Supporting EU Article 11a (Right of Withdrawal) Compliance with Recharge

Overview

Article 11a of the EU Consumer Rights Directive requires that, for distance contracts concluded through an online interface, traders provide consumers with an easily accessible "withdrawal function" so they can exercise their right of withdrawal online. The function must be clearly labelled, continuously available throughout the withdrawal period, and allow the consumer to submit a withdrawal statement and receive an acknowledgement of receipt.

This guide explains how you can use existing Recharge tools — with no code required — to support a withdrawal experience in your customer portal and cancellation flow. It covers:

1. Updating the cancel link copy so it references withdrawal.
2. Calibrating your cancellation survey so customers can specify whether they are cancelling or withdrawing, and so eligibility is explained.
3. Identifying, validating, and actioning withdrawal requests using existing reports and your Shopify refund tools.

Responsibilities

Recharge provides configurable tools (portal copy, cancellation flow, cancellation survey, and reporting/exports) that you can use to build a withdrawal experience. Recharge does not determine whether a given request is a valid withdrawal, does not decide who is eligible, and does not process refunds on your behalf.

You are fully and independently responsible for:

• Confirming your legal compliance needs with your own legal counsel.
• Updating the customer portal and cancellation prevention flow to meet your compliance needs (the steps below require no code).
• Confirming the validity of each withdrawal request — for example, that it comes from an EU resident and relates to a purchase within the applicable 14-day window.
• Actioning valid withdrawal requests, including processing any required refunds.

Step 1 — Update the cancel link copy

Article 11a calls for a withdrawal function labelled "withdraw from contract here" or an unambiguous corresponding formulation. You can repurpose the existing "Cancel subscription" link in the customer portal so it also references withdrawal.

To update the copy:

1. In the Recharge merchant portal, go to Storefront → Copy & translations.
2. Find the Products → Subscription → Cancel subscription field.
3. Replace the existing text with "Cancel or withdraw from contract here" (or an unambiguous corresponding formulation your counsel approves).
4. Save and preview your customer portal to confirm the new label displays correctly and remains prominently visible and easily accessible.

Step 2 — Calibrate the cancellation survey node

Recharge's cancellation flow includes a survey that asks customers why they are cancelling. You can use this survey to let customers indicate that they intend to withdraw rather than simply cancel, and to surface eligibility information.

Add a "Withdrawal request" reason

1. In the merchant portal, go to Cancellation prevention (sometimes shown under Retention or Customer portal settings).
2. Open the Cancellation flow editor and locate the cancellation reason survey node.
3. Add a new cancellation reason: "Withdrawal request".
4. Save the flow.

This lets a customer self-identify a withdrawal. Note that the customer selecting this reason does not by itself establish a valid withdrawal — you ultimately determine whether the customer withdrew within the applicable window (see Step 3).

Explain eligibility to the customer

To reduce confusion, use the survey node's text/description fields to explain who may be eligible to withdraw. For example, you might add helper text such as:

"Select 'Withdrawal request' if you are exercising your statutory right of withdrawal. This generally applies to EU residents who purchased within the last 14 days. We will confirm whether your request meets the requirements before processing."

Calibrate this messaging so the customer can clearly distinguish between:

• Cancelling a subscription (ending future billing), and
• Withdrawing from the contract (exercising a statutory right of withdrawal, which may entitle them to a refund if valid).

The exact wording, eligibility criteria, and disclosures you present should be reviewed and approved by your own legal counsel.

Step 3 — Identify, validate, and action withdrawal requests

As customers cancel going forward and select the "Withdrawal request" reason, you can review these requests and act on the valid ones.

Export and filter the activity report

1. In the merchant portal, go to Cancellation prevention → Activity.
2. Export the cancellation prevention activity report.
3. Filter the export by the cancellation reason "Withdrawal request" to isolate customers who indicated a withdrawal.

Validate the request

For each flagged customer, confirm whether the request is a valid withdrawal. This typically means confirming:

• The customer is an EU resident (or otherwise covered by the right of withdrawal), and
• The cancellation occurred within the applicable 14-day window from the relevant start/purchase date.

To check timing, you may need the subscription start date. You can run a subscription export from Recharge to obtain each customer's start date, then compare it against the cancellation date to determine whether it falls within 14 days.

Recharge does not determine validity for you. Confirming residency, the applicable window, and any other legal requirement is your responsibility and should be done in line with guidance from your legal counsel.

Action the valid request (refund)

For requests you determine to be valid withdrawals, process any required refund within the Shopify refund tools for that customer's order. Recharge does not issue these refunds automatically; you action them through Shopify.

Article 11a also requires that the trader send the consumer an acknowledgement of receipt of the withdrawal on a durable medium (including its content and the date and time of submission) without undue delay. Recharge's existing cancellation acknowledgement email — sent automatically when a subscription is cancelled — can serve this purpose, as it provides the customer a durable record of the cancellation including its date and time. Confirm with your counsel that your cancellation acknowledgement email's content and delivery satisfy the acknowledgement-of-receipt requirement for your business.

Quick reference

Support

This article describes how Recharge's existing tools can support a withdrawal experience. It is not legal advice and does not guarantee compliance. Your business is independently responsible for confirming its compliance needs, configuring its portal and cancelling flows accordingly, validating each withdrawal request, and actioning valid requests including refunds. Please consult your own independent legal counsel to confirm your unique business's compliance requirements and whether they are satisfied.