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The Swap guide to EU right of withdrawal

What the EU Right of Withdrawal directive requires and how to set up Swap's Withdrawal Portal to meet it.

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Written by Jemma O'Leary

The EU Right of Withdrawal Directive (2023/2673) requires online stores selling to EU consumers to provide a dedicated withdrawal function. This article explains what the law requires and how to set up Swap's Withdrawal Portal to meet it.


What is the EU Right of Withdrawal?

Under EU consumer law, any customer in an EU or EEA country who buys online can cancel their purchase and receive a full refund within 14 days of delivery. This applies even if your store has a "no returns" or "final sale" policy — the right of withdrawal overrides it. There are only limited exceptions, such as for perishable or custom goods.

The rule in force from 19 June 2026 adds one requirement on top: you must provide a clearly labelled, always-available way for customers to do this — a dedicated withdrawal function.

Key facts:

  • The 14-day window starts from the date of delivery, but cancellation before delivery must also be supported.

  • Customers must be able to withdraw without giving a reason.

  • You must refund the item price and the original outbound shipping cost.

  • The refund must go back to the original payment method.

  • You must send a confirmation when a withdrawal is submitted.

Who is legally responsible? You, as the brand and seller, are accountable for your own compliance. Swap provides the tooling — we do not give legal advice. If you're unsure about your obligations, speak to your legal advisor.


Who does this apply to?

This applies to you if you sell and ship to consumers in the EU or EEA (the EEA includes Norway, Iceland, and Liechtenstein) and the consumer's country has implemented the Directive into national law. It applies regardless of where your business is based — if you direct sales at EU consumers, the law covers you.

Not in scope:

  • UK customers (the UK has its own separate rules post-Brexit)

  • Switzerland (EFTA but not EEA)

  • Orders for personalised or made-to-order items, sealed hygiene goods once opened, perishables, and downloaded digital content


The Swap Withdrawal Portal

Swap's Withdrawal Portal is a dedicated entry point for EU customers to exercise their right of withdrawal, separate from your standard returns portal. It strips out retention mechanics such as exchange or store credit prompts, and handles both unshipped orders (cancel and refund) and shipped orders (return and refund) automatically.

This is available for Returns V2 merchants. If you're on V1, contact your account manager or our Support team.

Applied automatically

These rules always apply in the Withdrawal Portal and can't be changed:

  • 14-day withdrawal window, checked per item

  • Each item's window starts from its own delivery or fulfilment date, following your return-window preference

  • Original outbound shipping is refunded

  • Refunds only — no exchange or store credit

  • Handling fee is waived

  • Your standard Advanced Rules are skipped; withdrawal rules apply instead

Setting up your Withdrawal Portal

  1. Go to Returns → Settings → Withdrawal.

  2. Under Withdrawal portal link, enter your Withdrawal portal URL — a dedicated host configured for your brand (for example, https://withdrawals.yourbrand.com). To generate this link, you must already have a custom domain configured for your returns portal — see Set Up a Custom Domain for your Returns Portal (Returns V2).

  3. Under Configuration, select your Eligible countries — the EU/EEA destination countries whose customers can use the portal.

  4. Choose your Return shipping fee: Free return shipping, or Use my standard return shipping fees.

  5. Add your Withdrawal policy URL — shown in the portal in place of your standard returns policy, and used in withdrawal confirmation emails.

  6. Click Save.

What customers see

Customers visiting your dedicated withdrawal URL land on a simple, branded page where they enter their order number to start a withdrawal, with a link to your withdrawal policy and a way back to your store. Because it's a separate portal, EU customers get a clearly labelled withdrawal function without any changes to your standard returns portal copy.

⚠️ Currently the portal text cannot be edited from its defaults.

The below video will guide you through the experience from the end customer's point of view.

If the customer tries to withdraw from an order that isn't eligible (for example, outside the 14-day window, or not originating from an EU country), they'll see an error message.


Unshipped orders

Withdrawals submitted before an order ships are handled natively — Swap cancels the order and issues the refund automatically, with no product tagging or third-party app required.


What the Withdrawal Portal covers

Requirement

Status

Always-available, dedicated withdrawal entry point

✅ Covered by your Withdrawal Portal URL

Ability to withdraw without giving a reason

✅ No return reasons presented

As easy to withdraw as it was to place the order

✅ No exchange or credit options presented — simplified refund-only flow

14-day withdrawal window

✅ Applied automatically, per item

Outbound shipping refund

✅ Applied automatically

Refund to original payment method, no fees

✅ Applied automatically

Confirmation on submission

✅ Sent automatically

Pre-shipment cancellations

✅ Handled natively — no workaround needed


If you're unsure whether your current setup would affect an EU withdrawal — for example final-sale tags or store-credit-only settings — contact your account manager. They can review your configuration with you.

The above does not constitute legal advice. For legal questions about your compliance obligations, consult your legal advisor.

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