FAQ: Legal & Accessibility

Yes, under certain conditions: shops that only use technically necessary cookies and rely on analytics that do not access the visitor's device generally need no consent under § 25 of the German TDDDG – and therefore no cookie banner. Consent-dependent services such as Google Analytics or advertising pixels must be replaced or removed for this to work.

The EU Packaging and Packaging Waste Regulation (PPWR, EU 2025/40) applies directly in all EU member states and has applied since 12 August 2026. Since then, packaging that does not meet the requirements already in force may no longer be placed on the EU market. Further obligations for online retailers follow in stages: harmonised labelling from 2028, recyclability and an empty space limit (max. 50%) from 2030.

The German Accessibility Act (BFSG) has required B2C online shops to make their entire purchase process accessible since 28 June 2025 – from product search to payment. The technical benchmark is WCAG 2.1 at level AA, referenced by EN 301 549. Violations can lead to fines of up to 100,000 euros as well as warning letters from competitors and consumer associations.

Three areas matter most for product photos: copyright (usage rights are required for every image – including manufacturer photos), unfair competition law (the image must show the product accurately, and decorative items must be labelled) and, for AI-generated images, the EU AI Act labelling obligation that has applied since 2 August 2026. Violations frequently result in formal warning letters in Germany.

An online shop in Germany generally needs at least: a complete imprint (Impressum), a privacy policy, a withdrawal notice with a model withdrawal form, transparent prices in line with the Price Indication Ordinance (including VAT, shipping costs and unit prices where applicable) and an order button with unambiguous wording such as "order with obligation to pay". Since 19 June 2026, a mandatory withdrawal button has also been required.