An online store where placing an order takes three clicks but initiating a return requires finding an email, filling out a PDF and posting it — that standard is being retired by EU law. Directive (EU) 2023/2673 establishes a principle as simple as its popular name: if you can buy with one click, you should be able to return with one click.
For e-commerce merchants, this is not a cosmetic change — it is a technical, procedural and legal requirement that applies across the EU, including Poland, from June 19, 2026. Below we explain everything: what exactly the directive requires, how the full process works from the consumer's click to the refund, and what penalties apply for non-compliance.
What Are One-Click Returns and Where Did They Come From
The right to withdraw from a distance contract has existed in the EU for over two decades. Directive 2011/83/EU gave consumers a 14-day period to cancel an online purchase without giving a reason. The problem was that the way to exercise this right was left almost entirely to the merchant — resulting in form labyrinths, hidden PDF links, and requirements to print and post documents.
In 2022, the European Commission found that the right existed on paper but was systematically made difficult to use. The response was the amendment that became Directive (EU) 2023/2673 of the European Parliament and of the Council of November 22, 2023.
The directive adds a new Article 11a to the Consumer Rights Directive — the technical heart of the regulation — requiring online merchants to implement a dedicated, permanently visible withdrawal button or link that opens an electronic form within the store's own interface.
What the Law Requires
Requirement 1: Visible and permanently accessible button
The button must be clearly labelled (the directive suggests "Withdraw from contract here" or equivalent), permanently visible throughout the 14-day withdrawal period, and easily accessible in the customer account or order management interface — not hidden in the footer or terms page.
Requirement 2: Electronic form within the store interface
After clicking the button, the consumer must see an electronic form operating within the store. It must allow withdrawal from the whole order or individual items (partial return), and must not require the consumer to give a reason.
Requirement 3: Immediate confirmation on a durable medium
Immediately after the consumer submits the form, the store must automatically send a confirmation on a durable medium (an email with date and order reference). This date starts the merchant's 14-day refund clock.
Is This Already in Force?
Member States were required to transpose the directive into national law by December 19, 2025. The application date — when stores must comply — is June 19, 2026. This deadline is uniform across all 27 EU member states with no transition period after that date.
The Full Return Process — Step by Step
- Consumer clicks "Withdraw from contract" — within 14 days of receiving the goods (or contract conclusion for services/digital content)
- Consumer fills the in-store electronic form — order number, product selection; reason is optional
- Store sends automatic confirmation e-mail — with date/time of withdrawal, order reference, and instructions for returning the goods
- Consumer returns the goods — within 14 days of the withdrawal notice; return shipping costs are borne by the consumer if they were informed before purchase, otherwise by the store
- Store issues refund within 14 days — covering the product price plus basic delivery costs (up to the cheapest standard delivery option offered), using the same payment method as the original purchase
Who Is Covered
The directive applies to all B2C distance contracts — physical goods, digital content, digital services, subscriptions — with no revenue or company size thresholds. Non-EU merchants actively targeting EU consumers are also covered.
Exceptions
The right of withdrawal (and therefore the button requirement) does not apply to: custom-made or personalised goods, perishable goods, sealed audio/video recordings or software opened by the consumer, newspapers and periodicals (except subscriptions), fully performed services where the consumer consented before the deadline, and unsealed digital content where the consumer acknowledged the loss of the withdrawal right.
Penalties for Non-Compliance
Each member state sets its own penalties, which must be effective, proportionate and dissuasive. In Poland, the supervisory authority is UOKiK, which can impose fines of up to 10% of annual turnover for violations of collective consumer interests. For coordinated cross-border enforcement under Regulation (EU) 2017/2394, the cap is 4% of annual turnover across affected member states.
What Stores Need to Implement
- A withdrawal button in the customer account / order history
- An in-store electronic form (not a PDF download, not a mailto link)
- Automated confirmation e-mail sent immediately after form submission
- Updated terms and conditions describing the new process
- Implementation in mobile apps, if the store has one