mandate is in force.

The other costs a shop carries on every order — payments, shipping, packaging — are covered in our payments and logistics section, and payment methods and their risk in our online payment methods article. If you're still sizing up what running a store costs overall, see what does an online store cost.

Sources

Directive 2011/83/EU on consumer rights, consolidated text

Directive (EU) 2019/771 on the sale of goods

Directive (EU) 2023/2673 — the withdrawal-button amendment

CJEU, C-681/17, slewo, judgment of 27 March 2019

European Commission guidance on Directive 2011/83/EU (2021/C 525/01)

Eurostat — isoc_ec_iprb21, problems experienced when buying online, 2025

NRF / Happy Returns — 2025 Retail Returns Landscape

InPost Group — 2025 highlights