Module 5 · 5.1

Who you are: information obligations and the Impressum

Module 5: Obligations and terms · Reading time: 10 minutes

Learning objective: After this lesson you can list the information a web shop must give consumers in advance, where it belongs in a WooCommerce shop, and what the German Impressum requires.

Key concepts: distance contract, consumer, pre-contractual information, identity and business address, KVK number (Dutch Chamber of Commerce), enterprise number, VAT identification number, total price, delivery restrictions, means of payment, Impressum, accessibility

This lesson explains the rules as they apply on 9 November 2026. It is not legal or tax advice. If you are unsure about your situation, ask a lawyer, your trade association or your accountant.

Why the law asks for so much information

In a physical shop you see the seller, the product and the till. Online you only see a screen. Who is behind it? Where can you go if something goes wrong? What does it really cost, including shipping? The European rules for distance selling are built around that uncertainty: the consumer must know enough before the purchase to make an informed choice and to be able to use their rights later.

These rules apply when you sell to consumers (private individuals who are not buying for their business) and the purchase is concluded at a distance: through your website, by phone or by email. If you only sell to businesses, most of the rules in this module do not apply, although some (such as the details of who you are) still do. If you are unsure whether your customers are consumers, assume they are.

The basis is a single European directive, Directive 2011/83/EU on consumer rights. Every EU country has transposed it into its own law. The content is therefore almost the same everywhere; only the article numbers differ:

Country	Where the information obligation is set out
EU	Article 6 of Directive 2011/83/EU
Netherlands	Article 6:230m of the Dutch Civil Code (and Article 3:15d of the Civil Code for every website that provides services)
Belgium	Article VI.45 of the Belgian Code of Economic Law
Germany	Article 246a § 1 EGBGB, plus the Impressum in § 5 DDG

What you must tell customers in advance

Article 6:230m of the Dutch Civil Code (Netherlands) contains a long list. The points that come up in every web shop:

The main characteristics of the product: what it is, what size, what material. That is simply a good product page (lesson 3.1).
Your identity: your trade name, and the geographical address where you are established. A PO box is not enough.
How customers can reach you: phone number and email address. A contact form may be added, but it does not replace the email address.
The total price including taxes, and all additional costs such as shipping. If you cannot calculate these in advance, say that additional costs may apply.
Payment, delivery and delivery time: how customers pay, how the goods are delivered, and within what period.
The right of withdrawal: the conditions, the period, how to use it, the model withdrawal form, and since 2026 also where the withdrawal button is (lessons 5.2 and 5.3). If there is no right of withdrawal, say so.
Who pays the return costs, if the consumer has to pay them.
The legal guarantee: a reminder that the product must do what the customer may reasonably expect.
Where applicable: complaints handling, after-sales service, a commercial guarantee, codes of conduct.

In addition, Article 3:15d of the Dutch Civil Code (Netherlands, based on the European directive on electronic commerce) requires every website that provides a service to show: identity and business address, an email address, the trade register with your registration number (your KVK number (Dutch Chamber of Commerce)) and your VAT identification number if you are liable for VAT. The second paragraph states that prices must clearly indicate whether tax and delivery costs are included. In Belgium the same applies with the enterprise number (KBO), in Germany with the Handelsregister and the USt-IdNr.

Watch out for the VAT identification number in the Netherlands: since 2020, sole traders have a separate VAT identification number for their website and invoices, alongside the VAT tax number used for the Belastingdienst (Dutch Tax Administration). The VAT identification number starts with NL and ends with B followed by two digits.

When and where it must appear

The law does not say "somewhere on the site", but requires the information at specific moments:

Always accessible: who you are and how customers can reach you. In practice: a footer on every page with your name and a link to a contact page with your address, phone, email, KVK number and VAT identification number.
At the latest at the start of the ordering process: whether there are any delivery restrictions (for example, you do not ship outside the EU) and which means of payment you accept. In the Netherlands this is in Article 6:230v paragraph 4 of the Dutch Civil Code, in Germany in § 312j Abs. 1 BGB. A row of payment logos in the footer and a sentence such as "we ship to the Netherlands, Belgium and Germany" on the shop pages will do.
Just before the order button: the essentials once more, clearly and prominently (characteristics, total price, duration for a subscription). That is covered in lesson 5.4.
After the order: a confirmation on a durable medium, usually the confirmation email, with all the information you had not yet given in that form (lessons 5.4 and 6.1).

Pitfall: putting all the mandatory information only in your terms and conditions. The ACM (Netherlands Authority for Consumers and Markets) warns against this: consumers should not have to search for the information. Put it where it belongs.

Germany: the Impressum

If you sell to German customers, or target your site at Germany, you will come across the Impressum. It is set out in § 5 of the Digitale-Dienste-Gesetz (DDG), the successor to the old § 5 TMG. Anyone offering digital services "geschäftsmäßig" (on a business basis), and a web shop falls under this, must keep the following details "leicht erkennbar, unmittelbar erreichbar und ständig verfügbar" (easily recognisable, directly accessible and permanently available):

name and address where you are established; for a legal entity, also the legal form and who represents it;
details for quick electronic contact, including an email address;
the trade register and the registration number, if you are registered;
the Umsatzsteuer-Identifikationsnummer (German VAT identification number), if you have one;
for licensed or regulated professions, more details, such as the supervisory authority or the professional body.

In practice, "unmittelbar erreichbar" means: a link with the text "Impressum" in the footer of every page, leading to the page with these details in one click. An Impressum that can only be found via "About us" and then another click is often considered insufficient in Germany. The Impressum is a German rule; in the Netherlands and Belgium a contact page with the same details is enough, but a Dutch shop with German customers would do well to have both.

Accessibility

Since mid-2025, the European accessibility directive (Directive (EU) 2019/882, also known as the European Accessibility Act) also applies to web shops that sell to consumers. Germany transposed it in the Barrierefreiheitsstärkungsgesetz (BFSG), the Netherlands and Belgium in their own legislation. Small businesses may be exempt for services; check whether that applies to you. Even if you are exempt, it pays off: a shop that can be operated with the keyboard, with good contrast and alt texts, sells to more people. The basics (alt texts, headings) are covered in the WordPress course, lesson 4.4.

In practice: how it looks in WooCommerce

WooCommerce itself does not create a contact or Impressum page. This is how you handle it at Theehuis Example (shop.example.com):

Under Pages > New Page, create a "Contact" page with your trade name, business address, phone, email, KVK number and VAT identification number. For German customers, create an "Impressum" page with the details from § 5 DDG.
In your theme's footer (with a block theme: Appearance > Editor > Patterns > Footer, with a classic theme usually under Widgets or the Customiser), add links to Contact, Impressum, Terms and Conditions, Privacy and Right of withdrawal.
Under WooCommerce > Settings > General, fill in the store address; WooCommerce uses it for VAT and shipping, among other things. It does not appear on your site automatically.
Show the payment methods and the countries you ship to somewhere visible before checkout, for example below the "Add to cart" button or in the cart.

Other themes and shop systems work in a similar way: what matters is where the information appears, not the plugin.

Summary

The information obligation comes from Directive 2011/83/EU; in the Netherlands Articles 6:230m and 3:15d of the Dutch Civil Code, in Belgium VI.45 of the Code of Economic Law, in Germany Art. 246a EGBGB and § 5 DDG.
Always available: name, business address, phone, email, KVK number or Belgian enterprise number, VAT identification number.
At the start of ordering: delivery restrictions and means of payment; prices always including VAT and with the additional costs.
Germany requires an Impressum that is directly accessible, usually via an "Impressum" link in the footer.
Since 2025, accessibility is also a rule for web shops; check whether your business is exempt.

Quiz

Exercise

Exercise A5.1: Can you find out who the seller is? Enter your shop's address and choose the country where you are established. You can also enter the address of your contact or Impressum page. The program fetches the homepage (without cookies, like a new visitor) and reads the links. It opens the page you entered, or otherwise the first link with "contact", "impressum" or "over ons" in its text or address. In the text of the homepage and that page, it looks for an email address (red if missing), a phone number, a postcode in your country's format, your KVK number, Belgian enterprise number or Handelsregister, and your VAT identification number (orange if something is missing). If you choose Germany, the homepage must have a link with the text "Impressum"; otherwise the result is red. The program only sees whether the details are there, not whether they are correct.

A question for yourself (not checked): as a customer, click from a product page to your contact details. How many clicks did that take?

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