
E-Commerce
Order button labeling, withdrawal rights, pricing rules, and consumer protection.
Running an online shop in the EU means meeting the requirements of the Consumer Rights Directive, the Omnibus Directive, and country-specific distance selling laws. Your checkout process, pricing display, return policy, and order button text all have legal requirements. The most common issues: not clearly labelling the order button as a payment obligation, not showing the lowest price from the past 30 days on discounted items, and not providing pre-contractual information before checkout.
Key facts
- •EU law requires the order button to clearly indicate a payment obligation, 'Order' alone is not sufficient in Germany
- •The Omnibus Directive (2022) requires showing the lowest price from the past 30 days for any discounted product
- •Customers have a 14-day withdrawal right for most online purchases, and must be informed before checkout
- •Price display must include VAT in all B2C transactions, showing ex-VAT prices first is prohibited
- •The EU's cross-border enforcement network (CPC) coordinated action against 118 online shops in 2024 for pricing violations
What we check
- ✓Order button labelling requirements
- ✓Withdrawal/return policy presence and completeness
- ✓Price display including VAT
- ✓Pre-contractual information before checkout
- ✓Payment method information and security
E-commerce checkout: good vs. bad examples
Vague order button text
A checkout button that says "Continue" or "Complete order" without clearly indicating a payment obligation. In Germany, courts have ruled that the button must explicitly state that clicking it creates an obligation to pay.
Clear payment obligation button
A checkout button that reads "Buy now" or "Order and pay" (or the German equivalent "Zahlungspflichtig bestellen"). This makes the payment obligation unmistakable and satisfies EU Consumer Rights Directive Article 8(2).
Fake discount pricing
Showing "Was €49, now €29" when the product was never actually sold at €49. The Omnibus Directive requires that discounted prices show the lowest price from the previous 30 days.
Honest price history
Showing "€29 (lowest price in last 30 days: €35)" next to discounted products. This complies with the Omnibus Directive and builds customer trust through transparent pricing.
Hidden withdrawal rights
Burying the 14-day return policy in the terms and conditions instead of showing it clearly before checkout. EU law requires that customers are informed about withdrawal rights before placing an order.
Withdrawal info before checkout
A visible section before the payment step explaining: "You have 14 days to return this product without giving a reason. Returns are free." This satisfies pre-contractual information requirements.
Prices shown without VAT
Displaying product prices excluding VAT and only adding it at checkout. In B2C transactions, all displayed prices must include VAT. Showing ex-VAT prices first misleads consumers.
VAT-inclusive pricing throughout
All product pages and listings show prices including VAT with a note: "All prices include VAT." Shipping costs are shown separately but clearly before checkout begins.
Vague order button text
A checkout button that says "Continue" or "Complete order" without clearly indicating a payment obligation. In Germany, courts have ruled that the button must explicitly state that clicking it creates an obligation to pay.
Fake discount pricing
Showing "Was €49, now €29" when the product was never actually sold at €49. The Omnibus Directive requires that discounted prices show the lowest price from the previous 30 days.
Hidden withdrawal rights
Burying the 14-day return policy in the terms and conditions instead of showing it clearly before checkout. EU law requires that customers are informed about withdrawal rights before placing an order.
Prices shown without VAT
Displaying product prices excluding VAT and only adding it at checkout. In B2C transactions, all displayed prices must include VAT. Showing ex-VAT prices first misleads consumers.
Clear payment obligation button
A checkout button that reads "Buy now" or "Order and pay" (or the German equivalent "Zahlungspflichtig bestellen"). This makes the payment obligation unmistakable and satisfies EU Consumer Rights Directive Article 8(2).
Honest price history
Showing "€29 (lowest price in last 30 days: €35)" next to discounted products. This complies with the Omnibus Directive and builds customer trust through transparent pricing.
Withdrawal info before checkout
A visible section before the payment step explaining: "You have 14 days to return this product without giving a reason. Returns are free." This satisfies pre-contractual information requirements.
VAT-inclusive pricing throughout
All product pages and listings show prices including VAT with a note: "All prices include VAT." Shipping costs are shown separately but clearly before checkout begins.
The Consumer Rights Act 2022 changed the rules in November 2022
Ireland's main consumer law framework shifted in November 2022. The Consumer Rights Act 2022 consolidates what used to be scattered across the Sale of Goods Act 1893, the Sale of Goods and Supply of Services Act 1980, and various EU regulations. For B2C ecommerce it's now the first text to consult.
Four pillars matter for a website.
Goods must be of satisfactory quality, fit for purpose and as described. The buyer has 30 days to reject for a refund in the first instance, then a right to repair or replacement for up to six years.
Digital content and services get their own chapter. A one-off digital download and a streaming subscription are treated differently. The trader must provide updates needed to keep the service compliant with the contract.
Unfair contract terms are tested against statutory grey lists and black lists. Automatic renewal clauses, unilateral price changes and excessive cancellation fees typically land on the grey list.
Fake or incentivised reviews are prohibited. The Consumer Protection Act 2007 as amended by the 2022 Act catches sites that publish customer reviews without verification steps.
The CCPC (Competition and Consumer Protection Commission) enforces this regime. In 2024 and 2025 the CCPC issued guidance specifically on review authenticity and drip pricing.
Distance selling still lives in SI 484/2013
The European Union (Consumer Information, Cancellation and Other Rights) Regulations 2013, known as SI 484/2013, transpose the Consumer Rights Directive. They were not repealed by the 2022 Act. They sit alongside it and cover the specific obligations that apply before a distance contract is concluded.
Three obligations that every Irish ecommerce site must meet at the checkout page.
Pre-contractual information. Identity of the trader, geographic address, contact details, total price including all taxes and delivery charges, arrangements for payment and delivery, the existence of the right of withdrawal. Missing any of these can extend the withdrawal period from 14 days to 12 months.
The confirm button. The final order button must be labelled in a way that makes clear the user is agreeing to pay. "Order with obligation to pay" or equivalent. A vague "Continue" or "Submit" is a breach.
The 14-day cooling-off period. Starts the day the consumer receives the goods. The model withdrawal form must be available on the site. Some categories are exempt, including custom-made goods and perishables, but the exemption must be genuine.
Failure to inform about the right of withdrawal is the single most common compliance breach in Irish ecommerce audits. Fixing it is a two-paragraph addition to the terms and conditions page.
Omnibus rules on pricing and reviews
The EU Omnibus Directive 2019/2161 transposed into Irish law in 2022 added three specific duties that target deceptive ecommerce practices.
Reference price for promotions. If you advertise "20% off" the reference price must be the lowest price charged during the 30 days before the promotion started. A product that was €100 for three months, bumped to €150 for one week, then sold at €120 as "20% off" fails the test. The CCPC has made this a visible enforcement priority.
Review authenticity. If you publish customer reviews you must state whether the reviews come from verified buyers, describe your verification method, and have a process to remove fake reviews. A site that accepts open reviews from anyone must say so. A site that claims "verified reviews" must actually verify.
Personalised pricing disclosure. If the price shown to a user is based on their profile, browsing history or similar signals, this must be disclosed before the purchase. Dynamic flight and hotel pricing is in scope.
These rules apply to any site selling to Irish consumers regardless of where the business is registered. An Irish drop-shipper selling from an EU warehouse is covered. A UK site with Irish customers is covered.
Use our free scanner to detect missing distance selling disclosures and check your cookie consent at the same time. For full GDPR coverage see our GDPR compliance page.
Related guides
Withdrawal button for e-commerce: what Irish webshops need by June 2026
From 19 June 2026 every EU webshop must show a withdrawal button. Directive 2023/2673, Article 11a. Ireland missed the transposition deadline. Practical checklist.
"Buy Now" vs "Order": Why Your Button Text Matters Legally
EU law requires specific wording on order buttons. The wrong text could make your orders non-binding. Here is what your checkout button must say.
EU Checkout Page Requirements: Button Text, Pricing & Consent
EU rules for your checkout page: order button text, price display, withdrawal rights, and consent requirements. What you must show before the customer clicks Buy.
Discount Pricing Rules: The 30-Day Prior Price Requirement
EU Omnibus Directive requires showing the lowest price from the past 30 days when advertising a discount. Here is how it works.
EU Consumer Rights for Online Sellers: Plain-Language Guide
EU consumer protection law affects every online shop. Here are the rules you need to follow, explained without legal jargon.
The 14-Day Withdrawal Right: What Every Online Seller Must Know
EU law gives online shoppers 14 days to return purchases without reason. Here is what you must tell them and how to handle it.
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