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ARTICLE · 26 MAY 2026

EU Consumer Law: New ‘Withdrawal Button’ Requirements For Online Contracts

Greenberg Traurig
Greenberg Traurig
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Germany is implementing new EU requirements that mandate online merchants to provide an electronic withdrawal button, fundamentally changing how consumers can exit digital contracts. The legislation establishes specific technical and legal requirements for this withdrawal function, including design standards, data confirmation processes, and receipt acknowledgments.

GermanyConsumer Protection

The European Directive 2023/2673 introduces new framework requirements for online merchants which EU member states must implement into national law by June 19, 2026. To comply with this requirement, Germany has adopted the Act Amending Consumer Contract Law and Insurance Contract Law which will enter into force on the same day.

Key Element: Electronic Withdrawal Function

The act introduces an electronic withdrawal function (withdrawal button) for contracts concluded via an online interface for which a right of withdrawal is granted under Sections 355 et seq. BGB. This aims to ensure that consumers can opt out of an online contract as easily as they can opt into it. Contracts for which no statutory right of withdrawal exists (e.g., contracts for bespoke goods, perishable goods, or sealed hygiene products) are not subject to this requirement.

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