EU 2023/2673 module
The 6 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."If your store doesn't comply, you risk fines, complaints, and chargebacks. Run through the checklist below in 5 minutes.
5 min read
Reviewed with a EU consumer-law advisor
6 checkpoints
Shopify-native
Shopify EU withdrawal button + Flow automation
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This service is built for stores that want a professional setup for EU right of withdrawal, not just a basic contact form that creates confusion.
What’s included
- Withdrawal button implementation (clear labels, aligned with your theme)
- Placement across key locations, depending on your setup, such as
- customer account (order history)
- order status page
- order emails (order confirmation, shipping, etc.)
- website footer or support links
- A cancellation form where customers submit the required details (name, email, order number)
- Shopify Flow automation, including tagging and routing logic
- Customer confirmation messaging so it is clear the request was received
- Logic for different scenarios
- order not fulfilled yet, can be cancelled automatically
- order already in progress or fulfilled, routes into a return/manual handling process
How the Shopify Flow automation works
Depending on your store’s fulfilment process, the workflow can:
- add an “EU cancellation” tag to the order
- trigger internal notifications (email/Slack) and task assignment
- automatically cancel eligible orders
- send the correct confirmation email to the customer
- keep a clean record for reporting and operational clarity
Benefits
- Customers find cancellation within 2 clicks, reducing complaints and support tickets
- Consistent handling, fewer mistakes
- Less manual work, thanks to automation
- Professional post purchase experience
- Better operational proof and traceability (tags, emails, workflow logs)
FAQ
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.
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 applies. However, the customer bears the burden of proof that the goods were returned.
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, such as express delivery, 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.
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 the withdrawal right can be exercised
• the duration of the withdrawal period
• who bears the return shipping cost
• where and how the digital withdrawal flow can be used
• 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 the goods beyond what is necessary to examine their nature, characteristics, and functionality.
This means the customer may test the product in a way 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.
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 for information about their order and return.
In practice, the link or functionality should therefore be accessible from places such as:
• terms and conditions or pre-purchase information
• order confirmation emails
• shipping and tracking emails
• the order status page
• customer accounts or “My Pages”
• 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 the exact placement of the functionality. However, it must be easy for the consumer to find and use.
In practice, the link or functionality should be available in natural customer touchpoints, such as the customer account, order history, help center, or return portal.
What information must be saved when a customer withdraws from a purchase?
The directive does not explicitly regulate how the information must be stored. However, burden-of-proof requirements mean that merchants need documentation to handle potential disputes. GDPR requirements must also be considered.
In practice, merchants should therefore store:
• order ID
• customer identifier
• timestamp of the request
• products covered by the withdrawal
• confirmation sent to the customer
• status and refund information
The information should be searchable and internally accessible.
Can I charge my customer when they withdraw from a purchase?
No. Initiating a cancellation must cost the customer nothing. No fees, no premium support numbers, no admin charges to access the flow.
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 transactions (B2B).
Since the rules are based on an EU directive, implementation may vary slightly between member states. Certain aspects of Swedish marketing legislation may also affect some B2B situations.
In practice, however, 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 from the right of withdrawal. Examples may include:
• engraved products
• made-to-measure clothing
• custom-printed items
• other goods personalized specifically for the customer
Standard products are generally still covered by the right of withdrawal, even if the customer has selected a color or size.
Are there exceptions for sealed hygiene or beauty products?
Yes. Sealed products that are unsuitable for return for health or hygiene reasons may be exempt from the right of withdrawal if the seal has been broken after delivery. Examples may include:
• cosmetics
• underwear
• earrings
• contact lenses
• certain supplements
If the product is still sealed and unopened, the standard right of withdrawal generally still applies.
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.
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 applies. However, the customer bears the burden of proof that the goods were returned.
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, such as express delivery, 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.
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 the withdrawal right can be exercised
• the duration of the withdrawal period
• who bears the return shipping cost
• where and how the digital withdrawal flow can be used
• 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 the goods beyond what is necessary to examine their nature, characteristics, and functionality.
This means the customer may test the product in a way 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.
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 for information about their order and return.
In practice, the link or functionality should therefore be accessible from places such as:
• terms and conditions or pre-purchase information
• order confirmation emails
• shipping and tracking emails
• the order status page
• customer accounts or “My Pages”
• 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 the exact placement of the functionality. However, it must be easy for the consumer to find and use.
In practice, the link or functionality should be available in natural customer touchpoints, such as the customer account, order history, help center, or return portal.
What information must be saved when a customer withdraws from a purchase?
The directive does not explicitly regulate how the information must be stored. However, burden-of-proof requirements mean that merchants need documentation to handle potential disputes. GDPR requirements must also be considered.
In practice, merchants should therefore store:
• order ID
• customer identifier
• timestamp of the request
• products covered by the withdrawal
• confirmation sent to the customer
• status and refund information
The information should be searchable and internally accessible.
Can I charge my customer when they withdraw from a purchase?
No. Initiating a cancellation must cost the customer nothing. No fees, no premium support numbers, no admin charges to access the flow.
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 transactions (B2B).
Since the rules are based on an EU directive, implementation may vary slightly between member states. Certain aspects of Swedish marketing legislation may also affect some B2B situations.
In practice, however, 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 from the right of withdrawal. Examples may include:
• engraved products
• made-to-measure clothing
• custom-printed items
• other goods personalized specifically for the customer
Standard products are generally still covered by the right of withdrawal, even if the customer has selected a color or size.
Are there exceptions for sealed hygiene or beauty products?
Yes. Sealed products that are unsuitable for return for health or hygiene reasons may be exempt from the right of withdrawal if the seal has been broken after delivery. Examples may include:
• cosmetics
• underwear
• earrings
• contact lenses
• certain supplements
If the product is still sealed and unopened, the standard right of withdrawal generally still applies.
