Scope: EU consumer sales and separate China supplier contracts
A customer in Germany wants to return an online purchase. Your Chinese supplier refuses a refund because its business-to-business contract permits returns only for proven defects. Your support team is caught between the two positions.
EU consumer returns should be assessed under the customer-facing rules that apply to the sale. Your ability to recover money from the supplier is a separate contractual question. Treating them as one issue can produce an incorrect customer response and an unprepared supplier claim.
Identify why the customer is returning the item
Distinguish withdrawal from a qualifying distance purchase, a complaint about faulty goods and a voluntary commercial returns offer. EU guidance describes a general 14-day withdrawal right for distance sales, subject to exceptions, and separate legal protection for faulty goods. The category matters: an item need not be defective for a qualifying withdrawal. Your Europe business guidance.
Record the delivery date, request date, product type and the information supplied before purchase. Check the relevant national rules before relying on an exception or imposing a deduction. A blanket “no refunds” message is a poor substitute for deciding which right is being exercised.
Review the route customers use to withdraw
Directive (EU) 2023/2673 introduces an online withdrawal function for relevant contracts concluded through an online interface, with national implementing measures to apply from 19 June 2026. Review the rules applicable in your target markets and test the actual customer journey, including acknowledgement, rather than relying only on a policy page. Official amending directive.
Create a separate supplier recovery file
A consumer changing their mind does not establish that the factory breached its contract. For defective goods, preserve the specification, batch identifiers, complaint evidence and supplier notification. Compare the remedies promised to your customers with those negotiated upstream.
Map the cost categories separately: customer reimbursement, outbound shipping, return handling, testing and any recoverable supplier amount. Do not promise that every customer refund can be passed through to the factory.
Fix the operational gap before the next promotion
Give support staff a decision tree showing who reviews withdrawals, defects and exceptions. Ask logistics to identify a workable return route, and finance to reconcile approved refunds with supplier claims. Review marketplace obligations separately where a platform is involved.
Are returns exposing a gap in your supply chain contracts? Contact Jinyuan Law Firm with your target EU countries, customer policy and supplier agreement. Request a coordinated review of the China contract and the issues requiring advice from qualified counsel in the relevant EU market.
Related reading: Selling China-Made Products in the EU? Your Listing Is Part of the Safety Review.
General information only. Advice depends on the facts and applicable jurisdiction. Contact does not by itself create a lawyer-client relationship. Local-law advice may be needed outside mainland China.
