Starting on 19 June 2026, new requirements regarding the statutory right of withdrawal (cancellation right) will come into effect for many online retailers. Operators of Shopware stores should review whether their existing processes comply with the current legal requirements.
In addition to a transparent cancellation policy, technical features such as a cancellation button and a digital cancellation form may become mandatory to make it easier for consumers to exercise their right of withdrawal.
The key question is not only whether you sell online, but also to whom you sell, what type of contract is involved, and whether a statutory right of withdrawal exists at all.
For purely B2C online contracts concluded via an online user interface, an electronic withdrawal function (“cancellation button”) will become mandatory from 19 June 2026. The model cancellation form remains an important consumer information document and must be provided before the contract is concluded whenever a right of withdrawal exists.
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Legal Logic in One Sentence
The cancellation button is mandatory whenever a business concludes distance-selling consumer contracts through a website or app and those contracts are subject to a statutory right of withdrawal. The cancellation form is not an additional mandatory clickable feature but rather an information and model form that must be made available to the consumer before submitting their declaration, provided a right of withdrawal exists.
Detailed Checklist
| Business Situation / Product Range | Cancellation Button Required? | Cancellation Form Required? | Reason / Special Consideration |
| Pure B2C online store selling goods via website/app | Yes | Yes, as a model form provided before order submission if a withdrawal right exists | Classic use case of the new withdrawal function for online distance-selling contracts with consumers. |
| Mixed B2B/B2C store | Yes, as soon as consumers can also purchase | Yes, for consumer contracts | Even the possibility of concluding a consumer contract triggers the obligation; a purely B2B structure is sufficient only if sales are exclusively to businesses. |
| Pure B2B store | No | Generally no | Without consumer contracts, there is generally no statutory right of withdrawal; therefore, no button obligation applies. |
| Lead generation or quotation portal where contracts are concluded later offline or through individual communication | Generally no, if no online distance-selling contract is concluded | Only if a consumer contract is concluded online | The decisive factor is online contract conclusion through a user interface, not merely online initiation. |
| Digital content sold to consumers online | Yes, if a withdrawal right exists and the contract is concluded online | Yes, if a withdrawal right exists | The obligation may apply to digital services; however, the withdrawal right may lapse if downloading/streaming has begun with valid consent and acknowledgment. |
| Digital services / subscriptions for consumers | Yes | Yes, if a withdrawal right exists | The obligation applies not only to goods but also to online consumer service contracts. |
| Financial services offered online to consumers | Yes | Yes, if a relevant withdrawal right exists | This contract type is also explicitly mentioned in practical legal guidance. |
| Products manufactured according to customer specifications / custom-made / personalized products | No, if the statutory withdrawal right is validly excluded | No mandatory form for these excluded contracts | Correct: genuine custom-made or highly personalized products may be exempt from withdrawal rights. |
| Selection from standard options such as color, size, or material from a predefined catalog | Usually yes | Yes, if a withdrawal right exists | Configuration from predefined options generally does not constitute personalization in the legal sense. |
| Printing with photo, name engraving, custom-tailored clothing, genuine custom-made products | No, if the product is practically unsellable to others and the exemption applies | No | This typically qualifies as customer specification or clear personalization. |
| Perishable food products with short shelf life | No, if the statutory exemption applies | No | Quickly perishable goods may be exempt; not every food product automatically qualifies. |
| Sealed hygiene products that cannot be returned after opening | No, if the legal exemption applies | No | The exemption applies only under strict conditions, especially when the seal has been opened and hygiene or health protection concerns are involved. |
| Regular cosmetics, shampoo, everyday consumer goods | Usually yes | Yes, if a withdrawal right exists | Not every cosmetic product is automatically exempt; returnability and sealing are decisive factors. |
| Sealed data carriers after opening | No | No | The withdrawal right may lapse once the seal is broken. |
| Fast-consumption standard goods without exemption grounds | Yes | Yes | The button requirement is the standard case for online B2C sales; exemptions must be interpreted narrowly. |
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When You Need the Button
You should plan to implement the cancellation button if:
- Consumers are among your customers.
- The contract is concluded online through a store, app, or platform.
- The contract is not exempt from the statutory right of withdrawal.
The obligation applies regardless of company size or revenue. Even a small niche store falls within its scope if it sells to consumers.
When You Do Not Need the Button
You do not need a cancellation button for:
- Genuine B2B-only stores with no consumer transactions.
- Contracts concluded offline.
- Contract types for which the statutory right of withdrawal is excluded from the outset.
This primarily concerns genuine custom-made products, highly personalized goods, perishable products, and certain sealed hygiene products after opening.
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Proper Classification of the Cancellation Form
The model cancellation form is not simply optional. It forms part of the legally required consumer information whenever a right of withdrawal exists and must be made available to the consumer in a clear and understandable manner before they submit their contractual declaration.
However, consumers are not required to use this form. They may exercise their withdrawal right through other means.
If you additionally provide an electronic form and the consumer uses it, receipt must be confirmed without undue delay.
Practical Assessment for Shopware Projects
For Shopware operators, the decision can be modeled technically as follows:
- B2C active = Check whether a cancellation button is required.
- B2B only = Button usually not required.
- Only custom-made products = Button usually not required.
- Mixed product range = Button should generally be implemented.
In practice, the safest solution is often to visibly implement the cancellation button whenever any part of the product range or contractual transactions falls under consumer withdrawal rights.
For stores using product configurators, it is important to distinguish between simple option selection and legally relevant personalization.
Implementation Checklist
- Verify whether the store targets consumers.
- Verify whether the contract is concluded through the online interface.
- Verify whether the withdrawal right is legally excluded.
- Verify whether the store is B2B-only or serves both B2B and B2C customers.
- Integrate the model cancellation form and cancellation policy before order submission.
- Implement the cancellation button so that it is easy to find during the withdrawal period, clearly labeled, and directly usable.
- For configurators, always determine whether the customer merely selects options or creates a genuinely personalized product.
Shopware 6 Decision Matrix
| Product Range | Customer Type | Contract Type | Exemption | Button Required | Form Required | Risk Level | Technical Implementation in Shopware 6 |
| Standard products without personalization | B2C | Distance-selling contract via store | No exemption | Yes | Yes | High if missing | Integrate the cancellation button in the footer, customer account area, and a central cancellation page; provide links to the cancellation form and make it accessible during checkout. |
| Standard products with variants such as color, size, material | B2C | Distance-selling contract via store | No exemption if no genuine personalization exists | Yes | Yes | High | Do not confuse variant selection with personalization; legally these are standard products, so cancellation pages and buttons must be enabled. |
| Genuine custom-made or customer-specific production | B2C | Distance-selling contract | Withdrawal right excluded if requirements are met | No | No | Medium, as distinctions are often disputed | Product labeling and processes should clearly document personalization; legal texts should clearly define the exemption. |
| Personalized goods with name, photo, or engraving | B2C | Distance-selling contract | Exemption often possible if truly individualized | Usually no | Usually no | Medium to high | Clearly indicate personalization on the product detail page; verify whether it is mere personalization or a genuine custom-made product. |
| Configurator with fixed catalog options | B2C | Distance-selling contract | No exemption if only standard options are selected | Yes | Yes | High | Do not treat the configurator as an exemption; implement cancellation button and form obligations normally. |
| Hygiene products, sealed and non-returnable after opening | B2C | Distance-selling contract | Exemption only under strict legal conditions | Usually yes until the exemption applies | Usually yes | High | Mark exceptions only for affected products; do not exclude the entire store. |
| Perishable goods | B2C | Distance-selling contract | Withdrawal right excluded if legal requirements are met | No | No | Medium | Properly segment product categories in the backend and apply different treatment only to exempt products. |
| Digital content without physical medium | B2C | Online contract | Withdrawal right may lapse if immediate performance begins with proper consent | Depends on setup | Depends on setup | High | Properly obtain consent and acknowledgment before contract conclusion; document release logic in checkout. |
| Digital services or subscriptions | B2C | Online contract | Generally no exemption | Yes | Yes | High | Implement cancellation page and form by default; prepare processes for receipt and confirmation of withdrawals. |
| Pure B2B store | B2B | Business-to-business sales contract | No consumer withdrawal rights | No | No | Medium, as confusion with B2C can be costly | Configure Shopware consistently for B2B; use login or approval processes and avoid B2C checkout. |
| Mixed B2B/B2C store | Both | Depends on customer | Only B2B contracts are exempt | For B2C: Yes | For B2C: Yes | High | Clearly separate customer types during checkout; apply exemptions only to genuine B2B accounts. |
| Quotation process followed by manual contracting | B2C | Not a pure online-store contract | Depends on how the contract is concluded | Generally no if no online contract is formed | Only if a withdrawal right exists | Medium | Verify whether the contract is actually concluded online; do not assume a blanket button obligation. |
| Marketplace seller with own consumer contracts | B2C | Distance-selling contract | No exemption | Yes | Yes | High | Ensure withdrawal information at seller level; review platform logic and legal texts separately. |
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WebiProg Integrates Cancellation Buttons and Cancellation Forms into Shopware
WebiProg GmbH supports Shopware merchants in the legally compliant implementation of statutory withdrawal requirements effective from 19 June 2026.
Our experienced team analyzes your existing store, develops a suitable technical solution, and seamlessly integrates both the cancellation button and the cancellation form into your Shopware environment.
We focus not only on technical implementation but also on usability, responsive design, and compatibility with existing plugins and custom Shopware extensions. This ensures you receive a future-proof and legally compliant solution from a single source.
With WebiProg as Shopware Agency, you benefit from many years of experience in developing Shopware stores, custom plugins, and e-commerce solutions for businesses of all sizes.
Feel free to contact us for a non-binding consultation regarding the implementation of the new withdrawal requirements in your Shopware store.
Alex Samoylenko
Oleksii Samoilenko has been working in the IT industry since 2004 and possesses extensive experience in e-commerce (B2C and B2B), SEO, online marketing, conversion optimization, and digitalization.
As the Managing Director of WebiProg GmbH, he guides companies on their path toward digital transformation and develops sustainable strategies for successful online projects. His blog articles provide practical insights, in-depth expertise, and valuable tips for optimizing online shops and digital business processes.
