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EU Checkout Rules for Small Stores: Withdrawal Button and Guarantee Notice

Two items in an EU checkout generate most of the warning letters we see: a missing withdrawal function and a missing guarantee notice. Both are cheap to fix and expensive to ignore.

This is an operational checklist, not legal advice. It is what we check before a store takes money.

1. The withdrawal function

Since mid-2026, German courts have treated a checkout without a functioning withdrawal path as a competition violation. Letters arrive with a €390 plus VAT cost claim attached.

What "functioning" means in practice:

Test: place a test order, then try to withdraw as a customer would, on a phone, without help.

2. The guarantee notice

Separate from the statutory warranty, the EU sale-of-goods rules require a notice about the legal guarantee where the consumer buys. Since 27 September 2026 that notice has to appear at the point of sale, not only in the terms.

Minimum content: that a legal guarantee of conformity applies, its duration in your market, and where the details are.

Test: open your checkout on a phone and search the visible text for "guarantee" / "Gewährleistung". If it is only in the terms page, it is not at the point of sale.

3. The other ten things we check

  1. Total price including tax and shipping before the final button.
  2. Delivery time or date, stated before purchase.
  3. Trader identity and address, reachable.
  4. Withdrawal policy linked at checkout, not only in the footer.
  5. Order confirmation on a durable medium (email).
  6. Price reduction claims backed by a prior price.
  7. Consent for any pre-ticked extra, clearly not pre-ticked.
  8. Payment method fees, if any, disclosed.
  9. Country-specific consumer information for each market you ship to.
  10. Cookie/consent behaviour matching what your pages actually load.

4. What we do for $59

The $59 EU checkout check runs these twelve items against your public pages and returns a written report with the exact line to change, in English or Chinese. Three business days, no login to your store.

If you sell into several EU markets, do the check once per checkout, not once per country page.

5. What it costs to skip

A single warning letter in Germany typically costs €390 plus VAT plus a signed cease-and-desist obligation. The check costs $59. The maths is not close.

Free first step: score your CLAUDE.md if you also run agents on the store — the same "gates before money" logic applies to publishing and price changes.

FAQ

Is the withdrawal button required in every EU country?

The German enforcement is the loudest, and the EU-wide consumer rules push the same direction. If you sell to Germany, treat it as required.

Can I put the guarantee notice in the terms only?

No. The requirement is a notice at the point of sale; the terms page is where the details live.

What does the pack cost?

The EU check is $59 per checkout. The template pack, if you want the agent-side gates as well, is $9.99/month at the founding price, or $79/year. See the pricing page.

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