Shopify Legal Requirements in Germany 2026: Legal Texts & Duties

In short: Shopify's own templates don't cover the Shopify legal requirements in Germany. Your store becomes legally compliant with vetted legal texts (imprint/Impressum, privacy policy/Datenschutzerklärung, withdrawal notice/Widerrufsbelehrung, terms and conditions/AGB), a correct checkout and the duties added in 2026: the withdrawal button (since June 19, 2026) and the EU legal guarantee label (since September 27, 2026). On top of that come product safety details under the GPSR, LUCID registration and real cookie consent. The easiest way to stay up to date is a legal-text provider with an update service.

"Is that really everything I need to be legally compliant?" That question sits under almost every Shopify tutorial, and the answer is usually no. This article walks you through the Shopify legal requirements in Germany: how to set up your Shopify store so it holds up under German law, which duties are new in 2026 and where you implement them in Shopify. It is part of our overview Law and taxes for Shopify stores in Germany.

Who sends warning letters and why Shopify templates are not enough

In Germany, formal warning letters (Abmahnungen) mainly come from competitors, trade associations and consumer protection associations. Since 2020, competitors can no longer claim warning-letter costs for breaches of information duties in online retail or for GDPR breaches by smaller companies (§ 13(4) UWG (German)). That has reduced the number of mass warning letters. Associations can still send them, though, and a cease-and-desist declaration (Unterlassungserklärung) binds you all the same. Working in a legally compliant way is still a must.

Shopify offers templates under "Settings > Policies". Shopify itself states that you are responsible for compliance with your policies. The templates are not tailored to German consumer law: they lack, for example, the model withdrawal form, the details required under § 5 DDG and the notices added in 2026.

TextMandatory?Legal basisWhere in Shopify?
Imprint (Impressum)Yes§ 5 DDGOwn page or policy, linked in the footer
Privacy policy (Datenschutzerklärung)YesArt. 13 GDPR (DSGVO)"Privacy policy" policy
Withdrawal notice (Widerrufsbelehrung) + model withdrawal formYes, when selling to consumers§ 312d, § 355 BGB, Art. 246a EGBGB"Refund policy" or own page
Terms and conditions (AGB)No, but strongly recommended§§ 305 ff. BGB"Terms of service" policy
Shipping and payment infoYes (delivery times, shipping costs, payment methods)Art. 246a EGBGB, PAngV"Shipping policy" and own page

For sole proprietors, the imprint must contain your first and last name, an address that can receive mail (no PO box), an email address and another fast way to contact you (in practice usually a phone number); the VAT ID only if you have one (IHK Regensburg (German)). Which address to use if you want to protect your home address is explained in our article Trade registration for your online store.

You should remove or update two leftovers now:

  • ODR link: The EU online dispute resolution platform was shut down on July 20, 2025. The duty to link to it no longer applies, and an outdated notice can be considered misleading (IHK Schwaben (German)).
  • Consumer dispute resolution: The notice under § 36 VSBG on whether you take part in dispute resolution proceedings is still mandatory, unless you have no more than 10 employees.

Shopify automatically links the policies from "Settings > Policies" in the checkout footer. On all other store pages, you have to add them to your theme's footer menu yourself. The imprint must be reachable from every page in no more than two clicks. How to edit the footer and menus is shown in Customizing your Shopify theme.

It is usually one of these three things:

  1. Add the text as a policy: Under "Settings > Policies" there is also a dedicated "Imprint" field (Shopify Help Center). You then don't need an extra page.
  2. Add it to the menu: Under "Content > Menus", open the footer menu, click "Add menu item", search for the policy, add it and save. If the item points to an empty page, only the theme's placeholder text appears.
  3. Select the menu in the theme: In the theme editor, check whether the footer section has a menu block and that exactly this menu is selected there.

Where to get the texts

Copying is not a solution: other stores' legal texts don't fit your store, are often outdated and may themselves be protected by copyright. Realistically, you have three options:

OptionFor whomWhat to watch for
Legal-text provider with update service, e.g. IT-Recht Kanzlei, Händlerbund, Trusted Shops, eRecht24Most storesMonthly subscription. IT-Recht Kanzlei offers a Shopify interface that updates the texts automatically. Händlerbund lists legal texts from €9.90 per month net with a 12-month term. Check whether protection against warning letters or assumption of liability is included.
Free generatorsFor testing, very small storesUsually without updates and without liability. You have to add new duties such as the withdrawal button yourself.
IT law attorney, custom textsSpecial business models (subscriptions, B2B, personalized goods)More expensive, but tailored. Agree on updates separately.
AI texts, e.g. with ChatGPTNot suitable as a replacementNo review, no liability, often outdated or made-up requirements. Use them at most to understand the terms.

A subscription is worth it not for the one-time texts but for the updates. 2025 and 2026 brought the end of the ODR platform, the BFSG, the withdrawal button and the legal guarantee label. If you copied your texts once, you missed all of that.

Can I cancel the subscription once the texts are done?

Usually not, at least not if you want to keep using the texts. With subscription providers, the right of use is tied to the term. IT-Recht Kanzlei, for example, states for contracts from August 1, 2019: "The right of use expires when the termination takes effect", and the texts must then be removed from all pages (according to Händlerbund (German)). Onwalt (German) also grants the right of use "only for the duration of your contract". If you keep using them anyway, you risk copyright infringement and lose the updates.

If you actively sell to Austria, Switzerland or other EU countries, ask your provider for matching texts. IT-Recht Kanzlei, for example, lists legal texts for 21 countries.

Withdrawal button under § 356a BGB (since June 19, 2026)

Since June 19, 2026, online stores in Germany must offer consumers an electronic withdrawal function. A regular contact form or the email address in the withdrawal notice is no longer enough. The requirements according to the law and IHK Ulm (German):

  • Clearly labeled "Vertrag widerrufen" (withdraw from contract) or equivalent, highlighted and easy to access. An inconspicuous text link in the footer is unlikely to be enough.
  • Available throughout the entire withdrawal period, generally also without login and for guest customers.
  • It asks for the name, details identifying the contract (e.g. order number) and the channel for the confirmation of receipt. You should not ask for a reason or other mandatory details.
  • Then a confirmation page with a button such as "Widerruf bestätigen" (confirm withdrawal).
  • A confirmation of receipt without delay on a durable medium (e.g. email) with the content, date and time.

The withdrawal notice also has to be updated: the statutory model now refers to the withdrawal function. You usually need an app or a solution from your legal-text provider for this. Händlerbund, for example, offers its members an embed snippet. Our own app EU Withdrawal Form & Button by Appsentials adds the withdrawal button and withdrawal form to your store, sends the customer a confirmation email and tracks the 14-day period in a dashboard. There are other apps for the same duty in the Shopify App Store. Compare which solution fits your legal texts.

When is there no right of withdrawal?

The button doesn't change when a right of withdrawal exists. Two exceptions from § 312g(2) BGB are particularly relevant for Shopify stores:

  • Personalized goods: Products made to customer specifications (e.g. with a name, photo or custom design) are excluded from withdrawal. This does not apply to standard goods where the customer only chooses between variants.
  • Sealed hygiene products: Only if the goods were delivered sealed and the seal has been removed. You cannot generally exclude swimwear or underwear without a seal.

State the exception clearly in the withdrawal notice and on the product page. Personalizations should be technically and unambiguously recognizable as such. How to set this up properly for name or photo products is shown in Selling personalized products with Shopify.

Two cases that are often misjudged:

  • Print on demand: A shirt with your standard design that is only printed after the order is not made to customer specifications. The right of withdrawal applies here. The fact that your print provider doesn't accept returns changes nothing. Plan for the costs.
  • Downloads and digital content: A checkbox alone does not exclude withdrawal. The right only expires if the customer expressly agrees to immediate access, confirms that they lose their right of withdrawal as a result, and you confirm this to them (§ 356(6) BGB). Details are in Selling digital products with Shopify.

Legal guarantee label and GARAN label (since September 27, 2026)

Since September 27, 2026, retailers who sell goods to consumers must point out the statutory legal guarantee (Gewährleistung) with a uniform EU label. The legal basis is Implementing Regulation (EU) 2025/1960. According to IHK Dresden (German), the following applies online:

  • Legal guarantee label (always mandatory): the unchanged template from the EU Commission, in color, with QR code, clearly visible before the contract is concluded, e.g. on the product page or in the checkout.
  • GARAN label (only with a manufacturer's guarantee): if the manufacturer gives a free durability guarantee of more than two years. In that case in color next to the product image and additionally in the cart or on the last order page.
  • Additionally on a durable medium: Both labels are also part of the mandatory information provided with the order confirmation, for example as a PDF.

The EU Commission provides the templates in its Practical Guidelines. You can add the label to your theme and the order email yourself or use an app. Our app EU Warranty Label GARAN shows the legal guarantee notice with the official template and QR code as a block on the product page. The Pro version adds the GARAN label per product, a snippet for the order confirmation and display in the cart and checkout. Here too: compare it with your legal-text provider's solutions.

Checkout and price display

  • Order button: The last button must make clear that the order involves an obligation to pay, e.g. "zahlungspflichtig bestellen" (order with obligation to pay) (§ 312j(3) BGB). Check the label in your checkout.
  • Terms checkbox: Not mandatory. A clear reference to the terms before the order is enough. A mandatory checkbox for the privacy policy is not needed either.
  • Prices: Final prices including VAT and a note on additional shipping costs. Under the small business rule (Kleinunternehmerregelung) no "incl. VAT"; instead, a note on § 19 UStG next to the price is common. This note doesn't belong in the imprint, but it is mandatory on the invoice. For goods sold by weight, volume or length, state the unit price. How to set up tax display correctly is covered in Setting up taxes in Shopify.
  • Discounts: If you advertise a price reduction, you must state the lowest price of the last 30 days (§ 11 PAngV). This affects crossed-out "compare-at prices" in Shopify.
  • Invoices: Shopify sends an order confirmation, but not an invoice with a sequential invoice number that meets German requirements. How to create invoices, cancellation invoices and receipts properly is covered in Invoices and accounting in your Shopify store.

Product duties: GPSR, CE, packaging

This is where the most expensive mistakes happen, especially with goods from China.

  • GPSR (Regulation (EU) 2023/988): Since December 13, 2024, listings must include: the manufacturer with postal address and electronic address, for manufacturers outside the EU the responsible person in the EU, details identifying the product including an image, and warnings and safety information in German (regulation text). Where this belongs on the product page is shown in The perfect Shopify product page.
  • CE and labeling: Even as a retailer, you have to check whether required markings such as CE are present. For electrical devices and batteries, registration duties apply as well (e.g. with stiftung ear). Suppliers without an EU responsible person and without documentation are a deal breaker. What to look out for is covered in Finding reliable dropshipping suppliers.
  • Packaging Act (Verpackungsgesetz): If you sell packaged goods in Germany, you must register in the LUCID packaging register, including for shipping boxes and filling material. Registration is free. For the packaging, you also need a contract with a dual system, which costs money.

Are you liable for products from China?

Yes, and more than many people think. Under the German Product Liability Act (Produkthaftungsgesetz), anyone who imports a product into the European Economic Area also counts as a manufacturer (§ 4(2) ProdHaftG). If no manufacturer can be identified, even the retailer may be liable if they don't name their supplier in time (§ 4(3) ProdHaftG). So if a charger causes a fire, the claim can quickly land with you. Three things help:

  • Choose suppliers with an EU responsible person, test reports and a declaration of conformity. For jewelry this is about nickel, for example; cosmetics and toys have their own rules, see Prohibited and regulated products on Shopify.
  • Business liability insurance with product liability coverage that includes online retail and imported goods.
  • Archive sources and invoices so you can name the manufacturer and supplier at any time.

Cookie consent and tracking

Cookies and pixels that are not technically necessary may only run after active consent (§ 25 TDDDG, GDPR). Shopify has its own cookie banner under "Settings > Customer privacy > Cookie banner". It is shown automatically to visitors from the EEA when markets are active. A published privacy policy is required (Shopify Help Center).

According to Shopify, the banner covers Shopify's own tools. If you have embedded external scripts, your own pixels or apps that don't respect the banner, you need a consent app from the "Cookie consent" category. After setting it up, check in your browser that no tracking requests really go out before the click on "Accept". If your Meta pixel then reports fewer events, that's not an error but the result of consent: visitors who decline are not tracked. More on this in Setting up tracking in Shopify.

Accessibility (BFSG)

Since June 28, 2025, the German Accessibility Strengthening Act (Barrierefreiheitsstärkungsgesetz, BFSG) also applies to online stores. Exempt are micro-enterprises that provide services and have fewer than 10 employees and no more than €2 million in annual turnover or balance sheet total (IHK Berlin (German)). Most beginners fall into this category. Good contrast, alt texts and a usable checkout are still worth it because they work better for all customers.

Checklist: Shopify legal requirements in Germany

ItemDone when …
Imprintcomplete under § 5 DDG, in the footer of every page
Privacy policynames Shopify, payment providers, apps and tracking
Withdrawal notice + formcurrent model with reference to the withdrawal function
Withdrawal button"Vertrag widerrufen" clearly visible, confirmation page, receipt email
Legal guarantee labelvisible in color before the contract is concluded and with the order confirmation
Terms, shipping, paymentadded under "Settings > Policies"
ODR linkremoved; VSBG notice checked
Pricesincl. VAT (or § 19 note), shipping costs, unit price, 30-day lowest price
GPSRmanufacturer, EU responsible person, warnings on every product page
LUCIDregistered, dual system contract in place
Cookie consentno tracking before consent

These items also belong in your pre-launch checklist.

FAQ

Is it enough to fill in the policies in the Shopify settings?

Almost. Shopify automatically links texts added under "Settings > Policies" in the checkout. On regular store pages, however, they only appear once you add them to your theme's footer menu. The imprint and privacy policy must be reachable from every page. Also, the content of Shopify's templates is not enough for Germany.

Can I copy the terms and imprint from another store?

That's not advisable. Other stores' texts don't match your product range, payment methods and delivery times, are often outdated and may be protected by copyright. The duties from 2025 and 2026 in particular are almost always missing from copied texts. A legal-text subscription with an update service costs little compared to a warning letter.

Does the imprint need my address or Printful's?

Yours. The imprint states who operates the store and is the customers' contractual partner, which is you. The fulfillment partner's address has no place there. Manufacturer details required by the GPSR, on the other hand, belong on the product page. Who counts as the manufacturer in print on demand depends on the setup. Clarify this with your provider or your legal advisor.

Do I need a checkbox for the terms in the checkout?

No, a mandatory checkbox is not required in Germany. It is enough if the terms are clearly referenced before the order and the customer can open and save them. More important is the correct label on the order button, such as "zahlungspflichtig bestellen" (order with obligation to pay). Shopify automatically links your saved policies in the checkout footer.

Is the Shopify cookie banner GDPR-compliant?

For Shopify's own features, it is built to collect consent and is active by default for EEA visitors. Whether your store as a whole is compliant depends on your apps and pixels. If they load before consent, even the best banner won't help. Test this with your browser's developer tools or use a specialized consent app.

What does a warning letter cost if I forgot something?

That depends on the breach and on who sends the warning letter. Competitors can no longer claim warning-letter costs for breaches of information duties in online retail, but associations can. More expensive than the warning letter itself is often the cease-and-desist declaration with a contractual penalty. Don't sign anything without checking it and get advice from a lawyer specializing in IT or competition law.

Last updated: October 2026. The legal situation and provider offers change; check details with the linked sources. This article is not legal or tax advice.

Appsentials

The matching app.

We build Shopify apps for EU merchants. This one solves the topic of this article:

EU Withdrawal Form & Button

Withdrawal button and withdrawal form for your store, multilingual, with dashboard, email notifications and deadline tracking.

Free plan availableView in the App Store →
EU Warranty Label GARAN

The harmonised EU legal guarantee notice under Regulation (EU) 2025/1960 as a product page block, optionally with the GARAN durability label.

Free plan availableView in the App Store →