A customer from Belgium opens the German shop address, is thrown onto the Belgian version while the page is still loading and does not find the item they were looking for. They cannot get back, because the switch fires again on every request. What was planned in the project as friendly country guidance is an infringement of Article 3 of Regulation (EU) 2018/302. The Geo-blocking Regulation has applied since 3 December 2018 (Regulation EU 2018/302, Article 11) and affects every trader reaching customers in the single market - including those who did not plan to sell across borders. This article sorts the three prohibitions, names the exceptions and shows the points in the online shop where implementation typically breaks.
What the regulation requires and who it applies to
The Geo-blocking Regulation is not a law about national languages or currencies, but about access. It forbids three things: blocking access to the online interface, applying different general conditions of access to goods or services, and applying different conditions for a payment transaction based on origin. All three prohibitions attach to the same three characteristics: the customer nationality, place of residence and place of establishment (Regulation EU 2018/302, Articles 3 to 5). What a shop does technically is secondary - what matters is whether a customer from another member state ends up worse off than a domestic one. Country guidance that shows everyone the same thing is unproblematic; guidance that sorts people out is not.
This affects more than shops with international ambitions. In the view of the competent authority, the regulation also covers traders established outside the European Economic Area if they operate on the European internal market (Bundesnetzagentur). It protects consumers and - this is frequently overlooked - undertakings as customers as well, as long as they buy the goods or services for end use. A B2B shop therefore cannot fall back on the argument that it only supplies businesses. Anyone walking the ordering path with this in mind for the first time typically finds the issues not in the terms and conditions, but in redirect rules, registration forms and the payment selection.
A trader shall not, through the use of technological measures or otherwise, block or limit a customer's access to the trader's online interface for reasons related to the customer's nationality, place of residence or place of establishment.
Regulation (EU) 2018/302, Article 3(1)
The quotation is both the core and the benchmark. Blocking and limiting are forbidden, through technological measures or otherwise. Removing a country from the list of shipping destinations remains permitted; refusing a customer from that country access even to the basket is not. In its short-term review of 30 November 2020 the European Commission evaluated the 2019 website survey: outright access blocking has fallen sharply, 0.2 % of the roughly 9000 websites surveyed still blocked access, while location requirements at registration fell from 26.9 % in the 2015 baseline survey to 14 % (European Commission). Since then the remaining friction sits one level lower, in the form and at the checkout.
The regulation examines three characteristics of the customer - nationality, place of residence, place of establishment - and asks three questions: does the customer reach the interface? Do the same general conditions of access apply to them? Do they get the same payment conditions? Anyone able to answer these three questions for every country combination has completed the mandatory part. Everything else - language, currency, range, price - remains a business decision, as long as it is not tied to one of the three characteristics.
Article 3: access to the interface
The second paragraph of Article 3 governs redirection and is the most frequent source of errors in practice. An automatic redirect to a different language or country version is permitted if the customer has given explicit consent. Without that consent it is forbidden. And even with consent, the version originally requested must remain easily accessible (Regulation EU 2018/302, Article 3(2)). This rules out the common construction that redirects based on the visitor address and then offers no way back. Consent has to be active; a pre-ticked box or a notice banner without a choice typically does not carry it.
The exception in the third paragraph is drawn narrowly: blocking, limiting access and redirecting remain permitted where necessary to comply with a legal requirement laid down in Union law or in the law of a member state in accordance with Union law. In that case the trader owes a clear explanation - in the language of the interface the customer originally sought to access (Regulation EU 2018/302, Article 3(3)). A shop that is not allowed to supply certain products to individual countries therefore has both a solid reason and a clear duty to explain. A shop that merely finds foreign enquiries inconvenient has neither.
- Redirect without a way back: the country switch fires again on every request, and a manual change is overwritten with the next click. The regulation requires the opposite: the version originally requested must remain easily accessible.
- Consent after the fact: a banner announcing the redirect while it is already running is not prior consent. The choice belongs before the redirect, not behind it.
- Blocking from the operations layer: country or address range blocks in the server configuration take effect before any application logic and appear in no shop test. They belong in the same review as the application itself, see hosting and operations.
- Language choice as country choice: bundling language, currency and delivery country into a single selection pushes the customer into a country profile they cannot leave without loss.
One practical grey area concerns abuse defence. In the view of the Bundesnetzagentur, time-limited blocks on individual address ranges against automated login attempts do in principle interfere with Article 3, but are justified as long as they are directed against the attack and not against a country (Bundesnetzagentur). The difference lies in what triggers them: a rule that reacts to behaviour and expires after a short period is something other than a permanent country list. How to separate automated traffic cleanly from real customers without crossing that line is covered in managing bot traffic in the online shop.
The robust implementation reverses the direction: the customer stays on the version they requested and receives a visible notice that a version for their country exists. One click leads across, the choice is stored, a second click leads back. This variant satisfies Article 3(2) without special logic, because it does not redirect at all without consent. It typically costs less to build than retrofitting an existing switch, because no state has to be repaired across several sessions.
Article 4: same conditions, not same prices
Article 4 forbids different general conditions of access to goods or services and lists three cases: the sale of goods delivered to a territory to which the trader offers delivery in its general conditions, or collected at an agreed location; the receipt of electronically supplied services whose main feature is not the provision of access to copyright-protected works; and the receipt of other services at a physical location where the trader operates (Regulation EU 2018/302, Article 4(1)). For shop operators the first case matters most, and it is regularly read too broadly.
No obligation to deliver across borders arises from it. The delivery territory remains a free business decision. All that is required is that a customer from another member state can place an order with delivery to a location inside that territory - the onward journey home is then their own to organise (Bundesnetzagentur). In practice this means: a shop that only delivers within Germany may keep it that way, but has to let a customer from Austria order to a German address. A form that already stops the order at a differing billing address misses exactly this point.
| Case under Article 4(1) | What the customer may ask for | What the trader decides freely | Reference |
|---|---|---|---|
| Sale of goods with delivery or collection | An order on the same conditions, delivered to a location within the offered territory | The shape of the delivery territory and shipping costs per destination | Article 4(1)(a) |
| Electronically supplied services | Receipt on the same conditions, for example storage or running an application | Scope of service and net sale price per territory in a non-discriminatory manner | Article 4(1)(b) |
| Services provided at a fixed location | Booking on the same conditions, for example entry, a course or accommodation | Capacity, dates and prior conditions, identical for all customers | Article 4(1)(c) |
| Access to copyright-protected content | No claim under Article 4(1)(b) | Licence territory and availability | Article 4(1)(b) |
| Traders exempt from value added tax | No claim under Article 4(1)(b) | Restriction to their own market | Article 4(4) |
Prices remain negotiable. The prohibition expressly does not prevent traders from offering general conditions of access, including net sale prices, that differ between member states or within a member state, as long as they are offered to a specific territory or to a specific group of customers in a non-discriminatory manner (Regulation EU 2018/302, Article 4(2)). The distinction is fine but load-bearing: a separate price for the Austrian market is permitted, a surcharge for customers resident in Austria inside the German shop is not. Anyone running several country versions will find the matching structure in Shopware 6 multistore.
Many sets of terms forbid delivery to parcel forwarding services across the board. The Bundesnetzagentur regards this as an infringement of Article 4(1), because the rule formally applies to everyone but in practice hits almost exclusively customers from other member states who depend on that route (Bundesnetzagentur). Anyone carrying such a clause should cut it back to its actual purpose - cases of demonstrable abuse, for instance - instead of leaving it in place as an exclusion of entire groups of recipients.
Article 5: payment without an origin check
Article 5 forbids applying different conditions for a payment transaction within the range of accepted means of payment - and not only by nationality, place of residence and place of establishment, but additionally by the location of the payment account, the place of establishment of the payment service provider and the place of issue of the payment instrument within the Union (Regulation EU 2018/302, Article 5(1)). The prohibition applies where the payment is made through an electronic transaction by credit transfer, direct debit or a card-based instrument within the same payment brand and category, authentication requirements are met and the currency is accepted.
Two valves remain. First, where objective reasons justify it, the trader may withhold the goods or services until confirmation has been received that the payment transaction has been properly initiated (Regulation EU 2018/302, Article 5(2)). Second, charges for the use of a payment instrument remain permitted, but may not exceed the direct costs borne by the trader for its use (Regulation EU 2018/302, Article 5(3)). According to the Bundesnetzagentur, the European Commission stated orally that one common payment method available in all member states is sufficient and that not every locally widespread method has to be offered; the authority considers a written clarification useful (Bundesnetzagentur).
- Card country as a filter: a check on the country of issue of the card that rejects orders or forces prepayment falls directly under the prohibition in Article 5(1).
- Direct debit only with a domestic bank account: the location of the payment account within the Union is expressly not a permitted ground for differentiation.
- Prepayment for foreign addresses: if the selection is narrowed on the basis of the billing address, origin is the reason - and with it the infringement.
- A surcharge above cost: a charge for a means of payment may not exceed the direct costs; a flat foreign surcharge as a rule does not hold up against that limit.
The payment side is changing anyway, because European payment law is being reworked; anyone touching the selection at the checkout should think about both in one go, see PSD3 and PSR. And because every additional hurdle in the payment step costs orders measurably, a clean implementation pays twice: it meets the requirements and at the same time removes friction that serves nobody - the background is covered in checkout optimisation.
What expressly remains permitted
The regulation is often read more strictly than it is. It forces nobody into Europe-wide shipping, uniform prices or a multilingual interface. Nor does it require compliance with non-contractual legal requirements of the customer country or information about them; mere compliance with the prohibition expressly does not create such obligations (Regulation EU 2018/302, Article 4(3)). What it does require is equal treatment within the offer the trader has chosen. The following four points are the ones most often assumed to be forbidden in projects, although they are not.
Different net sale prices
Prices may differ between member states and within a member state, as long as they are offered to a territory or a group of customers in a non-discriminatory manner (Regulation EU 2018/302, Article 4(2)).
A self-chosen delivery territory
No trader is obliged to deliver to every country. All that is required is that every customer can order delivery to a location within the offered territory (Bundesnetzagentur).
Higher costs for a longer route
More may be charged for a longer distance. It only becomes impermissible when the surcharge is measured not by the destination but by the origin of the customer.
Payment confirmation before dispatch
Where objective reasons exist, the goods may be withheld until confirmation that the payment transaction has been properly initiated (Regulation EU 2018/302, Article 5(2)).
Two further exceptions concern defined groups. Traders exempt from value added tax under the VAT Directive are not subject to the prohibition for electronically supplied services (Regulation EU 2018/302, Article 4(4)). And where Union law, or member state law in accordance with Union law, prohibits sales to certain customers or into certain territories, the prohibition likewise does not apply; for the sale of books, different prices also remain permitted where national law requires them (Regulation EU 2018/302, Article 4(5)). Anyone operating in such ranges should keep the reasoning in writing, because in a dispute it carries the entire deviation.
Enforcement in Germany
The regulation leaves enforcement to the member states: each designates one or more bodies responsible and lays down rules on the measures applicable to infringements, which must be effective, proportionate and dissuasive (Regulation EU 2018/302, Article 7). In Germany this is the Bundesnetzagentur. Its competence follows from section 191 of the Telecommunications Act; section 2 number 6 of the Consumer Protection Enforcement Act additionally gives it extensive powers under Regulation (EU) 2017/2394 on cooperation in consumer protection (Bundesnetzagentur).
In accordance with section 191 of the German Telecommunications Act (TKG) the Bundesnetzagentur is the national authority responsible for enforcement of the Geo-blocking Regulation in Germany.
Bundesnetzagentur, evaluation of the Geo-blocking Regulation, December 2025
In practice this means: customer complaints land there, and the authority can issue orders and impose fines. Since 1 July 2026 it is additionally responsible for enforcing Article 20(2) of the Services Directive, which forbids unjustified differences in access to services generally (Bundesnetzagentur). For shop operators this shifts the picture noticeably: a matter previously pursued only under civil law now has an authority with its own reach. Cross-border cases are handled through the network of consumer protection authorities, so a complaint from another member state does reach the German trader.
The regulation is also in motion. Article 9 obliges the Commission to report on its evaluation by 23 March 2020 and every five years thereafter (Regulation EU 2018/302, Article 9). For the current round the Commission held a public consultation from 6 October 2025 to 5 January 2026 (Bundesnetzagentur). In the preceding call for evidence 598 responses were received, of which 571 focused on audiovisual services (Bundesnetzagentur) - an indication of where the political debate stands, and at the same time that for the trade in goods clarifications rather than a rebuild are to be expected.
Implementation in the shop: where it breaks
The rebuild is rarely large, but it spreads across several layers. The first is the country switch. Instead of a redirect based on the visitor address there is a notice offering a choice and storing the decision. The requested version stays in place as long as no consent exists - which satisfies Article 3(2) without further special cases. The excerpt below shows the logic in its simplest form; what matters are the three exit conditions, not the language they are written in.
<?php
// No automatic switch: the requested version stays in place.
// The notice appears only if another version exists.
function countryNotice(string $requested, ?string $chosen, ?string $country): ?array
{
if ($chosen !== null) {
return null; // The customer has already decided.
}
if ($country === null || $country === $requested) {
return null; // Nothing to offer.
}
if (!versionExists($country)) {
return null; // No version for this country.
}
return [
'target' => '/' . $country . '/',
'back' => '/' . $requested . '/', // The way back stays visible
'text' => 'There is a version for your country.',
];
}The second layer is the form. Address fields that reject postcode formats from other countries are the quietest exclusion of all: they produce no error report, no complaint and no log entry, only an abandonment. The same applies to country selectors that contain only shipping destinations - because the billing address may be in any member state, even one that is not supplied. The third layer sits in operations: block lists in the server configuration and in protection systems take effect before the application and are not visible from inside the shop.
Three queries of this kind answer the larger part of the question. The first shows whether a language preference alone already triggers a redirect. The second checks whether an address from another member state produces a redirect header - empty output is the desired result here. The third makes visible that the delivery territory is kept as a data record and not as a silent filter in the form. Checks like these belong in the same run as the other measurements taken before a release, see field data over lab scores.
- Tax and thresholds: supplying customers in other member states touches value added tax in the country of destination; the connections are covered in cross-border taxes.
- Master data and catalogues: country-specific availability belongs in maintained fields, not in exceptions in the program code. Handovers from the merchandise system and the catalogue run through the integrations. How such a catalogue is structured is covered in the article on BMEcat and ETIM.
- Ranges with restrictions: products that may not be supplied to individual countries need a maintained marker and the matching explanatory text in the language of the requested version.
- Adjustments to the standard: where the standard tools are not enough, the missing part is built as individual development inside the existing system instead of as a second tool next to it.
Checklist before the next release
A check only counts as a check once it is carried out from the perspective of several member states and leaves a record. Experience shows that three origins and two ordering paths are enough to produce the typical findings. It matters that the runs happen on an environment with real range and shipping rules, but without customer data - how to set that up cleanly is covered in staging with test data without customer data. The following list is the core of what a shop check works through on this topic.
- Switch redirects off or rebuild them into a notice with active consent, and test the way back.
- Check registration and checkout for country filters on address fields, running through at least three neighbouring countries.
- Keep the delivery territory as a maintained data record and offer it in the form, not as a silent filter.
- Check the payment selection against card country and account location, with at least one method for all member states.
- List blocks in the server configuration and in protection systems, with reason, trigger and duration.
- Store the explanatory text for legally required restrictions in the language of the requested version.
- File the results as a record and repeat the run with every change to country logic or checkout.
Where the effort really sits
The effort rarely sits in the switch that is turned off, but in the assumptions attached to it. A country switch often carries the currency selection, the tax logic and the range view along with it; removing it means anchoring those three things cleanly one by one. That is the actual work, and it pays off regardless of the regulation, because it dissolves a coupling that gets in the way again with every new market entry. Anyone thinking about a second country version anyway should do the rebuild in the same round rather than in two separate projects.
Commercially the calculation is unspectacular but clear: implementation raises reach slightly and lowers a risk noticeably that, since 1 July 2026, has an authority with its own reach behind it. The sensible entry point is a survey of the ordering path from three origins, followed by prioritisation by effort and effect. Anyone who would like their own shop reviewed will find the framework in our consulting or in a Shopware project; a short message through the contact form is enough for an initial assessment.
This article draws on Regulation (EU) 2018/302 of the European Parliament and of the Council of 28 February 2018 on addressing unjustified geo-blocking, in particular Articles 3 to 5, 7, 9 and 11 in the version published on EUR-Lex. The statements on enforcement in Germany, parcel forwarding, the delivery territory, payment conditions and the public consultation come from the Bundesnetzagentur position paper on the evaluation of the Geo-blocking Regulation of December 2025 and from the authority topic pages. The measured values on location requirements and access blocking come from the European Commission short-term review of 30 November 2020, which evaluates the 2019 website survey covering around 9000 websites. Regulation (EU) 2017/2394 on consumer protection cooperation, section 191 of the Telecommunications Act and section 2 of the Consumer Protection Enforcement Act in their applicable versions were used in addition.
As a rule yes. The regulation protects customers, and that includes undertakings as long as they buy the goods or services for end use and not for resale. A shop that supplies only businesses therefore typically cannot rely on a sector exemption. In practice this mainly means that the business check at registration must not become a hidden country filter: a VAT identification number from another member state is valid evidence and not a ground for rejection.
No, no delivery obligation arises from the regulation. The delivery territory remains a free business decision. In the view of the Bundesnetzagentur, all that is required is that a customer from another member state can place an order with delivery to a location within the offered territory; the onward transport is then theirs to organise. A shop shipping only within Germany may keep that arrangement, but should accept billing addresses from across the single market.
Yes. Article 4(2) expressly permits general conditions of access, including net sale prices, that differ between member states or within a member state, provided they are offered to a territory or a group of customers in a non-discriminatory manner. The price may therefore be tied to the market in which it is offered, but as a rule not to the origin of the individual customer. A surcharge that only appears once a foreign billing address has been entered typically does not hold up against that distinction.
Only with the explicit prior consent of the customer, and even then the version originally requested must remain easily accessible. Without consent the redirect is forbidden. An exception exists where the redirect is necessary to comply with a legal requirement; in that case a clear explanation is owed in the language of the interface originally requested. The simpler route is typically a notice offering a choice rather than a switch with exception rules.
The trader still decides which means of payment to accept. Within that selection, however, it may not differentiate by origin, account location, the seat of the payment service provider or the place of issue of the card. According to the Bundesnetzagentur, the European Commission stated orally that one common payment method available in all member states is sufficient; a written clarification is still outstanding. In practice at least one method that works without a domestic bank account and without a domestic card has proven itself.
The Bundesnetzagentur is responsible on the basis of section 191 of the Telecommunications Act; section 2 number 6 of the Consumer Protection Enforcement Act gives it additional powers under Regulation (EU) 2017/2394. It can issue orders and impose fines, and since 1 July 2026 it is additionally responsible for Article 20(2) of the Services Directive. The level of any fine depends on the individual case; the regulation itself only requires member states to lay down measures that are effective, proportionate and dissuasive. For an assessment of your own shop a conversation is enough to begin with, see contact.