The Legal Pages an EU Shop Cannot Skip, and the Link You Must Remove

Legal pages are the part of a website assembled by copying. Somebody finds a shop that looks reputable, adapts its terms, changes the company name, and the site now carries obligations from another country, a returns policy nobody in the business has read, and occasionally a link to a service that no longer exists.

That last item is not hypothetical, and it makes a useful test of whether your pages have been maintained or inherited.

The link you are supposed to have removed

For a decade, EU traders selling online were obliged to link to the European Commission’s Online Dispute Resolution platform. That obligation is gone. Under Regulation (EU) 2024/3228, the platform stopped accepting new complaints on 20 March 2025 and was shut down entirely on 20 July 2025, with its data deleted. The Commission’s own explanation is unflattering and instructive: roughly two hundred cases a year were successfully processed across the entire Union, against operating costs that made no sense.

The practical consequence is the opposite of what most published checklists still say. Traders were required to remove the link by 20 July 2025, and a site still pointing customers at a dead platform is not merely out of date; it is directing consumers to a remedy that does not exist, which is the sort of thing enforcement bodies treat as misleading.

What is actually required, and by what

The obligations come from several instruments that are usually blurred into one. Separating them makes it obvious what is missing.

Page titles do not matter. What matters is that the information exists, is findable, and is correct. A single well-written page can carry several of these; three badly written ones can satisfy none.

The five things most often missing

1. A real address and a company registration number. A contact form is not identification. This is the most common gap on small EU shops and one of the easiest for a regulator or a customer to check.
2. The withdrawal form itself. Many sites describe the right and never supply the model form, which is a separate obligation.
3. Who pays for return shipping. If you do not say the consumer bears the cost of returning goods, you may end up bearing it. Silence has a default and the default is not in your favour.
4. A delivery time. Where none is agreed, the trader must deliver without undue delay and in any case within thirty days. Stating your actual timescale is both a legal improvement and a conversion one, for the reasons set out in what resolves doubt on a product page.
5. The exceptions to the withdrawal right, stated before the order. Custom-made goods, sealed hygiene products opened after delivery, and digital content downloaded with the customer’s express consent all have specific treatment, and the exception only applies if the consumer was told.

The button that has to say the right thing

One requirement gets missed more than any other because it lives in the checkout rather than on a legal page. The button that concludes the order must make it unambiguous that the consumer is taking on a payment obligation. “Order with obligation to pay” or equivalent unambiguous wording.

“Continue”, “Confirm” and “Submit” do not meet it. The consequence is not a fine in the first instance: it is that the consumer is not bound by the contract. That is a commercially significant outcome hiding inside a label, and it takes five minutes to fix.

What it costs to get wrong

The assumption is that non-compliance means a fine, and that fines happen to other people. In practice the first consequences are commercial and automatic, which makes them more likely to actually reach you.

The clearest example concerns the withdrawal right. If the consumer is not informed of it as required, the period does not quietly stay at fourteen days. It extends by twelve months. A shop that never explained the right can find itself accepting returns on year-old orders, and the customer discovering this is usually the one you would least like to have discovered it.

The second automatic consequence is the checkout button covered below: an order concluded without the required labelling does not bind the consumer. The third is that missing or incorrect information about additional charges means the consumer does not have to pay them.

None of these require a regulator to act. They operate as a matter of contract, which is why treating legal pages as a filing exercise rather than a commercial one misjudges the risk.

Where the pages live

Presence is not enough; the information has to be available at the point it is needed and in a form the consumer can keep.

• Linked from every page, conventionally the footer. Identification details in particular have to be permanently and easily accessible.
• Reachable before the order, not only after. Terms presented for the first time on the confirmation page have not been provided pre-contractually.
• Confirmed on a durable medium. The order confirmation email should carry the terms or a stable link to them, because a page you can edit later is not a record of what was agreed.
• Readable on a phone. A ten-thousand-word terms page in eleven-point grey satisfies nothing in practice, and it interacts with the readability question directly.

B2B is not exempt from everything

Selling to businesses removes most consumer protections: no statutory withdrawal right, no consumer information obligations, considerably more freedom in the terms. It does not remove three things.

Identification requirements still apply, because they attach to providing an information society service rather than to selling to consumers. Data protection still applies, because a business contact is still a person. And the prohibition on misleading commercial practices survives in general commercial law even where the consumer directive does not reach.

The practical error we see is the reverse: shops that sell to both and apply consumer rules to neither, on the theory that most orders are from companies. The status of each buyer decides, and the site has to handle both.

Writing them so they are actually usable

A legal page that is technically complete and practically unreadable satisfies a regulator and loses customers. Three habits fix most of it.

Answer the question in the first line. A returns page should open with the number of days and who pays, not with a paragraph about your commitment to satisfaction.

Use the words customers use. “Withdrawal” is the legal term and “returns” is what people search for. Use both, with the legal term where precision matters.

Put the operative facts on the pages where the decision happens. The delivery estimate belongs on the product page and in the cart, not solely in terms. Legal completeness is a floor; the same information placed where the doubt occurs is what converts, which is the placement logic behind where evidence belongs on a page.

Keeping them current, cheaply

The ODR example is the argument for a review cadence rather than for a one-off legal review. Rules change quietly and the changes rarely reach the person who owns the website.

1. Review twice a year, on fixed dates, taking half an hour. Most reviews find nothing, which is the point.
2. Date the pages. “Last updated” is a signal to customers and a discipline for you.
3. Keep a list of what each page depends on. Which regulation, which payment provider terms, which carrier. When one changes you know what to open.
4. Check the pages exist and load after every site change. Legal pages are the most common casualty of a redesign, because nobody tests them, and a footer link to a 404 is a compliance failure with a technical cause, which is one of the silent breakages covered in the migration checklist.

For markets with their own additions on top of the EU baseline, the national layer matters as much as the European one: Bulgaria’s fiscal and language rules are a worked example of that in what a Bulgarian online store has to satisfy.

The short version

Legal pages are usually copied and therefore usually wrong in specific, checkable ways. The clearest test: the EU Online Dispute Resolution platform closed on 20 July 2025 under Regulation (EU) 2024/3228, the link requirement is gone, and traders were required to remove it, so a site still linking there has not been reviewed in over a year. Separate the obligations by source — identification, consumer information and withdrawal, product safety, data protection, cookies — because that makes the gaps visible. The five most common omissions are a real address with registration details, the model withdrawal form itself, who pays return shipping, a stated delivery time, and the exceptions to the withdrawal right. Check the order button says the consumer is taking on a payment obligation, because “Confirm” does not bind them. Then review twice a year on fixed dates, and verify the pages still load after every redesign.