Withdrawal Button from June 2026: What Shopware Merchants Need to Know and Implement Now
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From 19 June 2026, a classic withdrawal notice in an online shop will no longer be sufficient. Merchants must provide their customers with an electronic withdrawal function – the so-called withdrawal button. In future, cancelling a contract should be just as easy as concluding it. For Shopware merchants, this means: plan in good time, update, and implement the entire process properly.
We explain the background to the regulation, which requirements apply, and what you specifically need to do.
The key facts at a glance
Deadline: 19 June 2026
Legal basis: New § 356a BGB (EU Directive 2023/2673)
Affected: All B2C online shops – regardless of size or turnover
Fines: Up to €50,000 or 4% of annual turnover
Shopware solution: Native feature from version 6.7.9.0 (April 2026), backport to 6.6
Why is the withdrawal button coming?
Concluding a contract online today takes just a few clicks. Withdrawing from it, on the other hand, is often cumbersome: writing emails, downloading PDF forms, searching for contact forms. That is set to change.
On 30 January 2026, the Bundesrat passed the "Act Amending Consumer Contract and Insurance Contract Law". It was published in the Federal Law Gazette on 5 February 2026. The legal basis is the new § 356a BGB, with which Germany transposes EU Directive (EU) 2023/2673 into national law.
The core: in future, consumers should be able to exercise their right of withdrawal electronically and directly in the online shop – without additional hurdles. The existing right of withdrawal remains in place, but the way it is exercised is being digitised and standardised.
Who is affected by the obligation?
The new obligation applies to all distance contracts concluded via an online user interface – i.e. via websites, apps or other digital platforms. You are affected if you:
- Sell goods to consumers in your online shop (classic B2C distance selling)
- Offer digital services or content (e-books, online courses, streaming)
- Operate a platform with subscriptions or recurring services
Important: There are no exceptions based on company size, turnover or number of employees. Whether a small niche shop or a large marketplace merchant – anyone who sells online to consumers must offer the withdrawal button.
Not affected:
- Pure B2B shops – but only if they are actually cleanly restricted to business customers. As soon as consumers can place orders, the right of withdrawal applies.
- Mixed B2B/B2C shops are obliged to offer the button for the B2C area.
- Contracts without a statutory right of withdrawal under § 312g BGB – such as individually manufactured products, sealed hygiene articles after opening, or digital content after the start of performance with consent.
- Distance contracts concluded by telephone, order card or fax.
Practical note: Check not only your main shop, but all online sales channels – sub-shops, brand stores, booking portals and international storefronts.
What must the withdrawal button be able to do?
The law prescribes a clearly defined, two-step process.
Step 1: The entry point – "Withdraw from contract"
The consumer must be able to enter the withdrawal process via a clearly labelled function. The requirements in detail:
- Label: "Withdraw from contract" or an equivalent, unambiguous wording. Misleading labels such as "Service request" or "Contact" are not permitted.
- Visibility: Easily legible, prominently placed and easily accessible. The path to withdrawal must not be more complicated than the one to the purchase button.
- Availability: Permanently available on the website throughout the entire withdrawal period.
- Without login: The button must also be accessible to guest buyers without a customer account – this is legally required.
In the form, the consumer can provide the following information:
- Identification of the contract (e.g. order number)
- Email address for the confirmation of receipt
Caution: No further information – in particular regarding the reason for withdrawal – may be requested. This would be considered as making withdrawal more difficult.
Step 2: The confirmation – "Confirm withdrawal"
After entering the data, all details are summarised. The consumer confirms their withdrawal via a second button labelled "Confirm withdrawal" or an equivalent wording. Only with this click does the withdrawal become legally effective.
Confirmation of receipt
After submitting the withdrawal, the merchant must immediately provide a confirmation of receipt on a durable medium (typically by email). This must contain: the content of the withdrawal declaration as well as the date and time of receipt. The legislator clarifies that the declaration is deemed to have been received in time if it was submitted within the deadline via this function.
The process at a glance
Step | Action | Details |
|---|---|---|
1 |
"Withdraw from contract" button |
Visible in the footer, customer account & order details – even without login |
2 |
Form: order number + email |
No further information allowed – do not ask for a reason for withdrawal! |
3 |
Confirmation "Confirm withdrawal" |
Summary of all details – the withdrawal only becomes effective upon clicking |
4 |
Confirmation of receipt by email |
Immediately, with content, date & time of the withdrawal |
What are the penalties for violations?
Anyone who fails to implement the requirements on time must expect significant consequences:
Risk | Consequence |
|---|---|
Fines |
Up to €50,000 or 4% of annual turnover |
Warning notices (Abmahnungen) |
Competition law violation – associations and law firms check systematically |
Extended withdrawal period |
Up to 12 months and 14 days instead of the usual 14 days |
Experience shows that consumer protection associations and specialised law firms begin to check such violations early and systematically – similar to imprint, cookie banners and GDPR notices. Waves of warning notices do not come at some point – they come early.
Typical mistakes during implementation
A common mistake will be to install the button only symbolically, without actually reflecting the statutory process. Pay particular attention to these pitfalls:
Mistake | Why is it problematic? |
|---|---|
Contact form instead of withdrawal function |
A simple contact form or mailto link is not sufficient – the two-step process is missing. |
Placement too hidden |
Only hidden deep in the footer or behind several clicks = violation of easy accessibility. |
Only visible after login |
Guest buyers must be able to use the button. Without guest access = acute risk of warning notices. |
Missing confirmation of receipt |
Without immediate confirmation by email, a central part of the legal obligation is missing. |
No internal documentation |
Withdrawals that are not processed properly lead to organisational and legal problems. |
Not just the button: adapting legal texts and privacy policy
The technical implementation alone is not sufficient. From 19 June 2026, your legal texts must also be updated.
Withdrawal notice
The statutory sample withdrawal notice will be supplemented with a reference to the online withdrawal function. The new design note reads, in essence:
"You can also exercise your right of withdrawal online at [internet address of the withdrawal function]. If you use this online function, we will promptly send you a confirmation of receipt on a durable medium (e.g. by email) with information on the content of the withdrawal declaration as well as the date and time of its receipt."
No merchant may still be online with the old version of their withdrawal notice from 19 June 2026.
Privacy policy
The processing of data as part of the withdrawal process is an additional data processing activity that must be included in your privacy policy together with its purpose and legal basis.
Review standard emails
Order confirmations, shipping confirmations and the new withdrawal confirmation should also be reviewed and, if necessary, supplemented.
Tip: Coordinate the new texts with your legal service provider – e.g. Händlerbund, Trusted Shops, IT-Recht-Kanzlei or eRecht24.
Implementation in Shopware 6
Shopware integrates a complete, two-step withdrawal procedure directly into the core. In future, customers will be able to submit their withdrawal electronically via an online form – analogous to the existing contact form. The solution can be flexibly placed in the shop as a CMS element via the Shopping Experiences. A backport to Shopware 6.6 is also available. The feature is a free part of the Community Edition. Learn more about Shopware 6.7.9.0 in our detailed article on the Shopware 6 updates
Differences depending on the frontend setup
Setup | Effort |
|---|---|
Standard storefront |
Manageable – the integration takes place largely automatically through the update. Agencies and theme developers should ensure that the button does not "disappear" in custom themes due to layout adjustments. |
Individual theme |
Medium effort – the button must be integrated at the right places in your own template and tested. |
Headless / Composable |
Higher effort – Shopware provides the backend logic, but the frontend integration must be implemented project-specifically. Integrations with ERP and service tools should process withdrawals automatically. |
What Shopware does not solve automatically
Even with the native solution, there are points that merchants must address themselves:
- Deadline check: Whether a withdrawal was received within the deadline must be checked on a case-by-case basis manually or via custom logic.
- Product exceptions: Whether the specific product can even be withdrawn from (e.g. custom-made goods) requires manual review.
- ERP connection: The automatic status change of an order upon withdrawal – e.g. in Xentral, Pickware or other ERP systems – usually requires custom development or plugin adaptations.
Plugins and third-party solutions
Specialised extensions that provide the withdrawal button already exist in the Shopware Store – for example with guest access, captcha protection, Flow Builder integration and automatic confirmation emails. If you do not want to wait for the official release or need additional features, a plugin can be a sensible solution. Make sure that the plugin is explicitly designed for the new obligation under § 356a BGB and is regularly updated.
Special case: Shopware 5
No official update available. For merchants still working on Shopware 5, there is no official solution. Shopware 5 is in end-of-life status and no longer receives functional updates.
You must either have an individual solution developed or take the deadline as an opportunity to seriously tackle the migration to Shopware 6. At the latest with the withdrawal button obligation, it becomes clear that operating a Shopware 5 shop increasingly entails legal and technical risks.
If you are planning a migration, contact us early – this way the withdrawal button can be cleanly integrated directly as part of the migration project.
Your checklist: how to prepare
No. | Measure |
|---|---|
1 |
Check whether you are affected: Do you sell to consumers (B2C or mixed)? Record all sales channels – main shop, sub-shops, international stores, booking pages. |
2 |
Check your Shopware version: Plan the update to 6.7.9.0 as soon as it is available (April 2026). For 6.6, the backport is supported. Use a staging system for testing. |
3 |
Evaluate your frontend setup: Standard storefront, custom theme or headless? The development effort differs considerably depending on the setup. |
4 |
Define UX and placement: Footer (for all visitors, even without login), customer account, order detail page. Sketch the flow: button → form → confirmation → email. |
5 |
Update legal texts: Adapt the withdrawal notice, sample withdrawal form and privacy policy. Have them reviewed by a legal service provider. |
6 |
Ensure guest access: Withdrawal must be possible without login. This is legally required and one of the most common warning-notice traps. |
7 |
Clarify internal processes: Who handles withdrawals? How are the warehouse, accounting and customer service informed? Train the service team. |
8 |
Check ERP and system integration: Automatic status change in Xentral, Pickware or another ERP? Test interfaces to the inventory management system and shipping service providers. |
9 |
Test: Check the entire process – logged in and as a guest, on desktop and mobile. Also test the case "withdrawal period expired". Check confirmation emails and back-office processing. |
10 |
Don't wait until June! Experience shows that waves of warning notices come early. Those who plan in good time save costs, avoid time pressure and stay in control. |
Conclusion: use the obligation as an opportunity
The withdrawal button is more than just another regulatory obligation. It represents a development towards more transparency and stronger consumer rights in online commerce – and it is an opportunity: a clear, transparent withdrawal process signals professionalism, strengthens customer trust and can reduce support queries.
With version 6.7.9.0, Shopware provides a solid foundation. But depending on the shop setup – custom theme, headless architecture, ERP connection – there is a need for action that goes beyond a simple update. Those who take the obligation seriously, act in good time and integrate the process cleanly into UX, legal texts and systems are not only legally compliant but also positively differentiate themselves from the competition.
Our advice: Don't wait until June. Start planning now. As a certified Shopware agency, we are happy to support you with the technical implementation, coordination with your ERP system and preparing your shop for the new requirements.
Would you like to prepare your shop for the new obligation?
We support you with the technical implementation, the ERP connection and coordination with your legal service provider.
→ Request a non-binding consultation now
Note: This article serves as professional orientation and does not replace individual legal advice. We recommend coordinating the specific implementation with a specialised legal service provider.
Sources and further information:
- Shopware: Withdrawal button obligation 2026 – Official statement and technical roadmap
- eRecht24: Withdrawal button – what online shops need to know
- IHK Hannover: Withdrawal button comes from June 2026
- IT-Recht-Kanzlei: Withdrawal button – new legal texts required
- Datenschutz-Generator: Large FAQ on the withdrawal button 2026
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