EU right of withdrawal

A withdrawal function,
not a returns portal.

Since 19 June 2026, article 11a of the Consumer Rights Directive requires an electronic withdrawal function on the interface where the sale was made. A returns portal does not satisfy it, and that is the mistake the market is making. Returner ships the function itself: labelled as withdrawal, reachable without a login, open for the whole period, and evidenced.

Article 11a

What the function has to do, and who does it.

The statute asks for five things: a control labelled as withdrawal, placed where the purchase was made, continuously available for the whole withdrawal period, a confirmation step before anything is sent, and a receipt to the consumer on a durable medium recording the declaration with its date and time. Some of that is software and some of it is your storefront and your policy. Here is the split, in full, because a vendor who hides it is selling you an exposure.

What Returner ships

  • A dedicated control labelled as withdrawal, in the customer's language, using the statutory wording where a national act prescribes one
  • A second confirmation step, so nothing is sent on one click
  • No account and no login: an order number and an email, or the link in the order email
  • Open for the whole period, including before dispatch when there is nothing to return yet
  • 14 days that no setting of yours can shorten, plus article 10's extension when withdrawal information was not given: twelve months on top of the original period
  • An email receipt carrying what was withdrawn, the date and the time, and an append-only record you can export

What stays yours

  • Where the function sits in your storefront and how prominent it is. We serve the page; the interface is yours
  • The pre-contractual withdrawal information and the model form. The function does not replace that duty
  • Your return-cost policy, and disclosing it in advance if the customer is to bear it
  • Which of your products fall under a statutory exemption, tagged in your catalogue
  • Sign-off. This page describes product behaviour, not legal advice

The function is additive. It sits alongside the routes your customer already has and removes none of them: the model form, a plain email, or any other unambiguous statement still works, and you cannot refuse one because the function exists. The portal says so on the page and puts the model withdrawal form there too, rather than leaving it in an email. Finland's consumer authority KKV states this explicitly, and it is the second most common misreading after the portal one.

The clock starts at delivery, but the right starts at the order.

The 14 days are counted from the day AFTER the consumer receives the goods, and expire at the end of the fourteenth, so Returner anchors the clock to the carrier's outbound delivery event rather than the ship date, and falls back to ship date plus transit when no delivery event arrives. The right itself exists earlier than that. A customer who withdraws before the parcel has even shipped is the clearest case there is, so that request is accepted and the period simply has not started counting yet.

  • Window anchored to the carrier "delivered" event
  • Ship date plus transit as a fallback, floored so it can never land early
  • Open before dispatch, when there is nothing to return yet
  • 14 days that no merchant setting can shorten
  • Twelve months on top when withdrawal information was not provided
Portal / Withdrawal
Order #SE-2041
Withdrawal
Delivered14 Jun, 09:42
Window opensDay after delivery
Closes28 Jun, 23:59
Days left 9

Two tracks, structurally separated.

A statutory Withdrawal and an ordinary Return under your own policy are two different kinds on the record, not one flow with a flag on it. They follow different rules, different timelines and different refund maths, and no policy rule of yours reaches into the statutory one. Once the window has closed the portal offers the customer an ordinary return under your policy instead.

  • "Withdrawal" and "Return" are distinct kinds in the data model, not a UI label
  • Each carries its own rules, timeline and refund calculation
  • No merchant rule, final-sale flag or risk hold overrides a withdrawal
  • A restocking fee is never applied to a withdrawal
  • Once the window has closed, the portal offers an ordinary return instead
Portal / Withdraw from contract
Confirm your withdrawal
NameA. Bergström
Order#SE-2041
Preferred contactEmail
Withdraw from contract Confirm withdrawal
Step 2 of 2. You will get an email receipt of your withdrawal.

A receipt, not a ruling.

The moment a withdrawal is confirmed, the customer gets an email on a durable medium recording what they withdrew, with the date and the time. It confirms that the declaration reached you. It does not pronounce the withdrawal valid, which is a distinction German legal publishers have already faulted competing templates for collapsing. The event goes into an append-only record you can export, so the evidence exists before anyone asks for it.

  • Email receipt on a durable medium: the items, the order, the date and the time
  • Worded as receipt of the declaration, never as a ruling on its validity
  • Append-only event record: initiated, confirmed, acknowledged
  • Exportable as CSV from the withdrawals view
  • Two entry points: order number plus email, or a link from the order email
Dashboard / Audit trail
Withdrawal #SE-2041
Initiated15 Jun, 10:03
Confirmed (step 2)15 Jun, 10:05
Receipt sent15 Jun, 10:05
Refund issuedPending receipt

Shopify ships a cancellation, behind a login.

On 18 June 2026 Shopify added cancellations to self-serve returns, and its help centre says the return and cancellation rules "help meet" the electronic withdrawal function requirement. That hedge is doing real work. Read the setup guide and the gaps are specific rather than rhetorical, and the first is the one that matters: it runs on the new customer accounts, so the customer signs in. A guest buyer has exactly the same right of withdrawal as a logged-in one.

  • Shopify's path needs a customer sign-in. Ours asks for an order number and an email
  • Labelled as a return and a cancellation, not as a withdrawal
  • One withdrawal period, rather than a cancellation window plus a return window
  • A withdrawal is a declaration you receive, not a request awaiting your approval
What's covered

The statutory flow, handled.

Labelled as withdrawal

The control says withdrawal, not "request a return". Where a national act prescribes the wording, the portal renders the prescribed wording.

Two steps, then sent

A confirmation step stands between the customer and the declaration, capturing their name, the order and how to reach them.

No login wall

An order number and an email, or the link in the order email. A solution living inside an account area excludes every guest buyer.

Before dispatch too

The right exists from the contract, not from the parcel. A withdrawal with nothing yet to return is accepted rather than refused.

Refund incl. outbound shipping

A full refund including the standard outbound shipping the customer paid, back to the original payment method, with no restocking fee.

Non-blocking retention

An exchange or store-credit offer appears only once the window has closed. Nothing optional is ever placed in front of a withdrawal.

Where this comes from

Article 11a was inserted into the Consumer Rights Directive 2011/83/EU by Directive (EU) 2023/2673 and has applied since 19 June 2026. The amending directive is titled for distance financial services, which is why a few commentators read the duty narrowly, but the national transpositions settle it: Finland enacted the same function twice, once in its general goods chapter and once in its financial-services chapter, which it would not have needed to do if the duty were financial only.

Basis
Directive 2011/83/EU article 11a, via Directive (EU) 2023/2673
Applies since
19 June 2026
Scope
Distance contracts concluded through an online interface, wherever a withdrawal right exists
Enforcement
National, and the sanction differs by member state

Seven of the nine national markets this site serves have the duty in their own law today: Sweden, Denmark, Finland, Germany, the Netherlands, France and Italy. Spain missed the December 2025 deadline and has not transposed it for goods. Norway has adopted a provision but has not brought it into force, and the directive has not yet been incorporated into the EEA Agreement: EFTA lists it as under scrutiny for incorporation, and no Joint Committee decision has been published. A merchant in either country selling into the rest of the EU is caught there regardless of what its own law says yet. Each localised version of this page states its own market's position.

Return shipping, and what this page is not

Under the Consumer Rights Directive the consumer can be required to bear the cost of returning the goods where you disclosed that in advance. Returner does not promise free return shipping. Nor does installing Returner make a shop compliant: the function still has to be placed and kept visible in your own interface, and the withdrawal information you publish is yours. This page describes what the product does. It is not legal advice, and two of the markets named on it are still moving, so have your own counsel confirm your setup and your wording.

Last reviewed: 4 September 2026

Try each flow yourself.

Walk the real customer portal in demo mode, without a login. Each link opens a different scenario.

Ordinary return Withdrawal, within 14 days Withdrawal, window expired

The expired example shows what a customer sees once the statutory window has closed and only your own return policy is left.

Return portal

The branded, self-serve portal customers use to start a withdrawal or return.

Exchanges

The non-blocking exchange and store-credit offer that keeps the revenue.

Automation

Rules that route and act on returns once the withdrawal window closes.