Belgian consumer law reform: new rules on online sales, subscription renewals, sustainability claims and consumer complaints

Belgium has introduced a series of consumer law reforms that will affect online sales, subscription services, sustainability claims and consumer dispute resolution. Businesses should assess their customer journeys, contract management processes and marketing practices now to ensure compliance with the new requirements and avoid regulatory scrutiny.

1. New online withdrawal requirements for B2C e-commerce

On 19 July 2026, Belgium transposed Directive (EU) 2023/2673 into national law and introduced an additional online withdrawal function for B2C distance contracts concluded through an online interface. The aim is simple: consumers should be able to withdraw from an online contract as easily as they entered into it. 

Under new Article VI.61/2 of the Belgian Code of Economic Law (applicable as from 14 August 2026), businesses must provide an online withdrawal function clearly labelled “withdraw from the contract here” or with an equally clear and unambiguous formulation. The function must be prominently displayed on the online interface, easily accessible and continuously available throughout the withdrawal period.

Consumers should not have to take unnecessary steps to access the function, such as downloading an app that was not used to conclude the contract. Businesses may also provide a direct hyperlink to the withdrawal function. 

The withdrawal process must consist of two steps: 

• Withdrawal declaration: The consumer provides or confirms their name, the details needed to identify the relevant contract and the electronic address to which the acknowledgement should be sent.
• Confirmation: The consumer confirms the withdrawal through a separate button labelled “confirm withdrawal” or an equally unambiguous formulation.
• Once confirmed, the business must promptly send an acknowledgement via a durable medium, specifying the content of the withdrawal and its date and time of submission.  

The new requirement applies to B2C webshops and online providers of subscriptions, memberships and digital services, provided that the consumer has a statutory right of withdrawal. Consumers purchasing goods or services online generally have 14 days to withdraw from the contract without giving a reason. 

The online withdrawal function complements the existing methods of withdrawal without creating a new right or altering the applicable exceptions. Consumers may still use the existing model withdrawal form or otherwise communicate their decision through an unequivocal statement. 

Practical takeaway: Companies offering products or services online should review their customer journeys, withdrawal notices and website functionalities to ensure that consumers can exercise their withdrawal right through a compliant two-step online process. Existing withdrawal instructions and template disclosures should also be updated to reference the new withdrawal function and the consumer’s right to receive an electronic acknowledgement of withdrawal.

2. Automatic renewal clauses: new consumer reminder obligation

The Act of 20 April 2026 imposes a new obligation on businesses to remind consumers before automatically renewing fixed-term contracts concluded for more than one month.  

The reminder must clearly and unambiguously inform the consumer of: 

• the upcoming automatic renewal; and
• their right to cancel the renewal. 

The reminder must be provided via a durable medium, such as email or letter, no later than 15 days before the deadline for cancelling the renewal. Importantly, the relevant date is therefore not the renewal date itself, but the final date on which the consumer can cancel the renewal.  

The obligation applies to fixed-term B2C contracts containing an automatic renewal clause. Such clauses are commonly used for streaming subscriptions, fitness memberships, mobile applications and other recurring services. Without a timely reminder, consumers may remain unintentionally tied to a contract because they were unaware of the upcoming renewal or the deadline for cancelling it. 

The new reminder obligation supplements the existing Belgian requirements governing the content and presentation of automatic renewal clauses. It can be found in Article VI.91, § 1/1 of the Belgian Code of Economic Law and will apply from 1 May 2027. 

Practical takeaway: Organisations relying on automatically renewed consumer contracts should identify the affected products and services, map cancellation deadlines and build compliant reminder mechanisms into their CRM or subscription management systems. The content of renewal notices should also be reviewed to ensure that consumers are clearly informed of both the upcoming renewal and their right to cancel it.

3. Sustainability claims and product transparency: Belgium implements the Green Transition Directive

Belgium has adopted new legislation implementing the EU’s Empowering Consumers for the Green Transition Directive (2024/825). The reform introduces enhanced transparency requirements regarding product durability and reparability, strengthens restrictions on environmental marketing claims and expands the list of unfair commercial practices. The new rules will apply from 27 September 2026 and are expected to have a significant impact on consumer-facing communications and sustainability marketing strategies.

The legislation amends the Belgian Code of Economic Law to provide consumers with clearer and more harmonised information on the durability and reparability of products. Businesses will be required to disclose, where relevant, information such as the minimum period during which the manufacturer or supplier provides software updates, repairability scores, spare parts availability and repair instructions. Commercial durability guarantees exceeding two years must also be highlighted through a harmonised label.

The new framework also introduces stricter rules against greenwashing. Generic environmental claims will only be permitted where they can be substantiated by recognised environmental performance. Sustainability labels must be based on approved certification schemes or established by public authorities. Companies will furthermore be prohibited from presenting compliance with legal requirements as a unique product benefit or from claiming climate neutrality solely on the basis of carbon offsetting mechanisms.

In addition, the law expands the list of unfair commercial practices. Businesses may no longer conceal software updates that negatively affect product performance, misrepresent the durability or reparability of goods, or encourage unnecessary replacement of consumables. The objective is to help consumers extend product lifecycles and make more sustainable purchasing decisions.

A transitional regime applies to certain new offences relating to environmental claims and unfair commercial practices. For products manufactured, packaged or placed on the market before 27 September 2026, the new penalties will not apply for a period of six months following the law’s entry into force.

The reform reflects the growing regulatory focus on sustainability claims and product longevity, requiring businesses operating in Belgium to review their marketing practices, consumer-facing information and environmental messaging ahead of the new rules taking effect.

Practical takeaway: Marketing, compliance and product teams should conduct a sustainability claims review before 27 September 2026. Environmental statements should be supported by solid evidence, sustainability labels should be verified and any claims relating to durability, reparability or climate impact should be reassessed. Businesses selling connected products should also ensure that required information on software updates, spare parts and repair options is readily available to consumers. Given the increased focus on greenwashing enforcement, organisations may wish to implement an internal approval process for environmental claims and product sustainability communications.

4. Consumer complaints: mandatory participation in Ombudsman proceedings on the horizon

Consumer Protection Minister Rob Beenders has announced a reform of the Belgian Consumer Ombudsman Service that is expected to enter into force on 1 January 2027. Under the proposed framework, businesses would be required to cooperate with mediation proceedings and pay a fee for each admissible complaint handled by the Ombudsman Service. The initiative aims to encourage businesses to resolve complaints at an earlier stage and improve overall customer service standards.

Practical takeaway: Businesses should reassess their consumer complaint management procedures. As each admissible complaint may trigger a financial cost and mandatory participation in mediation, organisations may benefit from strengthening their internal complaint handling processes, escalation mechanisms and customer service functions in order to resolve disputes before they reach the Ombudsman Service.