EU Directive 2023/2673 – New Rules for e-Commerce Returns

Another regulation from Brussels? More new obligations? The European Union certainly doesn’t let us get bored. But relax – EU Directive 2023/2673 isn’t causing a massive upheaval. It simply tidies up certain issues so they no longer become a pain point for consumers. And that’s actually a good thing, because the goal is customer satisfaction. And that’s something you care about too. Still, there’s going to be some work on your end. Because the new rules for returns in e-Commerce mean you’ll need to implement a few things in your store that you haven’t had to think about until now. But don’t worry – in this article, we’ll explain everything the new Directive changes.

Directive (EU) 2023/2673 amends the rules on withdrawal from distance contracts. In practice, this means that from June 19, 2026, every B2C online store in the European Union – including, of course, Poland – will need to provide customers with a simple, digital withdrawal function. No more PDF forms, no more “please send an email to returns@…”, no more hiding the return procedure on the thirtieth subpage of your terms and conditions.

Sounds simple? In theory, yes. But the devil is in the details. And there are more details than you might expect. Because this directive isn’t just about a “return button.” It’s a change that will affect the UX of your online store, your terms and conditions, your logistics processes, and – if you offer deferred payments or shipment insurance – also the way you present financial services in your e-Commerce.

That’s why we’ve prepared this article. We read the full text of the Directive for you (21 pages of legal language) and pulled out what you actually need to know as an online store owner or e-Commerce manager. No fluff, no scare tactics, and no hard sell. Just concrete guidance on what to do and when.

What Is Directive (EU) 2023/2673?

Before we get into the specifics, let’s briefly clarify what document we’re actually dealing with here because there’s been quite a bit of oversimplification and misinformation surrounding this Directive – especially in the Polish corner of the internet.

Directive (EU) 2023/2673 of the European Parliament and of the Council was adopted on November 22, 2023. It amends Directive 2011/83/EU – the one that currently gives your customers the right to return products within 14 days without giving a reason.

Why Was It Introduced in the First Place?

The reason is pretty mundane. The EU noticed that in many online stores, placing an order takes two clicks, while withdrawing from it takes two weeks of email correspondence. That’s not fair to the consumer. And even though the right to return has existed for years, in practice, many e-Commerce businesses made it difficult to exercise – sometimes intentionally, sometimes simply through neglect.

On top of that, there were the so-called dark patterns – manipulative interface design techniques that discourage users from going through with a return. Hidden buttons, pop-ups asking “Are you sure you want to cancel?”, multi-step forms, or the requirement to call a hotline. Sound familiar? These are exactly the kinds of practices the Directive is designed to put an end to.

Two Areas of Change

And here’s where something comes up that many online sources don’t mention – or mention imprecisely. Directive 2023/2673 introduces changes in two areas that are worth clearly distinguishing:

1. Changes for all online stores (Art. 11a)

This is an entirely new provision that says: if a customer can buy from your online store, they must also be able to withdraw from that contract in your store, simply, without complications. This applies to every B2C e-Commerce platform that enables distance contracts: no exceptions, no revenue thresholds, no industry distinctions. If you sell to consumers online, this provision applies to you.

2. Changes for distance financial services (new Chapter IIIa, Art. 16a–16e)

Directive 2023/2673 was originally created with financial services in mind – banks, insurers, fintechs. That’s why the larger part of it (new Chapter IIIa) addresses precisely this area: expanded information obligations, a ban on dark patterns, the consumer’s right to contact a real person rather than a chatbot, and detailed rules for withdrawing from financial contracts.

Why does this matter to you? Because if your store offers deferred payments (e.g., PayPo, Klarna, Twisto), installments, shipment insurance, or other financial products as part of the checkout process, some of these provisions may apply to you directly. We’ll come back to the details a bit later.

Key Dates

There are two dates you need to remember:

• December 19, 2025, was the deadline by which EU member states were supposed to transpose the Directive’s provisions into national law. In Poland, UOKiK is responsible for this process.
• June 19, 2026 – from this day on, the new regulations take effect. Your online store needs to be ready.

So there’s not much time left. And as you’re about to see, there’s quite a bit of work to do.

Who Does Directive 2023/2673 Apply To?

Now that you know what this directive is, it’s time to answer the most important question: Does it apply to your business?

Short answer: if you run an online store and sell to consumers – YES. But let’s check more carefully, because the scope of this directive isn’t as straightforward as it might seem.

B2C Online Stores – This Applies to All of You

Art. 11a – the key provision for e-Commerce – applies to anyone who sells to consumers through a website or mobile app. Provided the customer has the right to withdraw from the contract (and in the vast majority of cases, they do).

What does this mean in practice? If you sell goods to consumers online and your customers have the statutory right to return within 14 days, the new regulations apply to you. It doesn’t matter whether your store runs on PrestaShop, Magento, Shopify, Shopware, WooCommerce, or a custom-built platform. It doesn’t matter whether you have 50 products in your catalog or 50,000. And it doesn’t matter whether your annual revenue is 100,000 euros or 100 million euros.

The obligation is the same for everyone.

B2B Sales – It’s Different Here

Directive 2011/83/EU (and, by extension, its amendments) applies to business-to-consumer relationships. If you sell exclusively to businesses (B2B trade), these regulations don’t apply to you.

There is one “but,” however. If you run a platform that serves both business clients and end consumers – and there are more and more of these businesses in the world – you need to implement the new requirements for the part of your e-Commerce that handles B2C sales. So it’s good to know who your customer actually is. And if you have any doubts, it’s worth sorting that out with a lawyer before June 2026 rolls around.

Digital Services and Subscriptions – Also in the Game

And this isn’t just about stores selling physical products. The new regulations also apply to:

• stores selling digital content (e-books, online courses, software),
• platforms offering services on a subscription model,
• services selling online-based offerings.

Of course, provided the customer has the right to return in their case. If, for example, they’ve already downloaded an e-book with their explicit consent, there’s no right of withdrawal, and so the obligation under Art. 11a doesn’t apply to them either.

What About Financial Services?

If your e-Commerce offers deferred payments (BNPL), installment plans, shipment insurance, or product insurance at checkout, it’s worth checking whether the new Chapter IIIa of the Directive (Art. 16a–16e) imposes additional obligations on you.

We’ll cover the details in a separate section of this article. At this stage, just remember one thing: if your store lets customers “buy” any kind of financial service – even as an add-on to the main order – read that section carefully.

What Exactly Do You Need to Implement in Your Online Store?

Now that you know Directive 2023/2673 applies to your business, let’s get to the heart of the matter: what specifically do you need to change in your store to meet the new requirements? Everything is built around one new article (Art. 11a), but it contains more requirements than most articles online would suggest.

Many sources write about a “one-click return button.” That’s a significant oversimplification that could get you into trouble. Because the directive doesn’t require one button, it requires an entire process – with a form, confirmation, and automated communication. So let’s break it down piece by piece.

The “Withdraw from Contract” Function – Visible, Accessible, Unambiguous

The first thing you need to provide in your store is a function that allows the consumer to withdraw from the contract online. The directive states explicitly that it must:

• be labeled with the words “Withdraw from Contract Here” or an equivalent wording, presented in a legible form,
• be available throughout the entire period during which the customer has the right to withdraw from the contract (14 days from receiving the goods as standard, unless you’ve extended this period in your return policy),
• be placed in a prominent way within the online store’s interface,
• be easily accessible – the consumer cannot be forced to search through menus, download an app, or log in to a separate system to reach it.

So this isn’t about a link hidden in the footer or a brief sentence in your store’s terms and conditions. It’s about a clearly visible interface element that the customer can find without any trouble, just as easily as the “Add to Cart” button.

Where’s the best place to put it? The directive doesn’t dictate that. But given the requirement for prominence and easy accessibility, sensible placements would be the customer panel (the “My Orders” section), the order details page, or the order confirmation email with a direct link to the withdrawal function. You could also consider placing it in a visible “Returns” section in the footer – but only if it’s genuinely easy to find there.

An Online Form with Specific Data

The withdrawal function isn’t just a button. After clicking it, the consumer must be able to submit an online withdrawal statement. In this statement, the customer must be able to provide or confirm three things easily:

• their first and last name,
• information identifying the contract they want to withdraw from (e.g., order number),
• contact details (e.g., an email address or other electronic means) to which the store will send confirmation.

Importantly, the directive emphasizes that if the customer is already logged in, they shouldn’t have to re-enter this information. The form should be pre-filled with data the store already has. This is a crucial detail that affects how you design this solution.

In practice, this means that if a customer is logged in and goes to their order details, they should be able to click “Withdraw from Contract,” see a form with their data already filled in, optionally select which products from the order they want to return, and proceed to confirmation – no re-entering what your system already knows about them.

Two-Step Confirmation – This Is Not a “One-Click Return”

And here we get to the point that most articles online either skip or misinterpret. The Directive requires a two-step process. After filling out the form, the consumer must have the option to confirm their decision with a separate step – a button labeled “Confirm Withdrawal from Contract” or similar wording.

Why? To avoid a situation where the consumer accidentally clicks and withdraws from a contract they never intended to cancel. The directive states this explicitly – the store should require the customer to confirm their decision in a way that clearly shows it was a conscious choice.

So the process looks like this:

Step 1: The consumer clicks “Withdraw from Contract Here” → fills out (or confirms the pre-filled) form with their data.

Step 2: The consumer clicks “Confirm Withdrawal from Contract” → the statement is submitted.

Simple? Yes. One click? No. And that’s a good thing – because it protects both the consumer and you.

Automatic Confirmation on a Durable Medium

After the consumer confirms their withdrawal from the contract, your store must send them a confirmation on a durable medium without undue delay. In practice, this means sending a confirmation email acknowledging receipt of the request (though the directive also allows other forms of communication).

This message must include:

• the content of the withdrawal statement (which order, which products),
• the date and time the statement was submitted.

This isn’t optional – it’s an obligation. And it should be automated, because “without undue delay,” as stated in the Directive, does not mean “whenever the customer service rep gets back from vacation.”

Protecting the Consumer’s Deadline

One more important thing. The Directive states that the consumer has exercised their right of withdrawal within the deadline if they submitted their online statement before the 14-day period expired. What counts isn’t the moment you read it, process it, or accept the request. What counts is the moment it was submitted.

That’s why it’s worth having your system record the exact date and time the statement was submitted. This could come in handy in the event of any disputes.

Updated Information Obligations

The directive also changes the rules around information you must provide to the customer before purchase (Art. 6 of Directive 2011/83/EU). From now on, you also need to clearly inform the customer that this withdrawal function exists and where to find it.

What does this mean in practice? You need to update:

• your store’s terms and conditions – by adding information about the new function and where to find it,
• pre-contractual information – the information the consumer sees before placing an order,
• the model withdrawal instructions – the Directive changes their content by adding a reference to the online function.

This isn’t a massive revolution, but it does require reviewing and updating the documents you have on your site. Better to do it once, properly, than to patch things together in a rush right before June 2026.

If you want to learn what else should be on your product page, read the article: Product Page in e-Commerce: 9 Stores That Do It Brilliantly.

What if You Offer Financial Services as Part of Your e-Commerce?

You’re going to have a few more obligations stemming from this Directive.

This section doesn’t apply to everyone. But if, in your online store, a customer can use deferred payments, installments, shipment insurance, or any other financial service when placing an order, read it carefully. Because Directive 2023/2673 has additional requirements for you that you need to meet.

When Does e-Commerce “Touch” Financial Services?

What counts as a financial service under this Directive? Banking, credit, insurance, pension, investment, and payment services. Sounds like something that applies to banks, not clothing stores. But that impression can be misleading.

Think about what your customer sees at checkout. If they can choose:

• a deferred payment option (BNPL) – e.g., PayPo, Klarna, Twisto,
• an installment purchase – e.g., PayU installments, Santander installments,
• shipment or product insurance – e.g., extended warranty, damage protection,

…then you’re selling them a financial service. That’s when the new Chapter IIIa of the Directive (Art. 16a–16e) comes into play, which imposes significantly broader obligations on businesses than Art. 11a alone.

Does this mean that every store with PayPo at checkout needs to implement all the provisions from this chapter of the Directive? Not necessarily. A lot depends on who the formal party to the financial contract is (you or the service provider) and on how it’s legally structured. But it’s worth checking. Because if your store acts as an intermediary in concluding such contracts, the new regulations may apply to you.

Additional Obligations – What Do You Need to Know?

The new Chapter IIIa of Directive 2011/83/EU (added precisely by Directive 2023/2673) is an entirely different level of requirements. Let’s walk through the most important ones.

You need to tell the customer significantly more than before

Art. 16a of the Directive introduces an extensive list of information you must provide to the consumer before they enter into a distance financial services contract. And we’re not talking about a brief mention in the terms and conditions. It’s a full list that includes, among other things, data identifying the business, a description of the main characteristics of the service, the total price including all fees and taxes, information about risks, conditions for withdrawing from the contract, and even information about whether the price has been personalized based on algorithms.

All of this information must be provided on a durable medium, in a legible form, and sufficiently in advance of the contract being concluded. On request, it must also be provided in a format accessible to people with disabilities.

And one more thing. If you provided this information later than 1 day before the contract was concluded, you must also send the consumer a reminder of their right to withdraw within 1 to 7 days after the contract is concluded. Just to make sure they know they can back out.

The customer has 14 days to withdraw, and if you don’t inform them, it will be much longer

The rule here is the same as for regular purchases: the customer has 14 days to withdraw – no reason required, no penalties.

But watch out! If you didn’t provide the required pre-contractual information, that deadline extends to 12 months and 14 days. And if you didn’t inform them about the right to withdraw at all? The deadline never expires. The customer can withdraw from the contract at any time.

That’s a serious consequence of failing to meet your information obligations – and it could cost you a lot.

Terms and conditions aren’t enough

Here’s a distinction that’s easy to miss. The directive requires (Art. 16d) that you don’t just provide the customer with information, but that you also explain in plain language what the contract actually means and what consequences it could have for them – including, for example, what happens if they’re late on an installment payment.

Imagine this situation: a customer buys a sofa from you on an installment plan. In your terms and conditions, you’ve written that “late payments will result in statutory interest being charged in accordance with Art. 481 §2 of the Civil Code.” Formally correct? Yes. Understandable to the customer? Probably not. The directive states explicitly – simply duplicating the content of your terms and conditions isn’t enough. The explanation must be accessible, understandable, and written in plain language.

A chatbot isn’t enough – the customer has the right to talk to a real person

If you use automated tools at the pre-purchase stage – chatbots or AI tools – the consumer has the right to request a conversation with a live human being (Art. 16d(3)). Free of charge, during your company’s business hours, in the same language in which they received the pre-contractual information. In justified cases, this right also applies after the contract has been concluded.

You probably know this from your own experience. You call a helpline, and there’s a bot that sends you around in circles through menus. The Directive says: enough of that, at least in the context of distance financial services.

In an era of growing customer service automation in e-Commerce, this provision warrants special attention, especially if your customer support handles inquiries about installments or insurance exclusively via a chatbot.

No more “Are you sure you don’t want to insure your shipment?”

You know those pop-ups? You add a product to your cart, don’t check the shipment insurance box, and the store asks you: “Are you sure you don’t want to insure your shipment?” You click “Skip,” and on the next step, the offer pops up again. That’s a classic dark pattern, and the Directive (Art. 16e) says explicitly: ENOUGH!

When it comes to financial services, the following are prohibited:

• highlighting certain options when the consumer is making a decision (e.g., visually “nudging” toward the more expensive insurance variant – a bigger button, a brighter color),
• repeatedly asking about the same thing when the consumer has already made their choice,
• making it harder to opt out of a service than to subscribe to it (e.g., buying insurance takes one click, but canceling it requires sending an email).

Importantly, EU member countries can introduce even stricter regulations in financial services. So it’s worth keeping an eye on how the Polish government interprets these requirements.

What should you do if you’re not sure whether this applies to you?

If you’re not certain whether the services offered as part of your checkout qualify as financial services under the Directive, consult a lawyer. This isn’t an area where guessing is a good idea. The cost of a legal consultation is significantly lower than the potential penalties for failing to meet your obligations.

And if it turns out that Chapter IIIa doesn’t apply to you, all the better. At least you’ll know for sure.

Table: What Applies to My Store?

So you don’t have to go back through individual sections, we’ve put together a summary of the most important obligations depending on your store type.

	Every B2C Online Store (Art. 11a)	Stores Offering Distance Financial Services (Chapter IIIa, Art. 16a–16e)
Who does it apply to?	Every B2C e-Commerce in the EU that enables distance contracts through a website or app. No exceptions, no revenue thresholds.	Stores offering at checkout: deferred payments (BNPL), installments, shipment/product insurance, or other financial services.
Withdrawal function	Yes – a “Withdraw from Contract Here” button (or equivalent wording), visible, prominent, and available throughout the entire withdrawal period.	Yes – the same requirements as Art. 11a, plus additional requirements described below.
Online form	Yes – with consumer data, contract identification, and contact details. Pre-filled for logged-in customers.	Yes (same requirements as Art. 11a).
Two-step confirmation	Yes – a separate “Confirm Withdrawal from Contract” button.	Yes (same requirements as Art. 11a).
Automatic email confirmation	Yes – without undue delay, including the content of the statement, date, and time.	Yes (same requirements as Art. 11a).
Expanded information obligations	No – it’s enough to update your terms and conditions and pre-contractual information to reference the new function.	Yes – a detailed list of pre-contractual information (business data, service characteristics, full price, risks, algorithmic price personalization, and more).
Withdrawal right reminder	No.	Yes – if information was provided less than 1 day before the contract was concluded, a reminder must be sent within 1–7 days.
Obligation to explain, not just inform	No.	Yes – an accessible explanation of the contract’s features and consequences for the consumer (e.g., what happens if an installment payment is late).
Customer’s right to contact a real person	No.	Yes – if you use chatbots or AI tools, the consumer can request a conversation with a human. Free of charge, during your company’s business hours.
Dark patterns ban	Not mandated by this Directive (though dark patterns are a bad practice regardless of regulations).	Yes – a ban on highlighting options, repeatedly asking the same question, and making it harder to opt out.
Withdrawal deadline	14 days (unchanged – based on existing regulations).	14 days (30 days for pensions). If pre-contractual information is missing: up to 12 months + 14 days. If withdrawal rights aren’t communicated, the deadline never expires.
Penalties	Financial penalties from the Consumer Protection Office for violating consumer regulations.	Financial penalties from the Consumer Protection Office + additional fines under the EU regulation on consumer protection cooperation.
Effective from	June 19, 2026.	June 19, 2026.

How to Prepare? A Practical Action Plan

Now that you know what Directive 2023/2673 changes and what obligations it places on your online store, it’s time to answer the most important question: what do you actually do about it?

The new regulations take effect on June 19, 2026. If you’re reading this article before that date, you don’t have much time. If you’re reading this after, there’s even more reason to act fast. Because along the way, you need to analyze your current processes, commission changes to your system, update your documents, and test the new solutions. The sooner you start, the smoother this process will be.

Here’s an action plan in five steps.

Step 1: Analyze How Returns Work in Your Store Today

Before you start implementing anything, check what the current withdrawal process looks like in your e-Commerce. Walk through this journey yourself, as a customer. Buy something from your own store, and then try to withdraw from that contract.

Ask yourself a few questions:

• Can the customer submit a withdrawal statement online, or do they have to send an email or download a PDF?
• How many steps do they need to take to find the return information?
• Is the process as simple as placing an order?
• Does the customer receive an automatic confirmation that their statement was submitted?
• How does it look on a phone?

If the answer to any of these questions is “no” or “I don’t know,” you’ve got an area to improve. And it’s better to find out about it now than from the head of the Consumer Protection Office after June 2026.

And if your store isn’t selling as well as you’d like, check out another article: 18 Reasons Why Isn’t Your Online Store Selling Enough?.

Step 2: Check What You Need on the Technical Side

You already know what you need to implement (withdrawal function, form, confirmation, two-step process). Now the question is: does your e-Commerce platform make this possible?

If your store runs on PrestaShop, Magento, Shopify, Shopware, or any other (non-custom) platform – check whether the vendor or community has already prepared a module or plugin that meets the Directive’s requirements. At the time this article was published, many platforms were still working on it, but closer to the deadline, there should be more ready-made solutions available.

If you’re running on a custom-built platform, talk to your development team or e-Commerce agency about the scope of changes. This isn’t a massive project, but it does require some thought: where to place the function, how to design the form, how to automate the confirmation, and where to store the date and time data for submitted statements.

One thing is certain – don’t put off this conversation until June 18, 2026.

Step 3: Update Your Terms and Conditions and the Rest of the Documents

The directive requires that in the information you provide to the customer before purchase, you clearly indicate that the new withdrawal function exists and where to find it. This means you need to review and update:

• your store’s terms and conditions,
• information about the right to withdraw from the contract (the information the customer sees before purchase and in the order confirmation),
• and the model withdrawal instructions.

If a lawyer wrote your terms and conditions, go back to them with a request for an update. If you wrote them yourself based on a template from the internet, there’s even more reason to get this sorted out now with a specialist’s help.

And one more thing. If you sell to international markets, keep in mind that each EU member state may adapt the Directive slightly differently into its national law. It’s worth verifying this.

Step 4: Test the New Journey – On Every Device

Have you implemented the function? Great. But before you consider the matter closed, test it thoroughly. And not just by yourself. Ask someone who doesn’t know your store inside and out to check how it works.

What to pay attention to:

• Is the “Withdraw from Contract” button easily visible and accessible?
• Does the form work correctly (including pre-filled data for logged-in customers)?
• Is the two-step process (form → confirmation) intuitive?
• Does the confirmation email send automatically and contain the required data (content of the statement, date, time)?
• Does everything work properly on a smartphone? Because remember – over 75% of internet users shop on mobile. And they’ll be submitting returns on their phones, too.

Test, fix, test again. It’s better to find a bug now than when a customer actually wants to use this function.

Step 5: Think About the Impact on Logistics and Budget

Easier returns may mean more returns. That’s not a certainty, but it’s worth being prepared for. If, up until now, a complicated withdrawal process has been a barrier for some customers, removing it could increase the number of requests.

So ask yourself:

• Is your warehouse ready for a potentially higher volume of returns?
• Do you have an efficient process for receiving, inspecting, and re-listing returned products for sale?
• Have you accounted for return handling costs in your e-Commerce budget?

This is a good moment to start looking at returns not as a “necessary evil,” but as an element of the customer experience that – if you design it well – can build trust and loyalty. Because a customer who returned a product easily and hassle-free is more likely to come back to your store for their next purchase.

If you want to learn more about how to plan an e-Commerce budget, read our article: An e-Commerce Budget: How to Plan Your Investment to Avoid Costly Mistakes?

What Penalties Do You Face for Not Meeting the New Requirements?

We don’t want to scare you. But ignoring this topic is a risk that’s not worth taking.

The Directive requires that sanctions for violating the new regulations be effective and dissuasive. The specific penalty amounts depend on how each EU member state transposes these provisions into national law. In Poland, consumer rights enforcement is the responsibility of UOKiK (Office of Competition and Consumer Protection). And if you follow industry news, you know that the head of UOKiK isn’t someone who turns a blind eye to these things.

What are you facing in practice? First and foremost, financial penalties imposed by the Consumer Protection Office. If your store doesn’t provide customers with the required withdrawal function, you can be fined. It’s that simple. And if you additionally offer distance financial services, the pool of potential consequences gets even larger.

But penalties from the Consumer Protection Office are one thing. There’s something else worth keeping in mind – reputational consequences. In a time when store reviews spread online in an instant, a customer who can’t easily withdraw from a contract isn’t going to patiently search for a PDF form in the “Terms and Conditions” tab. They’ll share their frustration on Facebook, in a Google review, or on an industry forum. And those kinds of “penalties” can cost more than any fine.

There is good news, though. Stores that implement the new requirements well and ahead of time can use this as a competitive advantage. A simple, transparent return process builds trust, improves the shopping experience, and has a real impact on customer loyalty. And after all, a loyal customer is the most valuable customer.

Summary

Directive (EU) 2023/2673 changes the rules of the game in one of the most important (and most underappreciated) areas of e-Commerce – the returns process. This isn’t a revolution that turns your business upside down. It’s the tidying up of something that should have worked better a long time ago.

What do you need to remember? From June 19, 2026, your online store must provide consumers with a simple, digital withdrawal function – complete with a form, two-step confirmation, and an automated response. If you offer financial services at checkout, additional information obligations and a ban on manipulative interface practices apply on top of that.

You can treat this as just another box to check. Or as an impetus to make your store handle returns so well that customers keep coming back – not to return products, but to buy more. And isn’t that what this is all about?