Since 19 June 2026 a trader that concludes distance contracts with consumers through a website or an app has to provide a withdrawal function for every contract that carries a right of withdrawal. It has to be labelled “withdraw from contract here” or an unambiguous corresponding formulation, it has to be continuously available throughout the withdrawal period, and it has to end in a separate step labelled only “confirm withdrawal”, followed by an acknowledgement of receipt on a durable medium.
The rule comes from Article 11a of the Consumer Rights Directive, inserted by Directive (EU) 2023/2673. Germany implemented it in section 356a of the German Civil Code. It does not create a new right of withdrawal and it does not replace your withdrawal policy or the model withdrawal form. It is a second, faster route that now has to exist alongside them.
Where the withdrawal button comes from
Directive (EU) 2023/2673 is titled as a directive on financial services contracts concluded at a distance, which is why many retailers filed it under “not my problem”. The withdrawal function is the part that reaches everyone. Recital 37 states that the obligation should apply “not only to distance contracts for financial services, but to all distance contracts that are subject to the right of withdrawal” under Directive 2011/83/EU.
Member States had to adopt the implementing measures by 19 December 2025 and apply them from 19 June 2026. This is national law now, in each member state’s own wording and language. If you sell into several EU markets, check the label required in each of them rather than translating the English phrase yourself.
What Article 11a requires
The article is short and every sentence of it turns into an implementation detail.
Label and placement
The function has to carry the words “withdraw from contract here” or an unambiguous corresponding formulation, in an easily legible way. It has to be continuously available throughout the withdrawal period, prominently displayed on the online interface and easily accessible to the consumer. Recital 37 adds the intent behind it. The consumer should not have to go through procedures to find the function, such as downloading an app when the contract was not concluded in that app, and hyperlinks leading to the function are an acceptable way to make it reachable.
What the statement has to collect
The withdrawal statement has to let the consumer easily provide or confirm three things: their name, details identifying the contract they want to withdraw from, and details of the electronic means by which the confirmation will be sent to them. A customer who has already identified themselves, for example by logging in, should not have to enter that information again. Where an order covered several goods or services, you may let the consumer withdraw from part of the contract instead of all of it.
The confirmation step
Once the statement is complete, submission runs through a separate confirmation function. It has to be labelled in an easily legible manner and only with the words “confirm withdrawal” or an unambiguous corresponding formulation. The word “only” is in the legal text, so this button carries no second message and no competing call to action. The two step flow exists so that the right is not exercised by accident.
The acknowledgement of receipt
Once the consumer activates the confirmation function, you have to send an acknowledgement of receipt on a durable medium without undue delay, containing the content of the withdrawal and the date and time of its submission. An email is the usual durable medium here. A confirmation shown only on screen is not one.
When the withdrawal counts as being in time
The consumer is considered to have exercised the right within the withdrawal period if the online statement was submitted before that period expired. That moves the evidential question onto your side. You need the submission timestamp in your own records, not only in the customer’s mailbox.
How Germany implemented it
Germany transposed the directive with the act of 3 February 2026 amending consumer contract law, insurance contract law and treatment contract law, published in the Federal Law Gazette on 5 February 2026 (BGBl. 2026 I no. 28). Article 10 of that act brought the relevant provisions into force on 19 June 2026.
The rule now sits in section 356a of the German Civil Code and follows Article 11a closely, with two German labels: the function has to read “Vertrag widerrufen” and the confirmation step “Widerruf bestätigen”, or in each case an equally unambiguous formulation. Section 356a(2) explicitly allows identification of the contract “or the part of the contract” the consumer wants to withdraw from. One wording detail differs from the directive: Article 11a has the acknowledgement state the date and time of submission, section 356a(4) the date and time of receipt. For a form running on your own site that is the same moment, so a single timestamp covers both.
Two consequences are easy to miss:
- The pre-contractual information changed. Article 246a of the Introductory Act to the Civil Code now requires information on the existence and the placement of the withdrawal function. Section 356(3) of the Civil Code ties the start of the withdrawal period to that information being given correctly, and section 356(4) caps the right at twelve months and fourteen days. An outdated withdrawal policy can therefore stretch the period a customer has to send goods back.
- There is an administrative fine attached. Article 246e of the Introductory Act now lists a missing or non compliant withdrawal function, and a missing acknowledgement of receipt, as an administrative offence. The ceiling is fifty thousand euro, and for traders with an annual turnover above 1.25 million euro up to 4 percent of annual turnover. That fine can only be imposed within a coordinated enforcement action under the CPC Regulation, with the Federal Office of Justice as the competent authority, so in day to day German practice the faster consequence is a warning letter from a competitor or a consumer association.
How to build it in a Shopify store
The mechanics are not hard, the details are. A setup that holds up looks like this:
- A dedicated withdrawal page carrying the exact label, reachable without a login, linked from the footer, the customer account, the order status page and the order confirmation email.
- A form that prefills order number and email address for logged in customers and asks for them when the visitor is not logged in.
- Line level selection when you want to allow partial withdrawal, otherwise a clear statement that the whole order is being withdrawn.
- A confirmation screen whose button carries only the confirmation wording.
- An automated acknowledgement email that repeats the submitted content and states the date and time of submission.
- A record on your side: the statement, the timestamp and the acknowledgement, stored where support can find them.
- An updated withdrawal policy that names where the function sits, in every language and market you sell to.
Treat the label as market specific content rather than as a translation string that someone improvises during a release. We build and retrofit this flow as part of our Shopify development services, and the build usually takes less time than the legal review around it.
Mistakes we keep seeing
- A returns portal presented as the withdrawal function. Returns and withdrawal are different things, and a returns flow that asks for a reason, a photo or an approval step does not satisfy Article 11a.
- A button that opens an email link. That is not a function that collects a statement and triggers an acknowledgement.
- A single step flow. The separate confirmation function is required.
- Wording invented in house. “Cancel order” is not an unambiguous corresponding formulation.
- The function placed behind a customer login. Guest checkout customers hold the same right.
- No acknowledgement email, or an acknowledgement without the date and time of submission.
- The withdrawal policy left untouched, which is the part that can extend the withdrawal period.
One point is genuinely unsettled. The German implementing act contains no transitional provision, so it is not spelled out how the function applies to contracts concluded shortly before 19 June 2026 whose withdrawal period was still running afterwards. The cautious reading, and the one we recommend, is to keep the function available for every withdrawal period that is still open. There is no case law on this yet.
If you are working through EU consumer law for your shop anyway, the withdrawal function pairs with the pricing rules that already apply. Our guides on the Omnibus Directive and on the pricing indication rules cover the other half of the picture.
Key takeaways
- The withdrawal function has been mandatory since 19 June 2026 for distance contracts concluded through an online interface.
- It applies to all distance contracts with a right of withdrawal, not only to financial services.
- The labels are prescribed: “withdraw from contract here” for the function and only “confirm withdrawal” for the confirmation step.
- An acknowledgement of receipt on a durable medium, with content plus date and time, is part of the obligation.
- In Germany the rule is section 356a of the Civil Code, with fines up to fifty thousand euro or 4 percent of annual turnover, and a withdrawal period that can stretch to twelve months and fourteen days if the information duty is missed.
Read next: staying compliant with the Omnibus Directive, the EU pricing indication rules, or our reference projects.
Sources
- Directive (EU) 2023/2673, Article 1 point 3 (new Article 11a of Directive 2011/83/EU), recital 37 and Article 2 on transposition, EUR-Lex (checked 22 August 2026).
- Section 356a of the German Civil Code, gesetze-im-internet.de (checked 22 August 2026).
- Gesetz zur Änderung des Verbrauchervertrags- und des Versicherungsvertragsrechts sowie zur Änderung des Behandlungsvertragsrechts of 3 February 2026, BGBl. 2026 I no. 28 of 5 February 2026, including the changes to Article 246a and Article 246e of the Introductory Act and the entry into force in Article 10, recht.bund.de (checked 22 August 2026).
- Sections 356(3) and 356(4) of the German Civil Code on the start and the outer limit of the withdrawal period, gesetze-im-internet.de (checked 22 August 2026).
This article reflects the legal position on 22 August 2026 and is general information about how the rules affect an online shop. It is not legal advice on your individual case.
Get the withdrawal function built into your Shopify store
Lars Henning
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