New rules for withdrawing from contracts are intended to simplify the process of cancelling online purchases for customers. For online stores, however, they mean the need to streamline the entire return process: from the initial notification and customer communication to receiving the goods and settling payments. The direction of these changes is set by EU Directive 2023/2673.
Although the domestic implementation of the regulations was called into question after the UC82 draft bill was withdrawn from the work of the European Affairs Committee, a Globkurier expert points out that entrepreneurs selling goods abroad should not wait for the legislative process to conclude.
The greatest risks will not arise from implementing the button itself in the interface, but from the operational handling of returns.
EU Directive 2023/2673 provides that an entrepreneur offering the conclusion of distance contracts via an online interface, such as a website or application, will have to provide the consumer with the ability to withdraw from the contract using a clearly visible and permanently available function. The Office of Competition and Consumer Protection (UOKiK) indicates that this function should be marked with the words “withdraw from contract here” or an equivalent, and the solution applies to all types of distance contracts, not just financial services. These rules are to be applied from June 19, 2026.
Legislative uncertainty should not halt preparations
A challenge for stores conducting cross-border sales is the uneven pace of implementing the regulations in individual EU countries. Domestic implementation was called into question after the UC82 draft bill was withdrawn from the work of the European Affairs Committee. It included, among other things, the implementation of Directive 2023/2673. Although the legislative process in Poland is delayed, some markets, including Italy, are already more advanced in implementing the new rules. A Polish seller conducting cross-border sales should analyze not only national regulations but also the requirements applicable in the markets to which they ship goods. This means acting in a state of incomplete regulatory clarity; however, in practice, online stores should already analyze their terms and conditions, customer communication, the method of confirming requests, and the handling of return shipments.
The direction of the changes in the regulations is clear: withdrawing from a contract should be simpler and easier for the customer to execute online. For stores, the optimal solution is to organize procedures before the new solutions come into force. The later an entrepreneur starts analyzing the return process, the greater the risk of costly errors resulting from working under time pressure.
– says Agata Kędzierska-Zawisza, Head of Marketing & E-commerce at Globkurier, a technological logistics partner supporting companies in the e-commerce sector with domestic and international shipments.
Stores are asking about situations that cannot be solved by a button alone
Globkurier’s experience shows that initially, the discussion around the new regulations focused mainly on the obligation to implement a function enabling online contract withdrawal, but today, entrepreneurs are increasingly asking about specific scenarios that may arise after the changes come into effect.
Among the most frequently discussed topics are situations where a customer notifies a withdrawal from the contract but does not send the goods back, returns a damaged product, makes a partial return of an order, or used a bundle promotion, e.g., “1+1”. Questions also concern payment refund deadlines, liability for return shipments, and digital, outlet, or discounted products. Therefore, a store should not only provide the customer with an electronic way to submit a statement of withdrawal from the contract but also clearly describe what happens after a return is reported: within what time frame the customer should send the product back, how the store verifies the shipment, and when the payment refund occurs. As the Globkurier expert points out, the mere submission of a withdrawal statement by the customer does not always mean that the seller must immediately refund the payment. If the customer does not send the product back or provide proof of its dispatch, the seller can, in principle, withhold the refund until the goods are received or proof of their dispatch is confirmed.
Conversations with entrepreneurs who are asking for advice in the context of optimizing processes related to return handling show that they want to know not only what obligations the new regulations impose, but also how to limit the risk of situations where a single return excessively engages employees, generates additional costs, or leads to a dispute with the customer. This shows that the market has moved from the stage of identifying new requirements to the phase of preparing for the implementation of specific organizational solutions that allow for reconciling consumer protection with efficient process organization on the store’s side.
– adds Agata Kędzierska-Zawisza.
The biggest challenges begin after the withdrawal notification, and mistakes can be costly
The new regulations are intended to increase transparency and make it easier for consumers to exercise their right of withdrawal. From the perspective of stores, however, they mean the need to organize the entire return handling path. Simply implementing a function in the store’s interface will not solve problems related to confirming the request, shipment status, assessing the product’s condition, partial order returns, or payment settlement.
Orders covered by bundle promotions, digital products, discounted goods, outlet items, and international shipments require additional analysis. In each of these cases, the store should determine in advance what communication with the customer will look like, who is responsible for individual stages of handling, and when the transaction settlement occurs. A well-prepared process can also provide stores with business-useful information. Analyzing the reasons for withdrawal allows for identifying problems with product descriptions, photos, sizing, packaging quality, or delivery time.
Returns are a source of rich knowledge about the customer’s shopping experience, which is why they should not be treated solely as a regulatory obligation. But this aspect, of course, cannot be ignored, as procedural errors can prove to be extremely costly.
– emphasizes the Globkurier expert.
Preparations for the new rules should cover not only the appearance of the online store but also terms and conditions, instructions on the right of withdrawal, email templates, customer service procedures, and rules for cooperation with logistics operators. In conditions of growing competition, the way returns are handled increasingly influences the assessment of the entire shopping process. A simple and predictable procedure reduces the fear of purchasing and increases the chance that the customer will return to the same seller.
This stage of shopping is crucial for building the store’s credibility. Therefore, the implementation of the return rules included in the directive should cover communication, logistics, and after-sales service. Easily finding key information, quick confirmation of the request, and transparency of financial settlement are important because the less uncertainty there is on the customer’s side, the lower the risk of complaints or consumer disputes, and this, of course, is associated with additional operational costs and loss of trust. Not to mention regulatory intervention. Therefore, in my opinion, it is worth testing the process on different types of orders, including partially returned purchases, products covered by exceptions, or international shipments, and if something requires improvement, take action immediately.
– concludes Agata Kędzierska-Zawisza, Head of Marketing & E-commerce at Globkurier.
Source: Globkurier