Withdrawal button from 19 June: 3 steps to a legally sound implementation

For three years now, a mid-sized mechanical engineering supplier has been selling through its online shop not only to commercial customers but also to ambitious DIY enthusiasts. The sales director knows that from 19 June 2026 the withdrawal button will be mandatory for all B2C transactions. Anyone who ignores this requirement risks warning letters and fines. For manufacturers and wholesalers with hybrid business models this means checking now whether and how to integrate the withdrawal button into their online shops. This article shows you in three concrete steps how to plan, implement and document a legally sound solution – without unnecessary complexity.

Why the withdrawal button matters for B2B shops that also serve end customers

The new rule does not only affect classic B2C shops. Many manufacturers and wholesalers have widened their sales channels in recent years and now supply private customers or small businesses alongside commercial buyers. Whether tools, packaging material or technical components: as soon as end consumers can place orders in the shop, the right of withdrawal applies. By introducing the withdrawal button from 19 June 2026, the legislator has created an additional transparency obligation. Consumers are to be able to exercise their right of withdrawal more quickly and easily. For shop operators this means the button has to be clearly visible, unambiguously labelled and technically functional.

Imagine a customer orders a spare part late in the evening and wants to withdraw from the purchase the next morning. With the withdrawal button they can do that directly in their customer account, without an email or a phone call. At first sight that sounds like more work for the shop operator. In fact the automation eases the load on customer service and reduces the number of queries. What matters is this: anyone who ignores the obligation is in breach of applicable consumer law. The consequences are not only warning letters from competitors or consumer protection bodies, but also substantial fines. In 26 years of digital B2B sales, Commerce Partner has repeatedly seen legal requirements underestimated until the first warning letter arrives. At that point it becomes expensive and hectic.

The three steps to a legally sound integration of the withdrawal button

Implementing the withdrawal button can be broken down into three clear steps. Each step builds on the one before it and ensures that you are not only formally compliant but also able to act operationally.

Step 1: check your customer structure and product categories

Not every online shop is affected to the same degree. First check whether you handle B2C transactions at all. If you do: which product categories are affected? Are there exceptions to the right of withdrawal, for example for perishable goods or individually manufactured products? Document your customer structure and clarify internally which parts of the shop fall under the new rule. This step costs you one to two working days but saves effort and errors later on.

Step 2: technical implementation with Shopware 6.7.9.0 or comparable systems

Since the update, Shopware 6.7.9.0 has offered a native solution for the withdrawal button in the standard storefront. That means you do not have to buy an external extension or commission custom development. The button is displayed automatically in the customer account as soon as an order eligible for withdrawal exists. Users of other shop systems should check whether their provider also supplies a standard solution. If not, an extension or plugin is required. Make sure the button is configured in a legally sound way: an unambiguous label such as “Withdrawal”, clearly visible placement and a direct link to the withdrawal process. The technical effort comes to three to five working days, depending on how complex the system is.

Step 3: define processes and train your staff

A button alone is not enough. You need a clear process that governs what happens once the button has been used. Who handles the withdrawal request? How is the reversal documented? What deadlines apply to refunds? Define these processes in writing and train your team in customer service and logistics. A well-documented process does not only protect you legally, it also makes handling faster and customers more satisfied. Allow two to three working days for process definition and training.

A look at the ROI: the investment for all three steps comes to around six to ten working days, spread across IT, legal and customer service. A warning letter can quickly cost you EUR 1,000 to 3,000, and a fine can be considerably higher. The work therefore pays for itself with the first warning letter avoided.

Risk of fines and legal consequences if you do not act

Failing to observe the withdrawal button obligation is not a trivial matter. Consumer protection associations and competitors watch the market closely and issue warning letters for infringements. As a rule, the recipient bears the cost of a warning letter. On top of that come legal fees, contractual penalties and the internal effort of implementing the change retrospectively under time pressure. More serious still are fines imposed by the supervisory authorities. Depending on the severity of the infringement and the size of the company, these can run to several thousand euros.

From experience we know that many companies keep putting legal requirements off because they believe “this does not apply to us” or “nobody will notice anyway”. That is a fallacy. Manufacturers and wholesalers that have only recently started supplying end customers as well are often not on the legal department's radar. That is precisely where the risk lies. Acting now avoids fines and at the same time builds trust with your customers. A working withdrawal button signals professionalism and transparency. That pays off in the long run, particularly in a market where trust is a decisive competitive factor.

One further point: the burden of proof lies with the shop operator. You have to be able to demonstrate that the withdrawal button was correctly implemented and in working order. Document every step of the implementation: screenshots showing where the button is placed, process descriptions, training records. This documentation protects you in a dispute and shows that you have met your duty of care.

Conclusion: act now, stay on legally sound ground

From 19 June 2026 the withdrawal button is a new obligation for many manufacturers and wholesalers with an online shop. Anyone who acts now in three clear steps – check the customer structure, implement the button technically, define the processes – is on legally sound ground and avoids expensive warning letters. Shopware 6.7.9.0 offers a native solution, and the work involved is manageable. Do not ignore the obligation. The risks are real and the consequences are tangible.

Commerce Partner has been helping manufacturers and wholesalers build legally sound, scalable online shops since 1999. If you are unsure whether your shop is affected, or how to approach the implementation in practice, talk to us. We offer you a free 30-minute strategy call in which we analyse your situation and give you concrete recommendations for action. Arrange your appointment now at www.commerce-partner.com/kontakt.