EU shoppers have always had the legal right to cancel an online order and get a full refund within 14 days of delivery — no questions asked. From 19 June 2026, a new EU directive (2023/2673) came into effect requiring EU countries to pass national laws that mean online stores have to make this right clearly available via a dedicated "withdrawal function." This article explains what that means for you and how to configure your Swap portal to meet the requirement while we build a fully dedicated withdrawal solution.
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 new rule from 19 June 2026 adds one requirement on top: you must provide a clearly labelled, always-available way for customers to do this. Think of it as a "make cancelling as easy as buying" rule.
Key facts:
The 14-day window starts from the date of delivery, but cancelation before delivery must also be supported
Customers must be able to cancel in "2-clicks" and do not need to give a reason
You must refund the item price and the original outbound shipping cost (in a case where the consumer selected a shipping method that is more expensive than your basic option, you need to refund only the cost of the cheapest shipping option)
The refund must go back to the original payment method
You must send an email 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 are 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 their 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 (UK has its own separate rules post-Brexit)
Switzerland (EFTA but not EEA)
Orders for personalised/made-to-order items, sealed hygiene goods once opened, perishables, and downloaded digital content
What Swap is building
We are developing a dedicated withdrawal portal — a separate entry point for EU customers to exercise their right of withdrawal, distinct from your standard returns flow. It will strip out all retention mechanics and handle both unshipped (cancel and refund) and shipped (return and refund) orders.
This is in active development. Until it is live, use the workaround below to configure your existing Swap portal for defensible compliance.
How to configure your portal now (workaround)
This three-step setup makes your Swap returns portal recognisable as a withdrawal function for EU customers.
[Note: UI may differ depending on what version of the portal you are using.]
Note: You will need to ensure your return window for EU customers is at least 14 days. If it is already 14 days or longer, no change is needed.
You can change it in Returns > Advanced Rules.
Step 1: Create advanced rules for EU customers
These rules ensure EU customers automatically receive a full outbound shipping refund when they withdraw, and optionally that a message displays in the portal to further signpost them towards withdrawal.
Rule #1 - Refund outbound shipping
Go to Settings → Advanced Rules in your Swap dashboard
Click + Create rule
Set the Title to:
EU Right of Withdrawal Customers - refund outbound shippingUnder Conditions, select Orders originating from specific countries
Add all EU and EEA countries (Austria, Belgium, Bulgaria, Croatia, Cyprus, Czechia, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden)
Click 'Add Condition', click 'AND' --> Order made between X and Y days ago, 0-14
Under Action, select Refund outbound shipping
Click Save
Rule #2 (optional) - Display a message in the portal
Repeat steps 2-5 above (Set the Title to
EU Right of Withdrawal Customers - display portal message)Under Action, select Display a message in the portal
Write your message. This will display on the first page of the portal once the customer enters their order number and email address
Step 2: Customise your portal copy
Update the text in your returns portal so EU customers recognise it as a withdrawal function.
Go to Settings → Portal Design
Edit the portal headline to:
Withdraw from your order or start a returnEdit the subheading to:
EU customers, you can withdraw from your order here.Click Save
Note: This change applies to all customers visiting your portal, not just EU customers, so keep the copy generic as in the example above. (We are working on creating two separate portals — this is a temporary solution.)
Step 3: Create a withdrawal return reason
Add a dedicated return reason so customers can clearly identify their withdrawal, and so you have an audit trail.
Go to Settings → Return Reasons
Click + Add reason
Set the Title to:
Withdrawal — I am an EU customer exercising my right to withdrawUnder Match Shopify reason text, select Other
Leave Enable comments, Require photo upload, and Require comments unchecked — customers withdrawing cannot be required to provide a reason or evidence
Click Apply
What this workaround covers
Requirement | Status with workaround |
Always-available portal (order number + email, no login required) | ✅ Already met |
14-day return window for EU orders | ✅ Configure via Advanced Rules (if yours is longer, no need to change it) |
Outbound shipping refund | ✅ Covered by Rule #1 in Step 1 |
Email confirmation on submission | ✅ Swap sends this automatically |
Dedicated, labelled withdrawal entry point | ✅ Covered by clearly labelling your portal in Step 2 and positioning it clearly on your website |
Pre-shipment cancellations (before the order ships) | ✅ Covered by pre-order workaround outlined below |
If a customer wants to withdraw before their order ships
Swap's returns portal only applies to orders that have been delivered. For cancellations before an order ships, you'll need a separate solution. You do not need to use a third party for this, but if you want to, there are two options below.
Option 1 - Tag all products as pre-order so Swap allows returns
Find your pre-order tag: go to Settings → Returns in your Swap dashboard and note the Pre-order tag field (e.g.
pre-order). If unsure, ask your account manager.
In Shopify Admin, go to Products, open a product, add the tag in the Tags field, and click Save.
Repeat for all products sold to EU customers.
For large catalogues, select all products and use Actions → Add tags to bulk-apply. You can also export your catalogue as a CSV (Products → Export), add the tag in the Tags column, and re-import.
Note: This is a standard Shopify product tag — no pre-order app is needed, and nothing changes on your storefront for customers.
Option 2 - use the Order Editing app
Order Editing is a Swap partner app that lets customers self-serve changes and cancellations to their order before it ships — including withdrawals. With the EU directive now in force, this is an increasingly important capability for any brand selling to EU consumers.
(If you do choose Order Editing and you use Swap Global, set up the integration: when a customer edits or cancels their order, Swap automatically recalculates duties and taxes and updates the order accordingly, no manual intervention required. To set it up: Order Editing Integration →)
If you are unsure whether your current rules would block 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.