# EU rules for online shops in 2026: a practical checklist Source: https://storecompliant.com/guides/eu-rules-checklist-online-shops Updated: 2026-10-07 Three EU display duties now apply to online shops that sell goods to consumers: the 30-day lowest price, the withdrawal function and the legal guarantee notice. This checklist goes through them page by page and lists the neighbouring rules to check. This is a working checklist of the EU rules for online shops in 2026, arranged the way a shop is built: the product page, the cart and checkout, the footer, and what happens after the order. It goes into depth on three display duties, because all three now apply and all three are visible on the storefront. Other rules a shop owner will ask about are listed near the end and marked as outside this site’s focus. The dates and wording below come from the directives themselves. A directive is put into national law by each Member State, so the rule that binds your shop is the national one. Use this list to find what to check, then check your national law. ## Who the rules apply to **Sales to consumers.** All three duties concern a trader selling to consumers. Sales to other businesses are a different subject. **Goods.** The price reduction rule covers goods. The Commission’s guidance states that it does not apply to services or to digital content. The legal guarantee notice also concerns goods. The withdrawal function is wider: it covers distance contracts concluded through an online interface wherever a right of withdrawal exists. **Shops inside and outside the EU.** The guidance on the price rule says that Article 6a “applies also to traders based outside the EU that direct their sales to EU consumers, including to traders offering goods via platforms”. The product safety regulation uses a similar test: an online offer counts as made available on the EU market if it “is targeted at consumers in the Union”. The withdrawal function and the guarantee notice sit in the Consumer Rights Directive, which each Member State has written into its own law. If you sell to consumers in a Member State from outside the EU, assume that country’s consumer rules can reach you and check them. **The EEA.** The Commission’s price guidance is addressed to the EU Member States and to Iceland, Liechtenstein and Norway. **Marketplaces.** For the price rule, the guidance treats the seller of the goods as the trader, including a seller that uses an online marketplace. ## Timeline: the dates to know | Date | What applies | Legal basis | | --- | --- | --- | | 28 May 2022 | An announced price reduction must show the prior price: the lowest price of at least the previous 30 days | Directive (EU) 2019/2161, which added Article 6a to Directive 98/6/EC | | 26 September 2024 | Court of Justice, Aldi Süd: a reduction shown as a percentage or a promotional statement must be worked out from that prior price | Case C-330/23 | | 19 June 2026 | Withdrawal function for distance contracts concluded through an online interface | Directive (EU) 2023/2673, which added Article 11a to Directive 2011/83/EU | | 27 September 2026 | Harmonised notice on the legal guarantee, and harmonised label for a producer’s guarantee of durability | Directive (EU) 2024/825 and Implementing Regulation (EU) 2025/1960 | The three directive dates are the dates from which Member States must apply their national measures. ## Product page checklist ### When a price is reduced - Show the **prior price**. Article 6a defines it as “the lowest price applied by the trader during a period of time not shorter than 30 days prior to the application of the price reduction”. - Count earlier promotions. The guidance says the lowest price “shall include any previous ‘reduced’ price during that period”. - Work out any percentage or “you save” figure from the prior price, not from the last price charged. That is what the Court held in Aldi Süd. - Treat a crossed-out price, a “sale” badge and a percentage alike. The guidance lists all of them as price reduction announcements. See [crossed-out prices and “was/now” discounts](/guides/strikethrough-prices-eu-rules). - Where sizes or colours have their own prices, work per variant. The texts do not mention variants; [the guide to product variants](/guides/omnibus-directive-product-variants) explains the cautious reading. - Check the national options. Member States may set different rules for goods that deteriorate or expire rapidly, for goods on the market for less than 30 days, and for reductions that increase progressively. The rule is covered in depth in [the Omnibus Directive and the 30-day lowest price](/guides/omnibus-directive-30-day-lowest-price). ### Legal guarantee notice - For goods, give “a reminder of the existence of the legal guarantee of conformity for goods and its main elements, including its minimum duration of two years”, and give it “in a prominent manner, using the harmonised notice”. - Use the notice as published. The annex to Implementing Regulation (EU) 2025/1960 states that none of its elements can be edited, and that for contracts concluded through an online interface it is shown in colour. - Show the **harmonised label** where it applies: when the producer offers a commercial guarantee of durability at no additional cost, covering the entire good, for more than two years, and has made that information available to you. - Give the information before the consumer is bound by the contract. The directive does not name a spot on the page, so check how your national law words it. More detail is in [the EU legal guarantee notice](/guides/eu-legal-guarantee-notice). ### Also on the product page (outside this site’s focus) The Consumer Rights Directive lists pre-contractual information such as the main characteristics of the goods and the total price inclusive of taxes, with delivery charges. The Price Indication Directive requires a unit price (per kilo, per litre) for certain products. The product safety regulation requires online offers to show, among other things, the manufacturer’s name and contact addresses and information identifying the product, including a picture. ## Cart and checkout checklist - If the cart repeats a crossed-out price or a “you save” line, use the same figures as the product page. Article 6a covers “any announcement of a price reduction”. - Directly before the order, show the main characteristics of the goods and the total price in a clear and prominent manner. Directive (EU) 2024/825 added the durability guarantee label, where one applies, to that list. - Tell the consumer about the right of withdrawal: the conditions, the time limit and the procedure, the model withdrawal form and, since Directive (EU) 2023/2673, “information about the existence and placement of the withdrawal function”. - Outside this site’s focus: the Consumer Rights Directive requires the order button to carry only the words “order with obligation to pay” or a corresponding unambiguous formulation, and requires trading websites to say, at the latest at the start of the ordering process, whether delivery restrictions apply and which means of payment are accepted. ## Footer and every page **Withdrawal function.** Article 11a requires the function to be “labelled with the words ‘withdraw from contract here’ or an unambiguous corresponding formulation in an easily legible way”. It must be “continuously available throughout the withdrawal period”, “prominently displayed on the online interface and easily accessible to the consumer”. The directive does not say “footer”. Its recitals give the example of hyperlinks leading to the function, and say the consumer should not have to download an application to reach it. A link that is present on every page is a common way to keep the function continuously available. Your national law may be more specific. **Outside this site’s focus.** The trader’s identity, geographical address and contact details are part of the pre-contractual information. Privacy and cookie notices fall under data protection law. ## After the order The withdrawal function is a short process, and each step is set out in Article 11a: 1. The consumer sends an online withdrawal statement in which they can easily provide or confirm their name, details identifying the contract, and the electronic means by which the confirmation is to be sent. 2. They submit it with a confirmation function labelled only “confirm withdrawal” or an unambiguous corresponding formulation. 3. The trader sends, without undue delay, an acknowledgement of receipt on a durable medium, including the content of the statement and the date and time of its submission. 4. A statement submitted before the withdrawal period expired counts as made in time. The function comes in addition to the other ways of withdrawing, such as the model form. The directive does not prescribe a log, but the time of submission decides whether a withdrawal was in time, so a dated record of each statement is useful to both sides. See [the EU withdrawal button](/guides/eu-withdrawal-button). Outside this site’s focus: the withdrawal right itself. The Consumer Rights Directive gives the consumer 14 days to withdraw from a distance contract without giving a reason. For a sale of goods the period runs from the day the consumer takes physical possession of them. There are exceptions, for example goods made to the consumer’s specifications. ## Neighbouring rules, outside this site’s focus This site does not cover the following in detail. They are listed so that you know to look them up. | Topic | Main EU text | What to check | | --- | --- | --- | | Pre-contractual information | Directive 2011/83/EU, Articles 6 and 8 | The full list of information and where it must appear | | 14-day right of withdrawal | Directive 2011/83/EU, Articles 9 to 16 | Start of the period, exceptions, refunds, return costs | | Unit prices | Directive 98/6/EC | Which products need a price per unit, and national exemptions | | Personal data and cookies | Regulation (EU) 2016/679 (GDPR) and national cookie rules | Guidance from your data protection authority | | Product safety | Regulation (EU) 2023/988 (GPSR), applying from 13 December 2024 | Information on online offers; a responsible person in the EU where the manufacturer is outside it | ## Where countries differ - **Price rule options.** The three options in Article 6a are for each Member State to use or not. - **Penalties.** For the price rule, Member States lay down penalties that must be “effective, proportionate and dissuasive”. The directive sets no amount. - **Length of the legal guarantee.** Two years is the minimum. The harmonised notice itself refers to the possibility that the guarantee is longer under national law. - **Wording and timing.** National laws do not always repeat the directive word for word. ## Working through the list Start with what shoppers see today. Open a discounted product, a product with variants, the cart, and the footer on a phone. Note where a reduction is announced without a prior price, whether the guarantee notice is there, and how many taps it takes to reach the withdrawal function. Then decide how each item will be kept up to date. Prices change, so the prior price is the one that needs a record behind it. You can do this by hand, with a script, or with an app. [The comparison of approaches](/compare) sets out the trade-offs. StoreCompliant is one option. It shows the [30-day lowest price](/features/30-day-lowest-price), the [legal guarantee notice](/features/legal-guarantee-notice) and the [withdrawal button](/features/withdrawal-button), and keeps the records. It is a compliance aid, not legal advice. Plans are on the [pricing page](/pricing) and common questions are in the [FAQ](/faq). ## Frequently asked questions **Do the EU rules apply to an online shop based outside the EU?** For the price reduction rule, the Commission’s guidance says Article 6a also applies to traders based outside the EU that direct their sales to EU consumers. The other duties sit in each Member State’s consumer law, so a shop that sells to consumers in a Member State should check that country’s rules. **Are all three display rules already in force in 2026?** The directives required Member States to apply their national measures from 28 May 2022 (price reductions), 19 June 2026 (withdrawal function) and 27 September 2026 (legal guarantee notice). Check how and when your own country has put them into national law. **Is there an exemption for small online shops?** The provisions quoted in this guide do not mention a size or turnover threshold. National law can treat some cases differently, so check the rules of the countries you sell to. **Where does the withdrawal button have to be placed?** The directive does not name a place on the page. It requires the function to be continuously available throughout the withdrawal period, prominently displayed on the online interface and easily accessible to the consumer. **Can I change the design or wording of the legal guarantee notice?** No. The Commission’s implementing regulation sets the design and content of the harmonised notice, and its annex states that none of the elements of the notice can be edited. **What are the fines for not following these rules?** The directives do not set amounts. For the price rule, Member States must lay down penalties that are effective, proportionate and dissuasive, so the figures and the authority in charge depend on the country. ## Official sources - [Directive (EU) 2019/2161 (Omnibus Directive), Article 2: new Article 6a of Directive 98/6/EC](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32019L2161) - [Commission Notice 2021/C 526/02: guidance on Article 6a of Directive 98/6/EC](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:52021XC1229(06)) - [Court of Justice, case C-330/23, Aldi Süd, judgment of 26 September 2024](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:62023CJ0330) - [Directive (EU) 2023/2673: new Article 11a of Directive 2011/83/EU (withdrawal function)](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32023L2673) - [Directive (EU) 2024/825: harmonised notice and label (Article 22a of Directive 2011/83/EU)](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32024L0825) - [Commission Implementing Regulation (EU) 2025/1960: design and content of the notice and the label](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32025R1960) - [Directive 2011/83/EU on consumer rights (original text)](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32011L0083) - [Regulation (EU) 2023/988 on general product safety](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32023R0988) --- General information, not legal advice.