A Hungarian webshop needs four things on the legal side: an impresszum (legal notice) with the details required by the e-commerce act, terms and conditions that include the withdrawal information and the model withdrawal form, a GDPR privacy notice, and, since 19 June 2026, an online withdrawal function labelled „elállás a szerződéstől” (withdraw from the contract). For goods, the 14-day withdrawal period starts on delivery, and you must refund the customer, including the standard delivery charge, within 14 days of learning about the withdrawal.
The holiday season puts all of this under pressure: December orders come back in January, plenty of people want to return gifts, and it all lands on customer service exactly when capacity is thinnest. We build and run webshops, so we see where these processes break in practice. We are not lawyers, though, and this is not legal advice: have a lawyer review your texts, while we cover the technical and process side.
- Mandatory pages: legal notice (including your hosting provider's details), terms with withdrawal information, the model withdrawal form, and a privacy notice.
- Since 19 June 2026 you also need an online withdrawal function: a clearly labelled entry point, a short form, a confirm button and an immediate acknowledgement.
- The deadline is 14 days from delivery. For a gift delivered on 2 December, it runs out on 16 December, before Christmas.
- A longer holiday returns window is a voluntary promise. Spell it out, and keep it separate from the statutory right of withdrawal.
- Links to the EU ODR platform have been pointless since 20 July 2025: the platform is gone.
Which legal pages does a webshop need?
These pages usually get written at launch and then sit untouched for years, while the hosting, the courier and the rules all change. This is how we audit them:
| Page | What it must contain | Legal basis |
|---|---|---|
| Legal notice (impresszum) | Company name, registered office, contact details including email, company registration number, tax number, the hosting provider's name and contact details | E-commerce Act (Ekertv.), Section 4 |
| Terms and withdrawal information | Conditions, deadline and procedure for withdrawal, who pays for returns, complaint handling, the conciliation body | Government Decree 45/2014 |
| Model withdrawal form | The template from the decree's annex, downloadable or fillable | Government Decree 45/2014 |
| Online withdrawal function | Button, form, confirmation, acknowledgement | Decree 45/2014, Section 22; Directive (EU) 2023/2673 |
| Privacy notice | What data you process, why and on what legal basis, who receives it, how long you keep it | GDPR, Article 13 |
The item most often missing from the legal notice is the hosting provider, even though the e-commerce act requires it alongside your own company details. If you have moved to Shopify or a cloud provider since launch, that line needs updating too. Cookie notices and consent management are a separate topic, covered in our article on Consent Mode v2.
How does the 14-day withdrawal work, step by step?
Under Government Decree 45/2014, the process looks like this:
- Deadline: for goods, 14 days from delivery. If an order arrives in several parcels, the delivery of the last item counts. Customers can also withdraw between placing the order and receiving it.
- Notice: the customer can use the model form, any unequivocal statement (an email will do) or the online withdrawal function. No reason is required.
- Return: the customer sends the goods back within 14 days of communicating the withdrawal. They bear the direct cost of the return if you told them so in advance and did not offer to cover it.
- Refund: within 14 days of learning about the withdrawal, including the standard delivery charge, as a rule using the same payment method the customer used. You do not have to refund the extra cost of a pricier option such as express delivery. You may hold the refund until the goods are back or the customer proves they have sent them, whichever comes first.
- Diminished value: if the customer handled the product beyond what is needed to establish its nature, characteristics and functioning, they are liable for the loss in value. They do not lose the right to withdraw because of it.
There are exceptions, such as goods made to the customer's specifications, perishable goods, or goods sealed for health or hygiene reasons once the seal is broken. Check the exact list in the decree, and only rely on it if your product genuinely falls under it.
The most expensive mistake is incomplete information. If you fail to inform the customer properly about the right of withdrawal, the deadline is extended by 12 months. A sloppy set of terms can keep a Christmas order open until the end of next year.
What does the online withdrawal function have to do?
This is the biggest change this year. Directive (EU) 2023/2673 added a new article to the Consumer Rights Directive, which Hungary transposed by amending Section 22 of Decree 45/2014. According to the Hungarian consumer protection authority's (NKFH) summary, the rule applies from 19 June 2026, and the authority has said it will check compliance.
The required elements
- Entry point: the Hungarian label „elállás a szerződéstől”, clearly visible, easy to reach, and available for the entire withdrawal period. Labels like „Visszaküldés” (Returns) or „Mégsem” (Cancel) do not qualify.
- Form: the customer can clearly state their intention to withdraw and enter their name, the order or contract reference, and the email address where they want the acknowledgement.
- Confirmation: the statement is submitted with a button labelled „elállás megerősítése” (confirm withdrawal).
- Acknowledgement: under the directive, sent without undue delay on a durable medium (in practice, email), stating the content of the withdrawal and when it was submitted.
How we build it
We put the button in the footer, on the “My orders” page and in the order confirmation email. In our view, putting the function behind a login is risky, because guest customers never get to it. We store each submission on the server with a timestamp instead of just firing off an email to someone. A minimal record looks like this:
{
"order_id": "WS-2026-10482",
"name": "Anna Minta",
"ack_email": "anna@example.com",
"items": ["SKU-1182"],
"submitted_at": "2026-12-28T21:14:05+01:00",
"refund_due": "2027-01-11"
}The refund deadline field is the point: the 14 days run from submission, not from when the parcel comes back. If the system calculates it and raises alerts, nobody has to dig through an inbox in January to work out who is owed money. Shopify stores have to deal with this too: the Shopify Help Center says merchants selling to EU customers may need a withdrawal button or link, but checking the Hungarian label and the flow is still on you. How flexible each platform is here is something we cover in Shopify vs. custom webshop.
What are the most common mistakes we see?
- A leftover ODR link. Following Regulation (EU) 2024/3228, the EU online dispute resolution platform shut down on 20 July 2025. Remove the link and any reference to it in your terms.
- “Unopened packaging only.” Apart from the hygiene and sealed-media exceptions, opening the packaging does not rule out withdrawal. At most, it may justify a deduction for diminished value.
- Mixing up withdrawal and warranty. If your form demands a fault description, you are attaching a condition to a no-reason withdrawal. A reason field is useful for your stats, but make it optional.
- Store credit only. As a rule, the money goes back via the original payment method. You can offer a voucher instead only if the customer expressly agrees.
- A copy-pasted privacy notice. The GDPR requires you to name the recipients or categories of recipients. If the notice does not list your courier, payment provider and newsletter tool, it is not really your notice.
- Unversioned terms. For every order you need to know which version of the terms applied. Date each version and keep the old ones.
How should you handle the holiday returns wave?
Extended returns windows: be precise
Many webshops extend their returns window for the holidays, because the statutory 14 days on a gift delivered in early December expire before Christmas. That is a voluntary promise, so write it down precisely: which order period it covers, how long it lasts and what conditions apply. Also state that it does not limit the statutory right of withdrawal. We keep the online withdrawal function open until the extended window closes, so customers do not have to guess which route to take.
Gifts
Gifts are often returned by someone other than the buyer. As a rule, the refund goes back to the original payment method, which means to the buyer. If you offer gift exchanges or gift cards, present them as a separate, voluntary service, and use the order number to identify the purchase.
Process and data protection
An incoming withdrawal should automatically open a ticket, send return instructions and show the refund deadline. You do not need a big system for this: the patterns in our small-team automation article work well. Data you collect during a withdrawal, such as a cash-on-delivery customer's bank account number, belongs in your privacy notice, and you should only ask for what the refund actually requires.
Frequently asked questions
Does the customer have to use the model withdrawal form?
No. You must make the form available, but the customer can withdraw with any unequivocal statement: by email, by letter or through the online withdrawal function.
Who pays for return shipping?
The customer bears the direct cost of returning the goods if you told them so in advance. You still have to refund the original standard delivery charge.
How long can I hold back the refund?
Until the goods are back or the customer proves they have sent them, whichever happens first. The 14-day refund deadline runs from the moment you learn about the withdrawal.
Do Shopify and WooCommerce stores need the withdrawal button too?
Yes, the obligation does not depend on the platform. An app or built-in feature can help, but you still need to check the Hungarian label, the form fields and the acknowledgement email.
Does this article replace a lawyer?
No. We have summarised the legal basics and the practical pitfalls. Your terms and privacy notice should be written or reviewed by a lawyer and tailored to how your business actually works.
If you want your withdrawal function to work hand in hand with order management, deadline tracking and refunds, take a look at our webshop development service. We leave the legal wording to your lawyer and build the system that runs behind it.