E-Commerce Changes 2026/2027

2026 and 2027 are shaping up to be two of the most heavily regulated years of the past decade for German online retail. The real problem is not a single rule – it is that several sets of regulations are being enforced at the same time and hit the same points in your shop: the checkout, the product data, the shipping packaging and every marketing claim.

This is no longer just about the “legally compliant shop” in the traditional sense. It is about transparency, product safety, sustainability, accessibility, platform and AI responsibility, and seamless provability – all at once. This article sorts the most important topics, explains the concrete consequence for your shop in each case, shows the opportunity for solid merchants and closes with a realistic effort estimate.

01Withdrawal button – mandatory from June 19, 2026

§ 356a BGB · EU Directive 2023/2673

After the cancellation button (2022), the next visible mandatory element follows. From June 19, 2026, businesses that conclude contracts with consumers through an online interface must provide a clearly recognizable electronic withdrawal function. The German implementing act was passed on December 19, 2025 and promulgated in the Federal Law Gazette on February 5, 2026 – so the deadline is fixed.

What this means for your shop: You need a clearly labelled button (e.g. “Withdraw from contract”) that is easy to find throughout the entire withdrawal period and leads to a working confirmation process – clearly separate from the cancellation button. The obligation applies regardless of company size, and also to merchants on marketplaces such as Amazon or eBay.

Concrete to-dos: Extend the customer account or shop front end with the function, connect your returns and reversal logic in the ERP/CRM cleanly to it, and ideally partly automate it. Anyone who solves this well also lowers their processing costs per return.

02Accessibility – already in force (BFSG / EAA)

Accessibility Strengthening Act (BFSG) since June 28, 2025

The most commonly underestimated topic – and it is already live. Since June 28, 2025, online shops that do not qualify as micro-enterprises must be accessible. There is no further transition period; market surveillance authorities have been able to carry out checks ever since. Since many shops are still not compliant, 2026 is a realistic year for warning letters and inspections.

What this means for your shop: Contrast, keyboard operability, screen reader compatibility, properly labelled forms, navigation, PDFs and above all the checkout become relevant. Shopify and WooCommerce themes, custom front ends, apps and product configurators are all affected alike. The WCAG 2.1 standard (Level AA) provides guidance.

Concrete to-dos: An accessibility audit with a prioritized action plan, theme or front-end adjustments, checkout hardening and an accessibility statement. The welcome side effect: better usability, clean semantic markup and higher conversion – which feeds directly into SEO and user guidance.

03EU Packaging Regulation PPWR – from August 12, 2026

Regulation (EU) 2025/40

The PPWR has been in force since February 11, 2025 and applies directly in all member states from August 12, 2026 – with no room for national implementation. In Germany, the existing Packaging Act is being replaced by a new implementing act. With their shipping packaging, online retailers place packaging on the market and are therefore generally covered.

What this means for your shop: It covers recyclability, recycled content, reuse quotas, uniform labelling and packaging minimization – for example restrictions on the empty space in oversized boxes. Registration, conformity and documentation obligations come on top. Important: some of the detailed requirements (design, recycling thresholds) are phased in only from 2028 onwards, but the legal framework itself applies from August 2026.

Concrete to-dos: Check your packaging range for recyclability, obtain recycled-content evidence from suppliers, adjust fulfilment processes and box sizes, and set up the registration and documentation chain. Cross-border commerce in particular becomes more complex – but structured packaging documentation becomes a differentiator.

04Greenwashing ban (EmpCo) – from September 27, 2026

EmpCo Directive (EU) 2024/825 · implemented in the UWG

One important point needs correcting here, because it often gets mixed up: the much-cited Green Claims Directive is currently suspended at EU level. What applies as binding law instead is the EmpCo Directive (“Empowering Consumers”). The Bundestag passed the implementation into the UWG on December 19, 2025; it was promulgated in the Federal Law Gazette on February 19, 2026. From September 27, 2026, it applies as binding law – to every business with end-customer contact, with no exceptions by size.

What this means for your marketing: Blanket terms such as “sustainable”, “climate neutral”, “eco-friendly”, “green” or “biodegradable” will only be permitted in future with recognized proof of performance. Four categories are clearly prohibited: generic environmental claims without evidence, company-owned seals without external certification, purely offsetting-based climate-neutrality claims, and whole-product claims when only one aspect is affected.

Concrete to-dos: Screen product texts, categories, packaging prints, ads and social media statements for environmental terms, document your evidence, and review proprietary seals. Brand and company names with an environmental reference are affected too.

05GPSR – product safety, now with real teeth

General Product Safety Regulation (EU) 2023/988

The GPSR is already active, but only becomes truly noticeable in practice in 2026 – above all through more consistent enforcement. Depending on the product, merchants must provide manufacturer details, warnings, safety information, a responsible person in the EU and clear product identification.

What this means for your shop: The problem is rarely willingness, but the data situation – many merchants have not stored this information in a clean, structured way. Amazon sellers, dropshipping models, China imports and small merchants without a PIM are particularly affected.

Concrete to-dos: Store the mandatory information per product in a structured way in your PIM/shop, name the EU responsible person, and close the supplier data chains. Anyone who builds structured product data here not only meets the GPSR but lays the foundation for all the points that follow.

06AI labelling obligation – from August 2, 2026

EU AI Act · Article 50 · Reg. (EU) 2024/1689

The topic that affects almost every shop with a modern marketing or service department – and is often overlooked. Article 50 of the EU AI Act introduces transparency obligations for AI content that apply regardless of risk class. The deadline is August 2, 2026.

What this means for your shop: You are affected if you use AI-generated images in marketing, run an AI chatbot, work with voicebots or publish AI-generated texts on topics of public interest. AI-generated product or mood images – for example an artificially generated “stock photo” of a person – must be recognizable as artificially generated. Pure retouching, colour correction or an obviously stylized logo or abstract graphic, on the other hand, do not fall under this. For chatbots, there is an additional rule: users must know they are talking to an AI.

Concrete to-dos: Take stock of the AI tools in use (e.g. image generators, chatbots, text AI), define clear labelling workflows – such as labels on AI images, notes below texts, disclosure in the chatbot – and document responsibilities. Tip: A visible AI label tends to build trust rather than deter today – transparency becomes a quality signal.

07What else is coming in 2026/2027

DPP · Warranty labels · AI transparency · CRA · Platform liability

Digital Product Passport (DPP). Products receive digital identities covering origin, materials, repairability, supply chain and recycling – usually via QR code or NFC. Initially for certain product groups (starting with batteries, among others), later more broadly. At its core: “Schema.org + supply chain + sustainability + product history”.

Warranty & guarantee labels. Structured mandatory information on the statutory warranty, voluntary guarantee, durations and conditions is on the horizon – especially critical for electronics, furniture, household appliances and on marketplaces. This requires new data fields and PIM adjustments.

AI & platform transparency (outlook). Beyond AI labelling (section 06), AI-generated reviews, manipulated fake reviews and AI avatars are gradually moving into sharper focus – driven by the EU AI Act and unfair competition law.

Cyber Resilience Act. Relevant for smart devices, IoT, apps and software: manufacturers must demonstrate security by design and security updates. Merchants face indirect liability pressure via the platforms.

More responsibility for marketplaces. Amazon, Temu, AliExpress & Co. are coming under pressure; the EU is moving toward joint liability. The consequence: stricter product checks, more documentation obligations, tougher seller checks and automated compliance reviews.

The opportunity: turning obligation into a trust and visibility advantage

The decisive strategic point: almost all of the new rules generate structured trust data. Verified manufacturer details, durability, warranty, safety information, sustainability data, origin and clear responsibilities – exactly what Google, AI Overviews, ChatGPT, Perplexity and Gemini will favour in the long run.

Anyone who provides this data cleanly, in machine-readable form and structured via Schema.org not only meets legal requirements but becomes citable for AI systems and a verifiable source. In the medium term, compliance data becomes a real ranking and trust factor – visibility will emerge where provability lies.

Online retail is evolving from the “website with a shopping cart” into a fully documented, verifiable trust and product system.

Effort estimate at a glance

A rough guide for a typical SME shop. Actual effort depends heavily on the system (Shopware/Shopify/Woo), range size and data quality.

Strategic recommendation: The biggest efforts – accessibility, GPSR product data and DPP – share a common core: clean, structured data. Anyone who sets this up properly once (PIM, Schema.org, documented processes) serves several requirements at the same time and builds the decisive visibility advantage in AI search systems in parallel. This is exactly where the lever lies for solid merchants who act quickly.

This article is for general orientation and does not constitute legal advice. Legal status researched in May 2026; details of individual regulations are in part still being specified by delegated acts and national implementing laws. Please have your individual case reviewed by a professional.