Selling online to private individuals means entering one of the most regulated areas of consumer law. Many stores run on terms and conditions copied years ago, which do not reflect recent changes. Yet 2025 and 2026 brought three concrete changes in France: the end of the European online dispute resolution platform, an accessibility obligation for some online retailers and, above all, since 19 June 2026, a mandatory online withdrawal function.
Here is the full tour, following a customer's journey: what must be displayed before the order, at the time of ordering, and afterwards. Each point refers to the corresponding text.
Before the order: what the site must display
Who you are
Article 19 of the French law on confidence in the digital economy (LCEN) requires “easy, direct and permanent access” to your identity: name or company name, address, email address and telephone details that actually make it possible to reach you, registration number, share capital and registered office if registered, and VAT number where applicable. Add to this the notices under article 1-1 of the LCEN, including the host and the publication director. We have set out the full list by status in our article on legal notices.
Clear prices
The same article 19 requires every price to be stated “clearly and unambiguously”, specifying in particular whether taxes and delivery costs are included. A price shown without delivery costs and without saying so, or costs that only appear at the last step, are a problem.
Pre-contractual information and terms and conditions
Before the customer commits, the French Consumer Code (article L221-5) requires a series of information to be provided legibly and understandably: essential characteristics of the product, price, delivery and performance terms, the conditions, time limit and procedure for exercising the right of withdrawal together with the standard withdrawal form, legal guarantees, and so on. In practice, this information is spread across product pages, the checkout and the terms and conditions of sale, which the official Entreprendre.service-public.gouv.fr page says must be displayed on the site when selling to consumers.
Article L221-14 adds two requirements specific to online stores: clearly indicate, at the latest at the start of the ordering process, the accepted payment methods and any delivery restrictions.
At the time of ordering: the “order with obligation to pay” button
This is an old obligation that is still poorly applied. Article L221-14 of the Consumer Code requires, just before confirmation, a clear and understandable reminder of the essential characteristics of what is being ordered, the price and, where applicable, the duration of the contract. It then requires the customer to explicitly acknowledge their obligation to pay: the function used to confirm the order must bear the clear and legible words “commande avec obligation de paiement” (order with obligation to pay) or an equivalent, unambiguous wording.
A “Confirm” or “Continue” button does not meet this requirement. “Pay now” or “Order and pay” are commonly used equivalent wordings, but the safest remains the one in the text.
The right of withdrawal: 14 days, and a new button since June 2026
The time limit
Under article L221-18, consumers have fourteen days to withdraw from a distance contract, without giving reasons and without paying costs other than those provided by law. The period runs from the conclusion of the contract for services, and from receipt of the goods for a sale. The day of conclusion or receipt is not counted (article L221-19).
Watch the information requirement: if the customer was not informed of the right of withdrawal as required by law, the period is extended by twelve months from the end of the initial period (article L221-20). If the information is provided along the way, the customer then has fourteen days from receiving it.
There are exceptions, listed in article L221-28 of the Consumer Code: notably goods made to the consumer's specifications or clearly personalised, and goods liable to deteriorate or expire rapidly. If you sell such products, your terms must say so clearly.
The new withdrawal function (19 June 2026)
This is the year's major change. Ordinance no. 2026-2 of 5 January 2026, which transposes Directive (EU) 2023/2673, amended article L221-21 of the Consumer Code. Since 19 June 2026, for distance contracts concluded through an online interface, the professional must make available to the consumer, free of charge, a function allowing them to exercise their right of withdrawal online before the period expires.
Decree no. 2026-3 of 5 January 2026 sets out the details, in article D221-5 of the Consumer Code:
- The function is legibly identified by the words “renoncer au contrat ici” (withdraw from the contract here) or an equivalent, unambiguous wording.
- It is displayed visibly, is directly and easily accessible, and remains available throughout the withdrawal period.
- It allows the consumer to send their withdrawal statement, giving in particular their name, details identifying the contract concerned and how they wish to receive the acknowledgement.
- The statement is confirmed with a button identified by the words “confirmer la rétractation” (confirm withdrawal) or an equivalent wording.
- The professional then sends an acknowledgement on a durable medium, repeating the content of the statement and the date and time it was sent.
Contracts in progress on 19 June 2026 remain governed by the previous rules. But any order placed since then must be open to withdrawal this way. In practice, this means a visible link, for example in the customer account and in the order confirmation email, to a form that can be reached directly. A simple “write to customer service” is no longer enough.
The refund
When the customer withdraws, article L221-24 requires you to refund all sums paid, including delivery costs, without undue delay and at the latest within fourteen days of being informed of the decision. For a sale of goods, the refund can be deferred until the goods are recovered or until the customer provides proof of dispatch. The customer returns the goods within fourteen days of withdrawing, and only bears the direct cost of returning them, unless you agree to cover them or failed to inform the customer that they are payable (article L221-23).
Two details of the same article are often overlooked. First, the refund must be made using the same means of payment as the original order, unless the customer expressly agrees to another method, and provided it costs them nothing: an imposed store credit does not meet this rule. Second, you do not have to refund additional costs if the customer expressly chose a more expensive delivery method than the standard one you offered. You then refund the equivalent of standard delivery.
After the order: guarantees and disputes
The legal guarantee of conformity
Every item sold to a consumer benefits from the legal guarantee of conformity, set out in articles L217-1 et seq. of the Consumer Code. According to the official service-public.gouv.fr page:
- It lasts 2 years from delivery of the goods.
- A defect appearing within 24 months (new goods) or 12 months (second-hand goods) is presumed to have existed at delivery: it is up to the seller to prove otherwise.
- The customer can obtain repair or replacement of the goods within 30 days of the request. If that is impossible, or causes major inconvenience, they can obtain a price reduction or cancellation of the contract.
This guarantee is mandatory: no clause in your terms and conditions can exclude it, and it must be presented there.
The consumer mediator
Every consumer has the right to use a consumer mediator free of charge (article L612-1), and the professional must guarantee effective access to one. You must therefore join a mediation scheme and provide the contact details of the mediator(s) you fall under (article L616-1). Article R616-1 specifies that this information must appear visibly and legibly on the website, in the terms and conditions and on order forms, together with the mediator's website address. Failing to provide this information can lead to an administrative fine of up to 3,000 euros for a natural person and 15,000 euros for a legal person (article L641-1).
The end of the European ODR platform
For years, online retailers had to display a link to the European online dispute resolution platform (ODR). Regulation (EU) 2024/3228 of 19 December 2024 abolished it: complaints could no longer be filed from 20 March 2025, and the platform closed for good on 20 July 2025. That link therefore no longer belongs in your terms and conditions or legal notices. If it is still there, it is also a good sign that your terms date from before 2025 and deserve a full review. The consumer mediation obligation remains fully in force.
Accessibility, for stores that are not micro-enterprises
Since 28 June 2025, e-commerce services aimed at consumers must be accessible to people with disabilities, except for micro-enterprises (fewer than 10 people, and at most 2 million euros in turnover or balance sheet total). We have written a full article on this accessibility obligation, the exact thresholds and the penalties.
Personal data and cookies
An online store inevitably collects data: customer account, delivery address, order history. The GDPR requires customers to be informed (purposes, legal basis, retention period, recipients, rights, the right to complain to the CNIL). For cookies, the CNIL points out that prior consent is the rule, except for strictly necessary trackers such as those for the shopping basket or authentication, and that refusing must be as easy as accepting. Advertising and conversion-tracking tools, common in e-commerce, generally require consent.
What if you sell to businesses?
Everything above, including the right of withdrawal and the withdrawal function, protects the consumer. A store selling exclusively to businesses is not subject to these rules in the same way. It has its own obligations: according to the official Entreprendre.service-public.gouv.fr page, business-to-business terms and conditions do not have to be displayed, but they must be provided to any business buyer who asks for them, under penalty of a fine. If you sell to both audiences, you need to separate the journeys clearly, or apply the consumer-protection rules by default.
Frequently asked questions
Does the withdrawal function also apply to services?
Yes. Article L221-21 covers distance contracts concluded through an online interface, without distinguishing between sales of goods and services. A booking or subscription taken out online by a consumer is covered.
I also sell by phone or in a shop: do I need the button everywhere?
The obligation covers contracts concluded through an online interface, meaning your website or app. A contract concluded by phone remains subject to the standard right of withdrawal, and an in-store sale does not, as a rule, give rise to a legal right of withdrawal.
Does my store software already provide this function?
It depends on the solution and its version. Check in practice: is the “renoncer au contrat ici” wording visible from the customer account without going through customer service, does the form ask for the required information, and is an acknowledgement sent automatically? If any answer is no, it needs to be completed.
Your store's compliance checklist
- Complete, up-to-date legal notices (LCEN articles 1-1 and 19).
- Clear prices, with taxes and delivery costs specified.
- Payment methods and delivery restrictions shown at the start of the ordering process.
- A summary before confirmation, and a “commande avec obligation de paiement” button or equivalent.
- Accessible terms and conditions of sale, including the right of withdrawal, the standard form and the legal guarantees.
- A “renoncer au contrat ici” function visible throughout the withdrawal period, with confirmation and an acknowledgement on a durable medium.
- A refund process within 14 days, including original delivery costs.
- Membership of a consumer mediation scheme, with contact details shown on the site.
- No remaining link to the former European ODR platform.
- A compliant privacy policy and cookie management.
- An accessible purchase journey if you are not a micro-enterprise.
Launching your online store or want to bring yours up to date? Let's talk: the first conversation is free.
Sources
- French Consumer Code, article L221-14 (Légifrance, in French)
- French Consumer Code, articles L221-18 to L221-28, version in force on 19 June 2026 (Légifrance, in French)
- French Consumer Code, article L221-21 and article D221-5 (Légifrance, in French)
- French Consumer Code, article L616-1, R616-1 and L641-1 (Légifrance, in French)
- Legal guarantee of conformity (service-public.gouv.fr, in French)
- Regulation (EU) 2024/3228 of 19 December 2024 (EUR-Lex)
- Law no. 2004-575 of 21 June 2004 (LCEN), article 19 (Légifrance, in French)
