It applies to both, but with different rules. For goods, the 14-day window starts when the customer takes possession of them. For services, it starts when the contract is concluded.
You must issue the refund within 14 days of confirming the withdrawal, but you are allowed to withhold the refund until you have received the goods back, or until the customer provides proof of return (e.g. a tracking receipt). You do not need to refund instantly – you can wait for the goods, as long as it falls within the 14-day window from confirming the withdrawal.
For most rules, enforcement falls under the authority of the country where your business is based. However, if a specific country has stricter requirements, a consumer in that country can approach their local authority. Our recommendation: use the most stringent market as your baseline. The EU directive is harmonized in its core rules, but implementations vary in enforcement culture and local nuances. Germany tends to require the most careful handling. Configure one set of core compliance rules in inretrn, and localise communication – language, terminology, model form language – per market.
Germany has one of the most consumer-protective legal environments in the EU and one of the most active. Consumer organisations and authorities act quickly, and Germany has a strong tradition of abmahnung: formal legal warnings sent by competitors or consumer organisations for non-compliant withdrawal notices. Importantly, if you receive a formal demand from a German party, you must respond – failure to do so can escalate to legal proceedings. Your withdrawal information must be correct, complete, and use the approved model form language. We recommend your legal team reviews your withdrawal notice text for the German market specifically.
The consumer has 14 days from the withdrawal notice to return the goods. If they do not return them within that window, you are no longer obligated to refund. You can hold the refund until goods are returned or proof of return is provided. If goods are not returned at all, the withdrawal is effectively invalidated – the customer loses their refund entitlement.
An order confirmation email alone is not sufficient. The requirement is for a button or hyperlink on your website – clearly visible, available to every customer including those not logged in, at any point within the 14-day window. An email link that expires or becomes unreachable does not meet the legal standard. The function must be on-site and easy to find.