Shipping, fulfilment and returns: what Irish eCommerce brands overlook in Germany
TL;DR
Difficulty: Intermediate
- Germany moved about 4.6 billion parcels in 2024, most delivered within a day or two. An Irish parcel is judged against that.
- Inside the single market there is no customs, no duty and no import VAT. The new €3 flat duty is for parcels from outside the EU, so keep it out of your prices.
- Stock in a German warehouse ends the One Stop Shop route for those orders: they become German domestic sales and need a German VAT registration.
- A German 3PL pays once the saving per order covers its fixed monthly cost. Without duty to save, count the returns in that saving or it rarely pays.
- Returns are a legal right: refund within 14 days, return transit risk is yours, and almost nine in ten German retailers offer free returns.
A German customer judges an Irish shop on the parcel as much as on the product: how fast it comes, who brings it, and how easily it goes back. I work through carriers, delivery promises, Irish dispatch against a German warehouse and its VAT, the break even for a fulfilment partner, and returns in law and in euro, using one invented Cork shop.
The point: in Germany the parcel is part of the product
A German customer judges an Irish shop on the product page, then again when the parcel turns up, and again when something goes back. Germany moves billions of parcels a year, most within a day or two, and a good few of them come back. That is the standard your parcel from Cork is measured against.
This article is about the operations: the carrier, the delivery promise, where to keep the stock and what that does to your VAT, when a fulfilment partner pays, and how returns work in law and in money. One invented shop goes through every step, in euro.
The legal setup, from the VAT routes to the withdrawal notice, is in the cross border setup steps for Germany, and I link to it rather than repeat it. This is guidance from someone who builds these shops, not legal or tax advice. Check your case with your own accountant at home and a German Steuerberater (a tax adviser licensed in Germany).
The example shop, running kit from Cork
Mardyke Running is made up. Clodagh runs it from a unit in Cork and sells online at mardykerunning.example. Two products matter here: a technical running top at €44, sewn for her by a small factory in Cork, and running socks at €10 a pair.
German runners find her through Strava clubs and Instagram. Her sales to consumers in other EU countries are above the €10,000 threshold, so her German orders carry German VAT, declared through the One Stop Shop with Revenue, as in the setup article. Her typical German basket is one top and two pairs of socks, €64 including German VAT. She expects 150 German orders a month. Every number about Mardyke is invented. Every figure about the market is sourced.
What German buyers are used to
Start with the size of the habit. The Bundesnetzagentur, the German regulator for post and parcels, collects volumes from the carriers every year.1
The line runs along the years and up in billions of parcels. It climbs from 2.66 billion in 2017 to 4.6 billion in 2024, with a jump in 2020 and 2021 and a dip in 2022. The 2025 figure, 4.83 billion, was published in December 2025, so treat it as provisional. The takeaway: parcels are an everyday utility in Germany, and your customer knows exactly what normal feels like.
Speed is the second part of normal. Sendcloud, a shipping software company, analysed more than 10 million shipments from small German online merchants between the third quarter of 2025 and the second quarter of 2026. Measured from the first scan at the sorting centre to the first delivery attempt, DHL delivered 72.9% on the next business day and 94.5% within two.2 That is the domestic benchmark. A parcel from Ireland cannot match it. There is no customs border on the way, but there is a stretch of sea and a handover between carriers.
And when it goes wrong, Germans give out about it. In 2025 the Bundesnetzagentur received 55,395 complaints about postal services, and 20,190 of them, about 36%, were about parcels.3
The carrier the customer meets is German
Whichever Irish service you book, the last stretch to the door is almost always run by a carrier in Germany. That is the company whose van, tracking page and missed delivery card your customer sees. In the private customer segment the market is highly concentrated, and Deutsche Post DHL carries most of the volume.4
In my experience three things make a cross border parcel feel local: tracking that works on the German carrier's own site, in German, an address form that accepts a parcel locker or a neighbour, and a shipping email that names the German carrier.
The way to compare services is not the price per parcel. It is the price plus the expected cost of what goes wrong. Expected value is the sum of each outcome's cost weighted by its probability:
Here is the expected extra cost per parcel, is the probability of outcome (a support ticket, a parcel returned as undeliverable) and is what that outcome costs you. The idea is explained from scratch in Foundations: expected value.
Worked example: two carrier quotes for Clodagh
All prices and rates here are invented. Get your own quotes and measure your own failure rates.
Step one, the quotes. Service A costs €9.80 per parcel, hands over to a German carrier with German tracking, and accepts parcel locker addresses. Service B costs €8.60, but its tracking goes quiet once the parcel leaves Ireland and it rejects locker addresses.
Step two, what goes wrong. With service A, Clodagh expects 1% of parcels to come back undeliverable, costing her €30 each to reship, and 4% to generate a "where is my parcel" email, costing €4 of her time each. With service B, she expects 4% undeliverable and 12% emails.
Step three, service A.
With , , and , the expected extra cost is €0.46, so service A really costs €10.26 a parcel.
Step four, service B.
With and , the expected extra cost is €1.68, so service B really costs €10.28. The €1.20 saving has gone, and that is before the customer who never orders again. The weighting is the expected value from Foundations: expected value. Clodagh books service A.
A delivery promise you can keep
German shops state a delivery time in working days, and German buyers read it before they buy. Promise what the lane really does, not what the carrier manages on its best day.
An example: Clodagh's carrier quotes three to five working days from Cork to German addresses. In the shops I have worked on, that holds for tracked services most of the year and slips in December. A customer in Köln orders at 4pm on a Thursday, after her 2pm cutoff, so the parcel leaves on Friday. Three working days later is Wednesday, five is Friday. Her product page says "Lieferzeit 3 bis 5 Werktage nach Deutschland" and her checkout shows Wednesday to Friday. German public holidays vary by state, so the calculation uses the customer's postal code.
Duties at the door: there are none, so do not price for them
Shops outside the EU have a whole extra problem at this point. An Irish shop does not. The EU is a customs union: customs duties between Member States, and any charge with the same effect, are prohibited.5 A parcel from Cork to Köln crosses no customs border, pays no duty and no import VAT at the door, and needs no customs declaration, no proof of origin and no customs number.
The change you may have read about does not touch you either. Since 1 July 2026, parcels worth less than €150 that come into the EU from outside pay a flat customs duty of €3 per category of item, and import VAT on top.6 That is a charge on goods entering the EU. Your parcel is already inside.
In my experience the mistake here runs the other way. Irish shops that hear about the new duty sometimes add a margin for "customs" to their German prices, or copy a line about possible import charges from a British competitor's delivery page. Both cost you. The first makes your prices look high next to German shops, and the second makes a German customer hesitate over a charge that will never come.
Worked example: the duty on Clodagh's basket
Step one, count the categories. A top and socks are two categories. For a shop outside the EU that would be €6. For Clodagh it is nothing, because the parcel never enters the EU from outside.
Step two, check where the goods came from. Her tops are sewn in Cork and her socks come from a supplier in Portugal. Both are in free circulation in the EU, so neither raises a customs question on the way to Germany.
Step three, the decision. Her German delivery page says plainly that there are no customs charges and no import fees, and her German prices carry German VAT and nothing else.
Fulfilment option one: ship everything from Ireland
Most shops start here. Stock stays in Ireland and each German order travels on its own. No stock is tied up abroad, and the VAT route is the distance sale route from the setup article: Irish VAT while your sales to consumers in other EU countries stay at or under €10,000 a year, German VAT through the One Stop Shop (OSS), Union scheme, with Revenue once you go over or opt in early.78 For a business established in the EU, the OSS is run by the country where it is established, so Revenue.9 But two costs grow with every order: international postage, and returns that travel all the way back.
An example: Clodagh's cost of getting one typical basket to a German door from Cork is the €9.80 postage, and nothing else at the border, before anything comes back.
Fulfilment option two: stock in Germany, and what it does to your VAT
Once volume grows, the obvious move is stock in Germany. Parcels get faster and the postage drops to a domestic German rate. But the VAT changes completely, and this is the part Irish shops most often get wrong, because inside the single market it feels as though nothing has moved.
The EU VAT Directive sets the place of a sale. Normally a sale takes place where the goods are when the transport to the customer begins. An intra Community distance sale is the exception: it takes place where the transport ends.7 That is why Clodagh's parcels from Cork are German sales that she can declare through the OSS. If the stock sits in a German warehouse, the transport begins and ends in Germany. Every German order is then a German domestic sale, it is no longer a distance sale, the OSS does not cover it, and you need a German VAT registration. For a business based in Ireland, that registration is handled by the Finanzamt Hamburg Nord.10
If the warehouse is in another EU country, say the Netherlands, a sale to a German consumer is still an intra Community distance sale. Its place of supply is where the transport ends, so German VAT applies, and it can still go through the OSS with Revenue.79 The stock in the Dutch warehouse brings its own registration, for the reason in the next paragraph.
Then the stock itself has to get there. No customs and no import: moving your own goods from Ireland to a warehouse in another Member State is a transfer under the VAT Directive. It counts as a supply out of Ireland, exempt from Irish VAT, which you report in your Irish VAT return and in your recapitulative statement (the VIES return). Where the goods arrive, it counts as an intra Community acquisition, and a business making acquisitions needs a VAT number in that country.7 The acquisition VAT is worked out on the purchase price or cost price of the goods. You can deduct it in the same country as long as the goods are used for your taxed sales, and the right to deduct arises the moment the tax becomes chargeable.7
Read it from the top. The first question is where the parcel starts, not where the company sits. Once the stock leaves Ireland, a VAT registration abroad comes in, in Germany or in the warehouse country, and the OSS covers less than it did. Either way the German customer pays German VAT at 19%.
Worked example: Clodagh moves her tops to a German warehouse
Step one, the basket. Nothing changes for the customer: €64 divided by 1.19 is €53.78 net and €10.22 German VAT. What changes is the filing: German VAT returns to the Finanzamt Hamburg Nord through her Steuerberater for every order shipped from the warehouse, instead of declaring them in her OSS return to Revenue.
Step two, the stock. She sends 600 tops to Germany. Their cost price is €9,600. No customs declaration, no proof of origin. Her Irish VAT return shows a €9,600 exempt supply to another Member State, and her VIES return lists her own new German VAT number as the acquirer.
Step three, the acquisition VAT, which is the VAT rate times the cost price of the goods moved.
Here is the acquisition VAT, is the German VAT rate and is the cost price of the tops in euro. So is €1,824. Taking a percentage of a total is covered in Foundations: percentages.
Step four, the cash. She declares the €1,824 in her German VAT return and deducts the same €1,824 in that return, so the two cancel out. Unlike import VAT paid at a border, it ties up no cash. It is paperwork, and the Steuerberater's fee is the real cost.
Fulfilment option three: a third party logistics provider
A third party logistics provider (3PL) is a warehouse that does the physical work for you: receives your stock, stores it, picks and packs each order, hands it to a carrier, and receives the returns.
What a 3PL does not do is take on your legal duties by default. You still need the VAT registration described in the previous section, the packaging registration and the German terms. There is one duty you do not need it for. Under the EU market surveillance rules, a product needs an economic operator established in the EU who is responsible for it, and a manufacturer established in the EU fills that role. A fulfilment service provider only steps in where no manufacturer, importer or authorised representative is established in the EU.11 Clodagh's tops are made in Cork, so that question is already answered. If you sell goods made outside the EU, the setup article covers who your operator is.
The decision is a break even. A 3PL adds a fixed monthly cost and saves money on every order. The number of orders a month that pays for it is the fixed cost divided by the saving per order:
Here is the number of orders a month needed to break even, is the extra fixed cost per month in euro, and is the saving per order. It is a rate of cost per unit of saving, built like every rate in Foundations: ratios and rates.
Worked example: when a German 3PL pays for Clodagh
Every price here is invented. Real 3PL quotes vary widely, and the minimum monthly fee is the line to read twice.
Step one, the fixed cost. The 3PL charges a minimum of €350 a month. Her Steuerberater charges €150 a month more for German VAT returns. So .
Step two, the saving. From Cork an order costs €9.80, as in option one. From the 3PL it costs €2.40 to pick and pack, €4.60 for a domestic German parcel and €0.60 of bulk freight, €7.60. So .
Step three, the break even.
With and , is 227.3, and you round up because nobody ships three tenths of an order: 228 orders a month. The method is the rate from Foundations: ratios and rates.
Step four, at her volume. At 150 orders a month she saves 150 times €2.20, which is €330, less the €500 fixed cost, so she is €170 a month worse off on delivery alone, even though her parcels would arrive in a day or two instead of three to five. With no duty to save, the warehouse has to earn its keep somewhere else. Returns are where it can, and I come back to that below.
The chart runs along German orders a month and up in cost per order in euro. Shipping from Ireland is flat at €9.80. The 3PL line is €7.60 plus €500 divided by the orders, so it starts high and falls as the fixed cost spreads thinner. On delivery alone, the lines cross at about 228 orders a month. The takeaway: inside the single market the saving per parcel is small, so the warehouse needs a lot of orders to pay on postage. Below the crossing, ship from home, unless returns change the sum.
Returns are a legal right, so design the process around the law
The setup article and the missteps article explain the notice and the withdrawal button. Irish consumer law comes from the same EU directive, so the 14 days will look familiar, but the German details carry money. Here is what the rules mean for the warehouse and the bank account.
A consumer who withdraws does not need to give a reason, and the period is 14 days.12 For goods it starts when the customer receives them, and it does not start until the customer has been told about the right as the law requires. At the latest it ends 12 months and 14 days later.13 Both sides must return what they received within 14 days at the latest.14 For the shop, that clock starts when the withdrawal reaches you.12
You must also refund what the customer paid for delivery, up to your least expensive standard delivery.14 The refund goes back through the payment method the customer used, unless you expressly agree otherwise at no cost to them.14 You may hold the refund until the goods are back or the customer shows they sent them.14 The customer pays the direct cost of the return only if you told them so in advance.14 And the risk of the return journey is yours: if the parcel is lost on the way back, you still refund.12
There is one protection for the shop. If the goods lose value because the customer handled them more than needed to check their nature, characteristics and functioning, the customer owes compensation for the loss in value, provided you informed them about the right of withdrawal properly.15
Worked example: one of Clodagh's refunds, day by day
Step one, delivery. A customer in Leipzig receives her parcel on Tuesday 3 November 2026. Her 14 days run to Tuesday 17 November.
Step two, the withdrawal. She presses the withdrawal button on Monday 16 November, in time. Clodagh's system confirms it straight away. Her 14 day refund deadline now runs to Monday 30 November.
Step three, the return. The customer posts the top on Wednesday 18 November. The tracking scan is proof of dispatch, so Clodagh may no longer hold the refund. Her prices include delivery, so the refund is the full €64, back to the same PayPal account.
Step four, Clodagh's own rule. The law gives her until 30 November. Her rule is to refund within two working days of the return scan, so the customer has her money on Friday 20 November. That speed is a choice, not a duty, and in my experience it is one of the least expensive ways to earn a second order.
How many come back: return rates in Germany
The best primary source I know is the returns research group at the University of Bamberg, the Forschungsgruppe Retourenmanagement. In its survey of 411 online retailers for 2021, almost one in four parcels in German online retail was returned, mostly in fashion. That is an estimated 530 million return shipments containing about 1.3 billion items.16
The same study shows how the German market has set expectations. 88.7% of the German retailers surveyed said returns were usually free, against 52.4% in the rest of the EU. The average return window they offered was 51.7 days, against 28.1 days elsewhere in the EU, well beyond the legal 14.16 A returned item cost the retailers on average €2.85 in transport and processing.16
Two cautions. These are 2021 figures from a retailer survey, the latest full measurement I could source, and they describe domestic returns. A return from Leipzig to Cork is not a €2.85 job.
Measure your own rate rather than borrowing one. A return rate is returns divided by deliveries:
Here is the return rate, is the number of returned parcels and the parcels delivered in the same period, see Foundations: ratios and rates.
Worked example: Clodagh's first quarter
Step one, the counts. In her first German quarter, 450 parcels were delivered and 99 came back.
Step two, the rate.
With and , the return rate is 0.22, so 22%.
Step three, the reading. Almost all of the 99 contained a top in the wrong size. Socks hardly ever come back. The fix is a size chart in centimetres on the German page, with chest and length measured flat, not a better returns portal.
Where the returns go, and what each route costs
A German return has two possible destinations: back to Ireland, or to an address in Germany.
Back to Ireland, the parcel stays inside the single market. There is no customs declaration, no duty and no relief to claim.5 It is an ordinary parcel, but an international one: it takes days, the label from Germany costs more than a domestic one, and the top sits in a van rather than on a shelf while your customer waits for her refund.
To a German address, the parcel never leaves Germany. If you use a German 3PL, its address is your returns address. The goods are checked, the good ones go back on the shelf in Germany, and the refund can go out the same day.
The cost of returns per order is again an expected value, here with only one outcome that costs money: the return rate times the cost of one return.
Here is the expected return cost per order, is the return rate as a decimal, and is the full cost to the shop of one return. It is the expected value from Foundations: expected value with a single costly outcome.
Worked example: two returns routes for Clodagh
All costs here are invented.
Step one, the cost of one return to Cork. The outbound postage she cannot recover, €9.80. A prepaid return label from Germany, €11.00. Checking and restocking, €2.00. So .
Step two, the cost of one return to her German 3PL. The outbound domestic parcel, €4.60. Pick and pack, €2.40. A domestic return label, €4.20. Checking and restocking at the 3PL, €2.00. So .
Step three, the expected cost per order, with from her first quarter.
With and , the Irish route costs , so €5.02 on every German order, returned or not.
With and , the German route costs , so €2.90. Both are the expected value from Foundations: expected value. The difference is €2.12 an order, so €318 a month at 150 orders, on top of the delivery saving.
Step four, the third option. Her German withdrawal notice could say the customer pays for the return, which the law allows if she says so in advance.14 That takes the €11.00 label out of on the Irish route, so and . Less expensive for Clodagh, but most German shops offer free returns,16 so she would be asking more of her customers than her competitors do. She keeps returns free and fixes the size chart instead.
The whole picture, per order
Put delivery, fixed cost and expected returns together.
The bars run along the three setups and up in cost per order in euro. Shipping from Ireland with free returns is the highest, €14.82: €9.80 postage and €5.02 expected returns. Making customers pay for returns brings it down to €12.40, the lowest of the three. The German 3PL sits between them at €13.83: €7.60 per order, €3.33 of the €500 monthly fixed cost spread over 150 orders, and €2.90 expected returns. The takeaway: for an Irish shop, who pays for the return label matters about as much as where the stock sits. Among the free returns setups, which is what German customers expect, the warehouse wins at Clodagh's volume, but only just.
The break even shifts once returns are in it. The saving per order is now the whole cost from Cork, €14.82, less the 3PL's variable cost, €7.60 plus €2.90, so €10.50:
With and , is 115.7, so 116 orders a month, half the 228 on postage alone. It is the same rate as before, from Foundations: ratios and rates. Below about 116 orders a month, shipping from Cork wins.
Against a net basket of €53.78, the gap of €0.99 an order is under 2% of the net price, about €148 a month at 150 orders. Real money, but a sizing fix that cut returns would be worth more.
What I would do, in order
First, ship from Ireland with a tracked service that hands over to a German carrier, show an honest delivery window in working days, say clearly that there are no customs charges, and count orders, returns and support emails for a quarter.
Second, fix what the returns tell you. In clothing that is almost always sizing, and a size chart is less expensive than any logistics change.
Third, run the break even with the returns in it, not on postage alone. If German orders sit well above the crossing point, talk to a Steuerberater about the German VAT registration before you talk to a single warehouse.
Fourth, if you move, pick a 3PL that can also be your German returns address and read the minimum monthly fee twice. And keep the refund fast. The law gives you 14 days. The customers who come back are the ones who got their money in two.
How German buyers pay, including buying on invoice, is in pricing and payment preferences in Germany, and how I wire those methods into a shop is in DACH payments in Solidus. If returns are your biggest cost, AI for reducing cart abandonment and returns looks at the prediction side.
Sources
Footnotes
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Bundesnetzagentur, Datenportal Post, Sendungsmengen Paket und Express (parcel and express volumes 2017 to 2025, from the annual market survey of postal providers), Bundesnetzagentur, updated 8 December 2025, https://bundesnetzagentur.de/DE/Fachthemen/Datenportal/3_Post/_svg_Post/Post_Postmarkt_allgemein/P_Sendungsmengen/P_Sendungsmengen.html
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Sendcloud, DHL Parcel Germany spotlight: delivery performance benchmarked (more than 10 million shipments, Q3 2025 to Q2 2026), Sendcloud, 6 November 2026, https://www.sendcloud.com/insights/dhl-delivery-performance
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Bundesnetzagentur, Datenportal Post, Beschwerden nach Kategorien 2025 (complaints by category, 2025), Bundesnetzagentur, 2026, https://bundesnetzagentur.de/DE/Fachthemen/Datenportal/3_Post/_svg_Post/Beschwerde/P_Beschwerde/P_Beschwerde.html
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Bundesnetzagentur, Veröffentlichung der Zahlen für den Brief und Paketmarkt 2023, press release, Bundesnetzagentur, 2 April 2025, https://www.bundesnetzagentur.de/SharedDocs/Pressemitteilungen/DE/2025/20250402_Post.html
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Treaty on the Functioning of the European Union, article 28, EUR Lex, 2016, https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:12016E028
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Bundesministerium der Finanzen, Zollbefreiung für Warensendungen unter 150 Euro entfällt (the end of the customs duty relief for consignments under 150 euros), BMF, 2026, https://www.bundesfinanzministerium.de/Content/DE/Standardartikel/Themen/Zoll/wegfall-der-150-euro-zollfreigrenze.html
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Council Directive 2006/112/EC on the common system of value added tax, consolidated text, articles 17(1), 21, 32, 33(a), 59c, 76, 138(2)(c), 167, 168(d), 214(1)(b), 262(1)(a) and 369a, EUR Lex, 2025, https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02006L0112-20250101
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Revenue, Tax and Duty Manual: VAT and intra Community distance sales of goods, sections 2, 3 and 5, Revenue, 2025, https://www.revenue.ie/en/tax-professionals/tdm/value-added-tax/Part04-place-of-taxable-transactions-place-of-supply/distance-sales/vat-and-intra-community-distance-sales-of-goods.pdf
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European Commission, One Stop Shop: Register, VAT One Stop Shop portal, https://vat-one-stop-shop.ec.europa.eu/one-stop-shop/register-oss_en
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Umsatzsteuerzuständigkeitsverordnung (UStZustV), § 1, Abs. 1 Nr. 9, Bundesministerium der Justiz, gesetze im internet, https://www.gesetze-im-internet.de/ustzustv/__1.html
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Regulation (EU) 2019/1020 on market surveillance and compliance of products, article 4(1) and 4(2), EUR Lex, 2019, https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32019R1020
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Bürgerliches Gesetzbuch (BGB), § 355 Widerrufsrecht bei Verbraucherverträgen, Bundesministerium der Justiz, gesetze im internet, https://www.gesetze-im-internet.de/bgb/__355.html
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Bürgerliches Gesetzbuch (BGB), § 356 Widerrufsrecht bei außerhalb von Geschäftsräumen geschlossenen Verträgen und Fernabsatzverträgen, Bundesministerium der Justiz, gesetze im internet, https://www.gesetze-im-internet.de/bgb/__356.html
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Bürgerliches Gesetzbuch (BGB), § 357 Rechtsfolgen des Widerrufs von außerhalb von Geschäftsräumen geschlossenen Verträgen und Fernabsatzverträgen mit Ausnahme von Verträgen über Finanzdienstleistungen, Bundesministerium der Justiz, gesetze im internet, https://www.gesetze-im-internet.de/bgb/__357.html
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Bürgerliches Gesetzbuch (BGB), § 357a Wertersatz als Rechtsfolge des Widerrufs, Bundesministerium der Justiz, gesetze im internet, https://www.gesetze-im-internet.de/bgb/__357a.html
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Universität Bamberg, Forschungsgruppe Retourenmanagement, Erste europäische Händlerbefragung zum Retourenmanagement, press release, Universität Bamberg, 7 September 2022, https://www.uni-bamberg.de/presse/pressemitteilungen/artikel/erste-europaeische-haendlerbefragung-retourenmanagement/