MageMe EU Withdrawal | Legal & Merchant Responsibility
This page describes the regulatory context the module is built for, the boundaries of what it does for you, and the work that remains the merchant's responsibility. Read it before you enable the module in production.
What this module is for
The module implements the workflow defined in Article 11a of Directive 2011/83/EU (the Consumer Rights Directive), as amended by Directive (EU) 2023/2673.
Article 11a requires traders selling at a distance to EU consumers to provide a clearly visible, easy-to-find online function that consumers can use to declare withdrawal from a contract, plus a durable-medium acknowledgement of that declaration. The withdrawal period is 14 days from delivery for goods (Art. 9(2)) and from conclusion for services or digital content, subject to exclusions in Article 16.
The merchant deadline for compliance is 19 June 2026.
AS-IS disclaimer
This module is a technical implementation aid, not legal advice.
It has not been reviewed by EU consumer-law counsel. MageMe does not warrant specific legal outcomes. Any administrative, civil, or criminal penalties imposed by a national authority remain the merchant's responsibility. Provided AS-IS under the MageMe End User License Agreement.
Button labels, Annex I disclosure text, and exclusion presets bundled with the module are based on publicly available transpositions of Directive 2011/83/EU and Directive (EU) 2023/2673 as of April 2026. National legislation, regulatory guidance, and case law evolve. Review applicable law at least annually and whenever a national regulator publishes new guidance.
If you operate in a high-value or sector-specific compliance context — financial services, regulated medicines, alcohol or other age-restricted goods, B2B with consumer crossover, or sales to consumers outside the EEA — engage qualified legal counsel before relying on this module in production.
Out of scope — streaming and SaaS subscriptions
If you sell subscription digital services affected by the Sky Österreich v VKI line of case law (CJEU C-234/25), the Article 16(m) waiver flow this module provides may not eliminate the customer's right of withdrawal.
The module's waiver is designed for one-time digital content purchases — extensions, ebooks, courses, software licences, downloadable templates. It is not a subscription cancellation flow. For recurring billing, mid-cycle pro-rata refunds, and dunning, use the cancellation flow your billing platform already ships:
These platforms have battle-tested, counsel-reviewed flows for this scenario. Layering this module on top is not a substitute.
National variations
The Directive sets the floor. Member States are free to transpose stricter requirements, and several already have. The table below lists the four highest-risk EU markets for Magento merchants. If you ship to any of them, treat the row as a separate compliance review item.
| Member State | Transposing law | In force | What's specific |
|---|---|---|---|
| 🇩🇪 Germany | §356a BGB + Art. 246 EGBGB amendments | 19 Jun 2026 | Button label Vertrag hier widerrufen / Widerruf bestätigen is widely treated as mandatory. Abmahnung (competitor cease-and-desist) is a real financial risk under §3a UWG. The standard Muster-Widerrufsformular (Annex I model form) must remain accessible in addition to the online button. vzbv monitors and litigates. |
| 🇳🇱 Netherlands | Boek 6 BW (art. 6:230o, 6:230s) | 19 Jun 2026 | Post-Bol.com (2024) case law expects precision in button labels. ACM is the active enforcement body. |
| 🇫🇷 France | Code de la consommation (L.221-18+) | 19 Jun 2026 | Action de groupe (class-action) exposure. DGCCRF enforcement, including fines and named-and-shamed publication on the regulator's website. |
| 🇫🇮 Finland | Kuluttajansuojalaki ch. 6 amendments | 19 Jun 2026 | Bilingual market — fi_FI and sv_FI translations must both be present and correct. KKV / consumer ombudsman enforcement; cases can be referred to markkinaoikeus (market court). |
Other Member States (IT, ES, PL, SE, DK, PT, BE, AT, CZ, SK, HU, HR, SI, RO, BG, GR, CY, MT, LT, LV, EE, LU) transpose to the Directive baseline. Belgium and Luxembourg are multilingual; verify the locale you serve. Ireland missed the original December 2025 deadline and is under EC formal notice — non-compliant MS status is a wildcard.
Licensing
| Tier | Licence | Price |
|---|---|---|
| Free (this module) | MageMe EULA — proprietary freeware | Free of charge |
| Pro (4 add-on sub-modules) | MageMe EULA — commercial | Paid, see eu-withdrawal-pro |
Licensor is ACTEK d.o.o., Slovenia. The free tier is distributed at no cost but is not open-source; modification and redistribution outside the EULA terms are not permitted.
Contact
| Topic | Contact |
|---|---|
| Bug reports and feature requests (free tier) | GitHub Issues |
| Pro support and licensing | support@mageme.com |
For suggestions about the disclaimer wording or the merchant checklist on this page, open a GitHub issue tagged docs.