v1.1.0 to git:20260925.e6c43e0

- description: When the user wants to create or optimize a refund or return policy page. Also use when the user mentions "refund policy," "return policy," "money-back guarantee," "returns and refunds," "refund page," "return process," "refund terms," "satisfaction guarantee," "cancellation policy," or "withdrawal right." For legal overview, use legal-page-generator.

- version: 1.1.0

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- # Pages: Refund / Return Policy

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- Guides refund and return policy page content for SaaS, digital products, e-commerce, and services. Covers jurisdiction-specific requirements including EU withdrawal rights.

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- **When invoking**: On **first use**, if helpful, open with 1–2 sentences on what this skill covers and why it matters, then provide the main output. On **subsequent use** or when the user asks to skip, go directly to the main output.

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- ## Initial Assessment

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- Identify:

- 1. **Product category**: See §Product Categories — refund logic is fundamentally different for SaaS vs digital downloads vs physical goods vs services

- 2. **Jurisdiction**: EU (14-day withdrawal right + mandatory withdrawal button), UK (DMCCA subscription rules), US (FTC clear-and-conspicuous), Australia (consumer guarantees), China (2026 platform rules)

- 3. **Refund model**: Full refund, partial/pro-rata, store credit only, no refund, or conditional

- 4. **Payment flow**: One-time, subscription/recurring, or tiered pricing

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- ## Product Categories

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- Refund policies differ radically by product type. Identify the category first:

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- | Category | Default Refund Stance | Key Considerations |

- |---|---|---|

- | **SaaS / Subscription** | Pro-rata or conditional | EU withdrawal button required by Jun 2026; trial periods; auto-renewal cancellation; Sky Austria case may reclassify subscriptions as "digital services" with full-period withdrawal rights |

- | **Digital Downloads** | Typically non-refundable | "Once downloaded, all sales final"; exceptions for technical failure or duplicate purchase; must obtain explicit consent to waive EU withdrawal right before download |

- | **Physical Goods** | 30-day return window (standard) | Return shipping costs; restocking fees; original packaging; final-sale categories |

- | **Courses / Coaching** | Conditional | Pre-recorded: non-refundable once accessed; Live: partial refund before start, none after; rescheduling preferred over refunds |

- | **API / Usage-Based** | Prorated or non-refundable | Pay-as-you-go typically non-refundable; subscription components may be prorated |

- | **Marketplace** | Per-vendor or uniform | Who processes refunds; vendor return rates (>8% review, >15% suspend); uniform policy builds trust |

- | **Free Tools** | N/A | No payment = no refund policy needed; state "free, no purchase required" if asked |

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- ## Jurisdiction Requirements

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- ### EU — Consumer Rights Directive + 2026 Withdrawal Button

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- **14-Day Cooling-Off Period**:

- - EU consumers have an unconditional 14-day right to withdraw from any distance contract (online purchase)

- - Applies to goods, services, AND digital products/SaaS

- - You must inform consumers of this right BEFORE purchase — failure extends the period by up to 12 months

- - For goods: withdrawal period starts on delivery

- - For services/digital: starts on contract conclusion

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- **Mandatory Withdrawal Button — Deadline June 19, 2026** (Directive EU 2023/2673):

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- This is the most urgent 2026 compliance item. Requirements:

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- - A clearly labeled digital withdrawal function (e.g., "Withdraw from contract" button) on your website/app

- - **Two-step process**: (1) Withdrawal button → confirmation page → (2) "Confirm withdrawal" button

- - Automated confirmation sent to consumer on a **durable medium** (email) with timestamp

- - Button must be **permanently available** during the withdrawal period, prominently placed, not hidden behind logins or menus

- - Applies to **any business targeting EU consumers**, regardless of where the business is registered

- - Penalties: fines up to 4% of annual turnover in some member states; extended withdrawal periods until compliant

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- **Digital Content vs Digital Services — Sky Austria Case (CJEU, pending 2026)**:

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- This pending case may significantly change how SaaS refunds work:

- - Advocate General opined that streaming subscriptions (and by extension, SaaS) are **"digital services"** — not "digital content"

- - **Why it matters**: Digital content can waive withdrawal rights immediately upon access. Digital services only lose withdrawal rights once the service is **fully performed** — not when access begins

- - **Practical impact**: If the CJEU follows this opinion, SaaS providers may not be able to extinguish withdrawal rights at first login; the right would persist for the full subscription term

- - **Monitor this case** and be prepared to update refund terms

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- **Exceptions** (Article 16 CRD — withdrawal right does NOT apply to):

- - Digital content where performance has begun AND consumer gave prior express consent AND acknowledged loss of withdrawal right (but note Sky Austria risk)

- - Fully performed services with consent and acknowledgment

- - Customized/personalized products

- - Services for specific dates (events, hotel bookings)

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- **2-Year Conformity Guarantee**: Under Digital Content Directive (2019/770), consumers have a minimum 2-year guarantee for defective digital products and services.

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- ### UK — DMCCA Subscription Rules (Spring 2027)

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- - Pre-contract disclosure of key subscription terms (trial price, renewal date, cancellation method)

- - Two 14-day cooling-off periods (one at sign-up, one after auto-renewal of long-term contracts)

- - Mandatory renewal reminders with prescribed information

- - Cancellation must be "straightforward" — no unnecessary steps

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- ### US — FTC Requirements

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- - No federal right of withdrawal for online purchases

- - FTC requires refund policies to be "clear and conspicuous"

- - Some states have specific rules: California requires posting the refund policy if not offering full refund within 7 days

- - State AGs increasingly enforce against "dark patterns" that make cancellation difficult

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- ### Australia — Consumer Guarantees (ACL)

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- - Consumer guarantees **cannot be excluded** by store policy

- - Defective items entitled to refund, repair, or replacement regardless of what the policy says

- - No fixed return window — "reasonable time" applies

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- ### China — 2026 Platform Rules (Effective February 1, 2026)

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- - Platforms **cannot force merchants** to accept "refund without return" (仅退款)

- - Rules must be transparent

- - Historical versions must be archived for 3+ years

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- ## SaaS Refund Patterns

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- ### Trial-to-Paid Conversion

- - Free trials are for evaluation; clearly state when the trial ends and when billing begins

- - Offer a limited post-conversion refund window (7–30 days) to catch accidental conversions

- - Send pre-billing reminders 3–7 days before trial ends

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- ### Pro-Rata Refunds (Mid-Cycle Cancellation)

- - Standard for annual subscriptions: refund unused months minus processing fee

- - Monthly subscriptions: typically no pro-rata; access continues until period end

- - Clearly state whether prepaid fees are forfeited or prorated on termination

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- ### Cancel-Before-Renewal

- - State the deadline for cancelling before auto-renewal (e.g., "at least 24 hours before renewal date")

- - Send renewal reminders 7–30 days in advance

- - Include a "Cancel subscription" link in account settings and renewal emails

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- ### Anti-Abuse

- - Consider: maximum refunds per customer per year; manual review for high-value refunds; fraud detection on refund patterns

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- ## Digital Products Refund Patterns

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- **Default**: "Due to the digital nature of this product, all sales are final and non-refundable."

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- **Recommended Exceptions**:

- - **Accidental duplicate purchase**: Refund as goodwill

- - **Technical failure preventing access/download**: Refund or re-deliver

- - **Product not as described**: Refund if materially different from listing

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- **EU Compliance for Digital Products**:

- - To waive the 14-day withdrawal right for digital content: (1) obtain consumer's prior express consent to immediate performance, AND (2) consumer must acknowledge they will lose the withdrawal right once download/access begins

- - Make this a checkbox at checkout — not buried in terms

- - After June 2026, the withdrawal button must be available even if the right has been waived (it may still apply if the waiver was invalid)

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- **Content License Clause**: Make clear the buyer owns a license to use, not the content itself. "You are purchasing a non-exclusive, non-transferable license to use [product], not ownership of the underlying content."

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- ## Physical Goods Return Patterns

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- ### Return Window

- - **30 days from delivery** is the dominant standard (58.5% of DTC brands)

- - Distribution: <14 days (4.7%), 14–29 days (21.4%), exactly 30 (58.5%), 31–60 (9.2%), 60+ (6.1%)

- - Shorter windows for food, supplements, personal care; longer for furniture, sleep products

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- ### Return Costs

- - **Defective/wrong item**: Vendor pays return shipping

- - **Change of mind**: Customer pays return shipping

- - **Restocking fees**: $5–15 flat or 5–15% — increasingly common, but **must be prominently displayed** (not buried in fine print)

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- ### Conditions

- - Original packaging required: 50.1% of brands require it — clearly state upfront

- - Final-sale categories: intimates, cosmetics, food (hygiene); custom/personalized orders (functional). Keep the list logical — don't stack with discount tiers.

- - Store-credit-only refunds: only 3.3% of brands; not recommended as the ONLY option

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- ### Refund Method & Timeline

- - Original payment method preferred

- - Specify timeline: "within 10–14 business days of receiving the returned item"

- - EU: must refund within 14 days of receiving the return

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- ## Essential Policy Elements

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- Every refund/return policy should cover:

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- | Element | What to Include |

- |---------|----------------|

- | **Eligibility** | What can be returned/refunded; time limits; condition requirements |

- | **Non-refundable items** | Final-sale categories; digital products with access/waiver |

- | **Refund amount** | Full, pro-rata, minus fees, store credit only |

- | **Refund method** | Original payment, store credit, check |

- | **Refund timeline** | When the customer will receive the refund |

- | **Process** | Step-by-step instructions; withdrawal button location; contact |

- | **Exceptions** | Defective items, duplicate purchases, technical failures |

- | **Trial terms** (SaaS) | Trial duration, conversion date, billing after trial |

- | **Cancellation** (SaaS) | How to cancel; what happens to data; pro-rata refund details |

- | **Jurisdiction rights** | EU 14-day withdrawal; Australia consumer guarantees; other statutory rights |

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- ## Placement

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- Place the refund policy where customers need it **before** making a purchase decision:

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- 1. **Checkout page** — Brief summary with link to full policy; visible before purchase completion (FTC requirement)

- 2. **Website footer** — Persistent link on every page

- 3. **Product pages** — Returns/refund summary tab or section

- 4. **Order confirmation email** — Include return/exchange instructions

- 5. **Account dashboard** — "Request Refund" or "Cancel Subscription" button accessible on eligible orders

- 6. **Terms of Service** — Cross-link for legal completeness

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- For SaaS: the cancellation flow should be accessible from account settings, billing page, and support contact — **never** require calling support as the only cancellation method.

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- ## Content Principles

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- - **Be specific about timing**: "Within 30 days of delivery" > "within a reasonable time"

- - **Distinguish by product type**: Digital vs physical vs subscription — don't use one blanket policy

- - **Prominent fee disclosure**: Restocking fees and return shipping costs must be visible, not buried

- - **EU withdrawal button**: Plan for the June 2026 deadline now; describe the mechanism in the policy

- - **Plain language**: "If you change your mind, you can return it within 30 days" > legalese

- - **Anti-dark-pattern**: Cancellation must be as easy as sign-up; don't hide the withdrawal button

- - **Update regularly**: Review when pricing, product types, or regulations change

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- ## Industry Benchmarks (2025–2026)

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- | Metric | Benchmark |

- |--------|-----------|

- | Median physical-goods return window | 30 days from delivery |

- | Brands offering free returns (stated on policy page) | 18.4% |

- | Brands with restocking fees | 19.2% |

- | Brands requiring original packaging | 50.1% |

- | Brands with final-sale clauses | 39.9% |

- | Brands using store-credit-only refunds | 3.3% |

- | SaaS pro-rata refund standard | Unused months minus processing fee or no refund after window |

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- ## Output Format

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- - **Product-category determination**: Which refund model applies

- - **Complete policy outline**: All applicable sections with key clauses

- - **EU compliance block**: Withdrawal right explanation + withdrawal button mechanism (if targeting EU)

- - **SaaS-specific block** (if applicable): Trial terms, pro-rata details, cancellation flow

- - **Refund process description**: Step-by-step in plain language

- - **Jurisdiction flags**: Which statutory rights apply and how they interact with the policy

- - **Placement recommendations**: Where to surface the policy

- - **Disclaimer**: Recommend legal review, especially for EU withdrawal button compliance

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- ## Related Skills

- - **legal-page-generator**: Refund is a legal page type; product categories, jurisdiction framework

- - **terms-page-generator**: Refund terms often embedded in Terms; cancellation and termination clauses

- - **shipping-page-generator**: Often paired in footer and checkout for e-commerce

- - **faq-page-generator**: FAQ may link to refund policy for common questions