Your website's legal checklist before selling in another EU country

In this article

The single market makes it easy to start selling to customers in another member state: switch on shipping, translate the product pages, and orders arrive. The legal side is less automatic. Much of EU consumer law is harmonised, so the core duties are the same everywhere, but your customer keeps the protection of the mandatory consumer rules of their own country, and those can go further than the EU minimum. This checklist covers the website itself: what it must show, say and do before and after the order.

01First question: whose law applies?

Under Article 6 of the Rome I Regulation (Regulation (EC) No 593/2008), a consumer contract is governed by the law of the consumer’s habitual residence when the trader directs its activities to that country. You may choose another law in your terms, but that choice cannot deprive the consumer of the protection of the mandatory rules of their own country. Under the Brussels I bis Regulation (Regulation (EU) No 1215/2012), consumers in that situation can also sue in their home courts.

What counts as “directing” activities? In the joined cases Pammer and Hotel Alpenhof (C-585/08 and C-144/09, 2010), the Court of Justice listed indicators such as offering delivery to that country, using its language or currency where these differ from your own, giving telephone numbers with an international code, using a country-specific top-level domain, and paying for search advertising aimed there. Once you deliberately sell to customers in a country, assume its mandatory consumer law applies.

The e-Commerce Directive’s country-of-origin principle (Article 3 of Directive 2000/31/EC) does not change this: its Annex excludes contractual obligations in consumer contracts.

02Say who you are: the imprint

Article 5 of the e-Commerce Directive requires every information society service provider to make certain information easily, directly and permanently accessible:

name and geographic address of establishment;
contact details including an email address, allowing rapid, direct communication;
the trade or similar public register and registration number, where applicable;
the supervisory authority, if the activity requires authorisation;
professional body, title and applicable rules, for regulated professions;
VAT identification number, where the activity is subject to VAT.

Member states implement this in national law, sometimes with additions. In Germany the provision is now § 5 of the Digitale-Dienste-Gesetz, which replaced the Telemediengesetz in May 2024; in Austria it is § 5 of the E-Commerce-Gesetz; in Slovakia, Act No. 22/2004 Coll. on electronic commerce. A single, complete imprint page linked from every page meets the core requirement in all of them.

03Before the order: information duties

The Consumer Rights Directive (2011/83/EU) sets out, in Article 6(1), what a consumer must be told before a distance contract binds them. The list is long; for a typical shop the core items are:

the main characteristics of the goods or services;
your identity, geographic address and contact details;
the total price including taxes, and all delivery charges, or how they are calculated;
payment, delivery and performance arrangements, and the date by which you will deliver;
the conditions, time limit and procedure for the right of withdrawal, and the model withdrawal form;
a reminder of the legal guarantee of conformity;
where applicable, that the price was personalised on the basis of automated decision-making (added by the Omnibus Directive (EU) 2019/2161).

The e-Commerce Directive adds duties specific to online ordering (Articles 10 and 11): explain the technical steps to conclude the contract, whether the contract will be filed and accessible, how to identify and correct input errors before ordering, and the languages offered. Acknowledge the order electronically without undue delay.

04The order button

Article 8(2) of the Consumer Rights Directive requires that the button or similar function that places an order be labelled in an easily legible manner only with the words “order with obligation to pay” or a corresponding unambiguous formulation. If it is not, the consumer is not bound by the contract. “Continue” or “Next” on the final step does not meet this. Check the wording in every language version of your checkout; the national implementations specify their own translations.

05Prices and discounts

The Price Indication Directive (98/6/EC) requires the selling price and, for many goods, the unit price (per kilogram, per litre) to be shown. Since the Omnibus Directive inserted Article 6a, any announcement of a price reduction must indicate the prior price, meaning the lowest price you applied during a period of at least 30 days before the reduction. A “was €49, now €29” claim needs the €49 to be that lowest prior price, and you should be able to show your price history.

The Omnibus Directive also tightened the rules on consumer reviews: if your site displays reviews, say whether and how you ensure they come from consumers who actually bought or used the product.

06The right of withdrawal, and the new withdrawal button

Consumers have 14 days to withdraw from a distance contract without giving a reason (Article 9 of the Consumer Rights Directive). You must explain the right using the information in Annex I(A) and provide the model withdrawal form in Annex I(B). If you fail to inform the consumer, the withdrawal period is extended by up to 12 months (Article 10). Article 16 lists the exceptions, such as goods made to the consumer’s specifications, perishable goods, and sealed goods unsealed after delivery that are unsuitable for return for health or hygiene reasons.

A newer duty applies since 19 June 2026. Directive (EU) 2023/2673 inserted Article 11a into the Consumer Rights Directive: for distance contracts concluded through an online interface, the trader must provide a withdrawal function, labelled with the words “withdraw from contract here” or an unambiguous corresponding formulation, that is prominently displayed and continuously available during the withdrawal period. It leads to a short confirmation step, labelled only with the words “confirm withdrawal” or with an unambiguous corresponding formulation, after which the trader must acknowledge receipt on a durable medium without undue delay. Shops that sell across borders should check that the function works in every language version.

07Legal guarantee of conformity

The Sale of Goods Directive ((EU) 2019/771) makes the seller liable for any lack of conformity that becomes apparent within at least two years of delivery; member states may set longer periods. Digital content and digital services are covered by the parallel Directive (EU) 2019/770. A commercial guarantee you offer on top must not be presented as if it replaced the legal one.

08No geo-blocking without a reason

The Geo-blocking Regulation ((EU) 2018/302) prohibits blocking or limiting a customer’s access to your online interface on the basis of nationality, place of residence or place of establishment, and prohibits automatically redirecting them to another country version without their consent. In listed situations you may not apply different general conditions of access for those reasons either. It does not oblige you to deliver everywhere: you can sell to a customer from another country on the terms of your own country version, including delivery only within the areas you serve.

09Dispute resolution notices

Footers across Europe still carry a link to the EU’s online dispute resolution (ODR) platform, once required by Regulation (EU) No 524/2013. That regulation was repealed by Regulation (EU) 2024/3228 and the platform closed on 20 July 2025, so the link obligation has gone and the link now leads nowhere; remove it. Information duties under the Alternative Dispute Resolution Directive (2013/11/EU) and national law remain: where you are committed or obliged to use an ADR body, say so and name it.

10Privacy and cookies travel with you

The GDPR is the same everywhere in the EU, and a business outside the EU that offers goods or services to people in the EU is covered by it too (Article 3(2)); such a business generally needs to appoint a representative in the EU (Article 27). Cookie rules are different: they come from national laws implementing the ePrivacy Directive and are enforced by national authorities, outside the GDPR’s one-stop-shop mechanism. When you start selling into a new country, read that country’s authority’s cookie guidance; our guide to consent banner designs regulators object to covers the common ground.

11Accessibility

Since 28 June 2025, the European Accessibility Act (Directive (EU) 2019/882) requires e-commerce services offered to consumers to meet accessibility requirements, with an exemption for microenterprises providing services. See our guide to the European Accessibility Act and your website.

12Language

EU law does not set one rule on the language of a shop. Several member states require consumer information or contract terms to be available in their official language or languages when you target their consumers, and in practice an order button or withdrawal notice that the customer cannot understand is hard to defend as clear information. If you deliberately sell into a country, translating the checkout, the pre-contract information and the terms is the safe default.

13The checklist

Complete imprint, linked from every page.
Pre-contract information on product and checkout pages, including total price and delivery costs.
Technical steps, input-error correction and languages explained; order acknowledged by email.
Final button labelled “order with obligation to pay” or a corresponding unambiguous formulation, in every language.
Prior lowest price shown on every price reduction; unit prices where required.
Withdrawal information, model form and, since 19 June 2026, a withdrawal function.
Legal guarantee reminder; commercial guarantees clearly distinguished.
No blocking or automatic redirection of visitors from other member states.
Old ODR platform link removed; ADR information where applicable.
Privacy notice and consent banner checked against the target country’s guidance.
Accessibility assessed, unless you qualify for the microenterprise exemption.

14Sources and further reading

Primary legal texts and official guidance referred to above. Links go to the official publishers.

Directive 2000/31/EC (e-Commerce Directive) (eur-lex.europa.eu)
Directive 2011/83/EU (Consumer Rights Directive) (eur-lex.europa.eu)
Directive (EU) 2019/2161 (Omnibus Directive) (eur-lex.europa.eu)
Directive (EU) 2023/2673 (inserting the withdrawal function, Art. 11a CRD) (eur-lex.europa.eu)
Directive 98/6/EC (Price Indication Directive) (eur-lex.europa.eu)
Directive (EU) 2019/771 (Sale of Goods Directive) (eur-lex.europa.eu)
Regulation (EU) 2018/302 (Geo-blocking Regulation) (eur-lex.europa.eu)
Regulation (EC) No 593/2008 (Rome I) (eur-lex.europa.eu)
Regulation (EU) No 1215/2012 (Brussels I bis) (eur-lex.europa.eu)
Court of Justice of the EU, joined cases C-585/08 and C-144/09 Pammer and Hotel Alpenhof (curia.europa.eu)
Regulation (EU) 2024/3228 (repealing the ODR Regulation) (eur-lex.europa.eu)
Directive (EU) 2019/882 (European Accessibility Act) (eur-lex.europa.eu)