Do you sell to customers in the EU? If so, you need to be aware of a new requirement that went into effect on June 19, 2026.
EU Directive (EU) 2023/2673 now requires online stores to offer a dedicated, built-in withdrawal function. What is a “withdrawal?” Think of it as the customer withdrawing from the contract they made with you when they placed their order. It’s similar to a “cooling off” period that you might encounter in some areas when you buy a car.
Put simply, it’s the customer’s right to change their mind and receive a full refund within 14 days.
Policy Changes
If you sell to the EU, you may need to change your refund policies:
- You will now be required to refund payments for any and all reasons – even if the product has already shipped, and even if you won’t receive the returned item within 14 days.
- You cannot require a customer to send photos of damaged goods, require that the product be in new condition, etc in order to receive a refund.
Implementation Steps
I am not a lawyer and cannot give legal advice. However, several clients have already asked how to implement the requirements. Therefore, what follows is a general guide to complying with the new rule based on the information BigCommerce provided.
To guarantee compliance and avoid penalties or fines, I recommend consulting a qualified legal professional to confirm your specific obligations.
- Create a contact form using a 3rd party form builder (I recommend Jotform). It should have fields for the customer’s name, email address, and order number. The form also needs to have a checkbox to confirm their submission.
- Set up an auto-responder for the form so that the customer receives a time-stamped receipt for their submission. The auto-response email should include all fields from the form.
- Configure a notification for the form so that you receive all withdrawal requests that are submitted. You only have 14 days to issue a refund from the time the form is submitted, so timely notification is important.
- Put this form on your website and make sure a link to it appears in your website’s footer.
- When a form is submitted:
- If the order has not shipped: Cancel the order and issue an immediate refund.
- If the order has shipped: Process the order as a return and refund within 14 days.
IMPORTANT: If you ship from the United States, there is a high likelihood that you will not receive the returned order before the 14-day deadline. You must process the refund within 14 days whether or not you have received the returned merchandise.
Additional Details
BigCommerce’s notification about this new rule includes three things worth mentioning:
- They recommend localizing the form labels for each country’s language. That would require setting up multiple forms, or possibly adding a translator app to the form page (or your entire website).
- Legal requirements vary by EU member state and by the nature of your products and services.
- If you do not implement a withdrawal form, EU customers automatically get 12 months + 14 days to legally exercise their withdrawal. Fines may also be levied by EU countries individually.
If you are concerned about any of the above, I suggest consulting with a lawyer.
Final Note
If all of this seems too complicated or overwhelming, the simplest solution is to stop selling to the EU.
If you would like my assistance with the setup, contact me via email (existing clients) or my contact form (new clients). As a Jotform partner, I’m able to offer you discounted pricing on their form plans for the first year.
Disclaimer: I am not an attorney, and this service does not constitute legal advice. Implementation of this feature does not guarantee compliance with EU Directive (EU) 2023/2673 or any other applicable law. You remain solely responsible for ensuring your store meets all legal requirements, and for any liability, fines, or penalties resulting from noncompliance.
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