Notice: Information only, not legal advice.
TL;DR
- Market principle: the target market matters, not the company's location
- 24 EU official languages must be available for EU-wide sales
- Withdrawal instructions + model form + withdrawal button (§ 356a BGB from 19 Jun 2026) in the contract language
- Manual maintenance of 24 languages is impossible — automation is mandatory
What is the market principle?
For consumer contracts, per Art. 6 Rome I Regulation (EC 593/2008): The law of the consumer's habitual residence applies, if the merchant targets activities to that state.
Concretely: if your Shopify store is in Germany but actively sells in France, Italy, Spain (localized domain, local currency payment), French rules apply to French customers, Italian to Italian, etc.
Which means: Withdrawal instructions must be provided in the consumer's language.
What EU Directive 2011/83/EU requires
Art. 6 of the Consumer Rights Directive (implemented in German § 312d BGB) demands merchants inform consumers about withdrawal rights clearly and comprehensibly.
"Clearly and comprehensibly" in practice means: in the language the contract is concluded in. If you sell via an Italian shop URL with Italian menu to an Italian customer, instructions must be available in Italian.
Which 24 languages?
The 24 EU official languages: Bulgarian, Croatian, Czech, Danish, Dutch, English, Estonian, Finnish, French, German, Greek, Hungarian, Irish, Italian, Latvian, Lithuanian, Maltese, Polish, Portuguese, Romanian, Slovak, Slovenian, Spanish, Swedish.
UK + Switzerland + Norway add separate legal regimes — not covered by EU directive.
The addition from 19 June 2026: withdrawal button
The new EU Directive 2023/2673 (implemented in § 356a BGB) additionally requires a withdrawal button with exact labelling. This too must be in the consumer's language.
Pragmatically: 24 button labels, 24 confirmation pages, 24 PDFs — plus German/English admin languages.
Barely feasible manually.
How to implement 24 languages in Shopify
Option 1: manually per language
- Hire translators (€200-500 per language)
- Translation app for Shopify (Translate & Adapt, Langify)
- One withdrawal instructions PDF per language
- One withdrawal form PDF per language
- Button label per locale
Effort: Initial 30-60 hours, ongoing 5-10h/month on law changes.
Option 2: automated
Revoka generates the model withdrawal form and flow automatically in all 24 EU official languages. Merchant configures merchant data once, Revoka handles the rest.
Effort: 10 minutes setup, 0 ongoing maintenance.
What happens without localization?
Multiple court rulings confirm: missing withdrawal instructions in consumer's language count as defective instructions. Consequences per § 356 (3) BGB:
- Withdrawal deadline extends to 12 months + 14 days
- Warning risk via consumer protection associations in respective countries
- From § 356a BGB (June 2026): also fine risk
Practical implementation (Shopify)
- Shopify Markets enabled for country segmentation
- Translation app for store content (T&Cs, imprint, privacy, withdrawal instructions)
- Revoka for withdrawal form + button in all 24 languages
- Footer link to withdrawal instructions / model form per locale set correctly
- Order confirmation language automatically adapted
Which languages are required vs. nice-to-have?
Required (if actively selling there):
- German, English, French, Italian, Spanish, Dutch, Polish, Portuguese
Nice-to-have (smaller markets, lower warning risk):
- Scandinavia (Swedish, Danish, Finnish)
- Baltics (Estonian, Latvian, Lithuanian)
- Southeastern Europe (Romanian, Bulgarian, Greek)
Important: the legal obligation is tied to active sales activity. Passive reach (no localized URL, no local currency) has lower requirements.
Checklist for EU merchants
- Shopify Markets enabled
- T&Cs/imprint/privacy/withdrawal instructions in target-market languages
- Model withdrawal form PDF in 24 languages (Revoka)
- Withdrawal button in target language (mandatory from 19 Jun 2026)
- Email templates (order confirmation, withdrawal confirmation) localized
- Regular review on law changes
Further reading: § 356a BGB explained · Revoka: 24 EU languages · Withdrawal button obligation