Most e-shop owners know that on June 19, 2026, the new EU withdrawal button requirement comes into effect. But here is where most leave half the work undone: the e-shop terms and conditions that the customer reads on the site before purchasing must be reviewed before installing the plugin. Otherwise, you end up with one promise on the page, another in the form, and a third in the law. None of these three different stories will protect you.
In this article, I will go through what this actually means — in plain English, without legal jargon — and provide a checklist you can use for your shop today.
The Problem: Terms That No One Has Read for 5 Years
A typical situation I see with e-shops: the terms and conditions page exists. Often it is copied from another shop or created during the site build. Since then, no one has looked at it. The domain has been renewed, the company address has changed, the return process works completely differently in practice — but the page still displays what was originally typed there.
The feeling is familiar: you open your shop’s terms and conditions for the first time in years, read a few paragraphs, and discover they refer to an address where you no longer operate. Or it says returns can be made within 30 days, even though you actually follow the 14-day statutory deadline. Or even worse: the return address contains the details of a former colleague.
What This Information Discrepancy Costs You
What happens if the terms and conditions remain uncorrected and you simply install the plugin? In the first few months, likely nothing. The customer buys, the customer is satisfied, and withdrawals are rare.
But after about 5–10 returns, there will be one customer who reads the terms thoroughly. There is always one such customer. They submit an application, wait for their money back, and if they don’t like how things were handled, they write to the Consumer Protection and Technical Regulatory Authority. The Authority will come to inspect your site. And then they will start checking line by line: have the necessary requirements been met?
Before a customer makes a purchase, they must be able to review the e-shop’s terms and conditions and understand their rights regarding returns. If this information is missing, incorrect, or contradictory, the law says something very inconvenient: the withdrawal period is extended by 12 months. This means that instead of 14 days, the customer can return the product and claim a refund for an entire year.
Think about it: you sold 200 products last Christmas. If your terms were deficient, all those customers still have the right today to return the product and demand their money back. This is stated in the Law of Obligations Act (§ 56 (1⁶)).
Additionally, there is the precept from the Consumer Protection Authority and a possible fine of up to €3,200. But the 12-month extension is even worse in my eyes, because it cannot be corrected retroactively — the deadline has already been extended.
Ten Things That Are Broken in the Terms and Conditions of Estonian E-shops
Over the past year, I have reviewed quite a few terms and conditions of Estonian e-shops. Patterns repeat. Below is a checklist you can apply to your shop tonight.
1. Contradictory deadlines. One paragraph says 14 days, another 30 days, and a third “a reasonable time.” The customer will choose the best option for themselves — and it will be difficult for you to prove which one applied.
2. The word “immediately” is missing regarding refunds. The law states that money must be returned immediately, but no later than 14 days from receiving the withdrawal notice. If your text only says “within 14 days,” you are already technically incorrect.
3. Reference to the EU standard form is missing. The customer must be able to use the European Union standard form to submit a withdrawal notice. This form must be either linked or included as text — not just your own solution for the withdrawal button.
4. The return address is vague. “Send it back to us” is not sufficient. There must be a precise address including the name, street, postal code, and city. If you expect returns to a parcel machine, the name of the parcel machine and the recipient’s phone number must be provided.
5. There is only one way to submit an application. The law requires that the customer can submit a withdrawal notice in several ways — by email, by post, or (from June 19, 2026) digitally via a button. If it only says “send us an email,” the information requirement is not met.
6. The starting point of the 14-day period is unclear. Do the days start running from placing the order, the receipt of payment, or the receipt of the product? The correct answer: from the receipt of the product (from the courier or from picking up the package from the machine).
7. B2B exclusion is missing. The right of withdrawal applies only to consumers. If you also sell to companies, the terms must include a clear sentence stating that this does not extend to orders from legal entities. Otherwise, an OÜ (limited company) can also submit a return and you won’t be able to refuse.
8. Allocation of return costs is unstated. Who pays for the return shipping? If you want the customer to pay, this must be stated before the purchase. By default, you pay.
9. Exceptions are missing. Some products are not eligible for return — for example, sealed cosmetics that have been opened, or custom-made items. The law allows these to be excluded, but only if the exception is clearly stated in the terms. Check Section 53, subsection 4 of the Law of Obligations Act again
10. Contact details are outdated. Old phone number, old email, old company name. Easy to fix, but no one has checked.
The Solution: How to Fix It All
Reviewing a proper set of terms and conditions takes 2–3 hours for an average e-shop — assuming you know what to look for.
Step one: Print out your terms. Seriously, on paper. You read them too quickly on a screen. On paper, use a pen to mark every instance of a specific number (days, euros), every address, and every promise to the customer. These are the places where errors usually hide.
Step two: Compare with the law. Chapter 4 of the Law of Obligations Act covers the right of withdrawal. If that is intimidating, use the website of the Consumer Protection and Technical Regulatory Authority — the information there is in plain language.
Step three: Correct and publish. Make the changes, save the date (including when it was last updated), and add a note to the footer of the page. This way, the customer and, in case of a dispute, the Authority can see that the terms are current.
Only Install the Plugin Once the Terms Are in Order
This is the sequence that I believe is important. Some customers do the opposite: they install the plugin first because the deadline is approaching, and leave the terms for “next week.” But the plugin creates a form for the customer that includes references to the terms. If the terms are broken, the plugin simply displays broken information in a beautiful form.
However, if the terms are in order, installing the plugin is a simple mechanical step. I have made a separate video guide for this — and the entire installation takes 5 minutes. If you want to try out how the button and form look from the customer’s perspective, the plugin.riin.eu demo environment is open.
A more thorough article on the background of the withdrawal button obligation explains exactly what Directive 2023/2673 requires and what the deadlines are. I recommend reviewing that as well if you haven’t gone into the details before.
A Final Thought
June 19, 2026, is not a deadline that forces you to do something you should have actually done years ago: review your terms and conditions and align them with what actually happens in your shop.
The plugin handles the technical side. But the rest — the text the customer reads before purchasing — is in your hands. And if you fix it today, you will wake up tomorrow morning with one less nagging worry.
Frequently Asked Questions
Is it enough if I install the withdrawal button plugin and leave the terms and conditions as they are?
No, it is not enough. The plugin fulfills the technical requirement — the button, the form, the notification. But the law also requires the information side: the terms must state the 14-day period, who bears the return costs, when the period begins, how the application can be submitted, and the exact return address. If these are contradictory or missing, no plugin will help.
How can I see if my current terms and conditions are in order?
Read them through carefully yourself and check ten things: the 14-day deadline, the word “immediately” regarding refunds, the link to the EU standard form, the exact address to send the product, several different ways to submit an application, when the 14-day countdown begins, and whether B2B customers are clearly excluded. If any of these are missing or contradictory, they need to be corrected.
Is the withdrawal button also mandatory for B2B sales?
No. The right of withdrawal applies to consumers (B2C). If you only sell to companies, the button is not necessary. However, in most e-shops, both buy — in that case, there must be a clear clause in the terms stating that the 14-day right of withdrawal does not apply to orders from legal entities, and the form must distinguish between them.
How long should a proper terms and conditions text be?
There is no magic number, but an average proper text for an Estonian e-shop falls between 1,500 and 2,500 words. Shorter is usually too superficial, while longer starts to deter the customer. It is more important that all mandatory points are covered, rather than the word count.
Can I copy the terms and conditions from somewhere?
Technically yes, many people do it. But copied text is usually written for someone else’s store — wrong address, wrong company, wrong return procedure. If you choose to copy, choose carefully! I recommend familiarizing yourself with the Estonian E-commerce Association’s guidelines for e-traders. Their website also features a sample of terms and conditions that you can use for your e-shop.
