E-Commerce
Order button labeling, withdrawal rights, pricing rules, and consumer protection.
Running an online shop in the EU means meeting the requirements of the Consumer Rights Directive, the Omnibus Directive, and country-specific distance selling laws. Your checkout process, pricing display, return policy, and order button text all have legal requirements. The most common issues: not clearly labelling the order button as a payment obligation, not showing the lowest price from the past 30 days on discounted items, and not providing pre-contractual information before checkout.
Key facts
- •EU law requires the order button to clearly indicate a payment obligation — 'Order' alone is not sufficient in Germany
- •The Omnibus Directive (2022) requires showing the lowest price from the past 30 days for any discounted product
- •Customers have a 14-day withdrawal right for most online purchases, and must be informed before checkout
- •Price display must include VAT in all B2C transactions — showing ex-VAT prices first is prohibited
- •The EU's cross-border enforcement network (CPC) coordinated action against 118 online shops in 2024 for pricing violations
What we check
- ✓Order button labelling requirements
- ✓Withdrawal/return policy presence and completeness
- ✓Price display including VAT
- ✓Pre-contractual information before checkout
- ✓Payment method information and security
E-commerce checkout: good vs. bad examples
Vague order button text
A checkout button that says "Continue" or "Complete order" without clearly indicating a payment obligation. In Germany, courts have ruled that the button must explicitly state that clicking it creates an obligation to pay.
Clear payment obligation button
A checkout button that reads "Buy now" or "Order and pay" (or the German equivalent "Zahlungspflichtig bestellen"). This makes the payment obligation unmistakable and satisfies EU Consumer Rights Directive Article 8(2).
Fake discount pricing
Showing "Was €49, now €29" when the product was never actually sold at €49. The Omnibus Directive requires that discounted prices show the lowest price from the previous 30 days.
Honest price history
Showing "€29 (lowest price in last 30 days: €35)" next to discounted products. This complies with the Omnibus Directive and builds customer trust through transparent pricing.
Hidden withdrawal rights
Burying the 14-day return policy in the terms and conditions instead of showing it clearly before checkout. EU law requires that customers are informed about withdrawal rights before placing an order.
Withdrawal info before checkout
A visible section before the payment step explaining: "You have 14 days to return this product without giving a reason. Returns are free." This satisfies pre-contractual information requirements.
Prices shown without VAT
Displaying product prices excluding VAT and only adding it at checkout. In B2C transactions, all displayed prices must include VAT. Showing ex-VAT prices first misleads consumers.
VAT-inclusive pricing throughout
All product pages and listings show prices including VAT with a note: "All prices include VAT." Shipping costs are shown separately but clearly before checkout begins.
Vague order button text
A checkout button that says "Continue" or "Complete order" without clearly indicating a payment obligation. In Germany, courts have ruled that the button must explicitly state that clicking it creates an obligation to pay.
Fake discount pricing
Showing "Was €49, now €29" when the product was never actually sold at €49. The Omnibus Directive requires that discounted prices show the lowest price from the previous 30 days.
Hidden withdrawal rights
Burying the 14-day return policy in the terms and conditions instead of showing it clearly before checkout. EU law requires that customers are informed about withdrawal rights before placing an order.
Prices shown without VAT
Displaying product prices excluding VAT and only adding it at checkout. In B2C transactions, all displayed prices must include VAT. Showing ex-VAT prices first misleads consumers.
Clear payment obligation button
A checkout button that reads "Buy now" or "Order and pay" (or the German equivalent "Zahlungspflichtig bestellen"). This makes the payment obligation unmistakable and satisfies EU Consumer Rights Directive Article 8(2).
Honest price history
Showing "€29 (lowest price in last 30 days: €35)" next to discounted products. This complies with the Omnibus Directive and builds customer trust through transparent pricing.
Withdrawal info before checkout
A visible section before the payment step explaining: "You have 14 days to return this product without giving a reason. Returns are free." This satisfies pre-contractual information requirements.
VAT-inclusive pricing throughout
All product pages and listings show prices including VAT with a note: "All prices include VAT." Shipping costs are shown separately but clearly before checkout begins.
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