EU Right Of Withdrawal

Introduction

Consumers in the European Union have certain cancellation rights when they purchase products or services online. If you sell to customers in the EU, these rules may apply to your business even if your business is established outside the EU.

This guide provides an overview of the EU right of withdrawal, including the rules for digital products and the online withdrawal functionality introduced in 2026.

Important: This article is provided for general information only and shouldn't be considered legal advice. Consumer protection requirements can vary depending on the circumstances and the EU country involved. Consider obtaining professional legal advice if you're unsure about your obligations.

What is the right of withdrawal?

For many online purchases, EU consumers have a period during which they can change their mind and cancel the contract without having to provide a reason.

This is commonly referred to as the 14-day cooling-off period.

For physical goods, the withdrawal period will generally run from the date the customer receives the goods. Different rules can apply to services and other types of contracts.

When the right applies, sellers should provide customers with clear information about how and when they can exercise it.

Online withdrawal requirements from June 2026

New requirements applying from June 19, 2026 make it easier for consumers to exercise their right of withdrawal for contracts entered into through a website or other online interface.

Where a customer has a right to withdraw from an online contract, the online interface must provide an easily accessible way for them to do so electronically.

The withdrawal option should:

be clearly visible and easy for the customer to locate;
remain available throughout the applicable withdrawal period;
use clear wording indicating that it can be used to withdraw from the contract;
allow the customer to provide or confirm the information needed to identify themselves and the relevant order or contract; and
allow the customer to specify where the withdrawal confirmation should be sent.

The process must also include a separate confirmation step so that a withdrawal isn't submitted accidentally.

After the customer confirms their withdrawal, they should receive an acknowledgement without undue delay on a durable medium, such as email. The acknowledgement should include the details of the withdrawal together with the date and time it was submitted.

These requirements were introduced by Directive (EU) 2023/2673 and apply from June 19, 2026.

Digital products

Digital products have some particularly important rules.

Examples of digital content can include:

ebooks;
downloadable files;
music and audio;
videos;
software;
digital artwork; and
other content supplied electronically.

A customer can generally lose their right of withdrawal once the supply of digital content begins, but this doesn't happen automatically simply because the product is digital.

For paid digital content supplied without a physical medium, the customer must generally have:

expressly agreed to the digital content being supplied during the withdrawal period; and
acknowledged that beginning the supply means losing their right of withdrawal.

The seller must also provide the required confirmation of that consent and acknowledgement.

For example, if a customer buys a downloadable ebook and properly agrees to immediate delivery while acknowledging that they will lose their withdrawal right, the right can be lost once the download begins.

Because of these requirements, sellers of instantly delivered digital products should pay particular attention to how consent is collected during checkout.

Other purchases that may be excluded

The cooling-off right doesn't apply to every type of purchase. Depending on the circumstances, exemptions can include:

Personalised or made-to-order products — such as an item manufactured specifically for an individual customer.
Perishable goods — including products that can deteriorate or expire quickly.
Certain sealed products after opening — including sealed software, audio or video products after the seal has been broken, as well as some hygiene-sensitive products.
Digital content after supply has begun — where all of the required consent and acknowledgement conditions have been met.
Services that have been fully performed — where the necessary consent and acknowledgement requirements have been satisfied.
Urgent repair or maintenance work specifically requested by the consumer.
Certain products whose price depends on financial-market movements outside the seller's control.
Bookings for particular dates or periods, which can include accommodation, passenger transport, car hire, catering and some leisure activities.

This isn't an exhaustive list. Whether an exemption applies can depend on the exact nature of the product, service and transaction.

What sellers should consider

If you sell online to EU customers, review your store and checkout process to determine whether the withdrawal rules apply to your products.

In particular, consider whether you:

clearly explain customers' cancellation and withdrawal rights before purchase;
provide the legally required information about the withdrawal period;
have an appropriate process for customers to submit withdrawal requests;
provide the required online withdrawal function where applicable;
send confirmation when an online withdrawal request is submitted; and
obtain appropriate consent and acknowledgement before immediately supplying digital content where you intend to rely on the digital-content exemption.

Your refund, cancellation and terms-of-service policies should also be consistent with any statutory rights that apply to your customers.

How to comply with this law

Based on our understanding, the following approach should provide a suitable way for customers to submit withdrawal requests:

Create a Google Form that collects the information required to identify the customer and process their refund
Add the Google Form link to your store, for example in the footer links or another clearly visible and appropriate location.

This would give customers a straightforward way to exercise their right of withdrawal.

In future we will make this process even easier by introducing a built-in withdrawal system, removing the need to rely on third-party form providers. For the time being, however, using a Google Form in this way should provide a practical solution.

If you also need to require customers to provide consent before completing checkout, you can use our custom checkout questions feature. This allows you to add a required checkbox that customers must select before completing their purchase.

The customer's response is also recorded on their order, providing you with a record of their consent for compliance purposes.