Sealed and yet returned? The 14-day cooling-off period and its exceptions
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by Verpakkingdeals.nl
6 min reading time
The main rule for online purchases is a fourteen-day cooling-off period. There is an exception for sealed hygiene products, but this has three strict conditions. What this means for your packaging.
A package comes back. The box is open, the seal is broken, the product is neatly in its original packaging, and the customer writes: "Not what I was looking for after all, please refund my money." For a webshop selling cosmetics, personal care products, or 18+ items, this is the moment you want to know exactly what is allowed. Because the law has one specific exception here, and that stands or falls with what *you* did before the shipment left the door.
Below is the main rule, the exception, and what it practically means for your packaging.
The main rule: 14 days cooling-off period, and then another 14 days
For an online purchase, a consumer has a cooling-off period. According to the Netherlands Authority for Consumers and Markets (ACM), buyers may cancel the purchase up to fourteen days after the product has been delivered. If they cancel the purchase, they then have another fourteen days to actually return the product.
What you refund is the purchase price plus the standard shipping costs. If the customer chose a more expensive delivery method, you only reimburse the standard rate. Separate conditions apply to who bears the cost of return transport, about which you must inform the customer in advance — refer to the ACM itself for this, as it is a precise matter.
That's the basic rule. And with it comes an uncomfortable truth: a customer may try out a product just as they would in a store. Unpacking and inspecting is therefore allowed. The fact that it is no longer in its original foil is not, in itself, a reason to refuse a return.
The exception: sealed and not suitable for return
For a specific category, things are different. The ACM puts it this way: the cooling-off period expires if the customer breaks the seal on products related to hygiene, such as a toothbrush or a razor — provided you have informed the customer about this in advance and sent the product sealed.
According to the explanation by Thuiswinkel.org, there are three conditions attached to this, and they all apply simultaneously:
The product was delivered sealed and that seal was broken *after* receipt. Whether the item has actually been used is irrelevant.
You have clearly and understandably informed the customer in advance that the right of withdrawal for this product expires as soon as the seal is opened. The burden of proof that you have done so lies with you as the seller.
The product is not suitable for return for health or hygienic reasons — you must be able to substantiate that it cannot be cleaned or disinfected in such a way that it can be safely resold.
Simply sticking a sticker on the box is not enough. A sentence in your general terms and conditions is also not enough if you don't display it anywhere with the product itself. It's the combination that counts. If you have doubts about your specific assortment, consult a lawyer or refer to the source — this text is a practical explanation, not legal advice.
What this means for your packaging
The exception is essentially a packaging issue. If you want to be able to invoke it, there must be a seal that is visibly broken. This can be done in three ways:
The VOID sticker is the most explicit: if you peel it off, a pattern remains that you cannot remove. This makes it impossible to dispute afterwards whether the seal has been broken. For larger volumes, you can seal more cheaply with tape — Tape Rolls 6 Pieces 48x66mm costs €21.00 for six rolls, or €3.50 per roll — although tape is easier to remove discreetly.
Important detail: the seal must be on the *product*, not on the shipping box. A taped-up shipping box must be opened by the customer anyway to see what they have bought. The seal referred to by the exception is the packaging of the item itself.
The other side: make returns easy where it *is* allowed
For everything that does *not* fall under the exception, the opposite applies. The easier the customer can return the product undamaged, the greater the chance that you can simply resell it. That saves write-offs.
If you're on the other side and unsure about a purchase, the practical lesson is short: inspect first, then break the seal. Before opening, check the product page for sizing, contents of the set, and material. If something is wrong, you can still return a sealed item; once the seal is open, this is no longer possible for this product category.
Furthermore, keep the box it came in, at least until the cooling-off period is over. Returning a product without adequate packaging is asking for transport damage, and that will still be your problem.
In short
Fourteen days cooling-off period is the main rule, and it's broad. The exception for sealed hygiene articles truly exists, but it's not automatic: it requires a real seal, clear information beforehand, and a product that you demonstrably cannot safely resell. As a webshop, you arrange this upfront — on your product page and in your packaging process — not afterwards in an email discussion.
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