Does the Geo-blocking Regulation require delivery to every EU country?

The Citead team, updated

In short. The Geo-blocking Regulation requires equal access under existing delivery or collection arrangements without requiring delivery to every EU country.

Definition: As applicable on 17 October 2026, the EU Geo-blocking Regulation does not require delivery to every EU country. Article 4 requires equal access to goods under a trader's existing delivery or collection arrangements, regardless of the customer's nationality, residence or establishment.

Key facts

  • Article 4(1)(a) of the Geo-blocking Regulation covers delivery to locations the trader already serves and collection under its existing terms.
  • The Commission's Questions & Answers explains that traders have no obligation to set up collection points in other countries.
  • Article 8(3) of the Consumer Rights Directive requires trading websites to display delivery restrictions clearly and legibly by the beginning of the ordering process.

What equal access does Article 4 require?

General conditions of access are the publicly available terms governing a purchase, including net sale prices, as defined in Article 2(14) of the Geo-blocking Regulation. Recital 15 expressly includes delivery conditions in these terms.

Article 4(1)(a) prohibits different conditions based on a customer's nationality, residence or establishment when goods are delivered to a location in a Member State covered by the trader's delivery terms. It also covers collection at an agreed location in a Member State where the trader offers collection under those terms. Recital 23 specifies equal conditions, including the price and delivery conditions, compared with similar local customers.

The Commission's Questions & Answers illustrates this with a Belgian customer ordering a camera from a German website that offers delivery and collection only in Germany. The customer can use a German delivery address or the offered collection arrangements under the same conditions as a German consumer.

Who arranges delivery beyond the shop's service area?

Recital 23 of the Geo-blocking Regulation explains that customers may collect goods in the country served by the trader or arrange onward cross-border delivery privately. Recital 28 confirms that the Regulation creates no obligation to deliver to another Member State outside the trader's delivery offer. It also creates no additional obligation to bear postage, transport or assembly costs beyond the contractual agreement under applicable law.

The Commission's Questions & Answers gives the example of a trader offering delivery or collection points only in Portugal. Spanish customers can collect goods themselves or through designated people or providers at the Portuguese collection points. The trader has no obligation to establish collection points in Spain.

Can national websites offer different prices and delivery options?

Article 4(2) of the Geo-blocking Regulation permits different general conditions, including net sale prices, between or within Member States when offered on a non-discriminatory basis.

The Commission's Questions & Answers explains that the terms of the website used for the order apply. Its example concerns a Greek customer ordering from a Bulgarian website whose terms provide delivery only in Bulgaria. The customer cannot demand delivery to Greece simply because the trader's Greek website offers it. If both websites' terms include delivery to both countries, the national website used for ordering cannot itself restrict that delivery service.

For consumer orders, Article 8(3) of the Consumer Rights Directive requires the website to indicate delivery restrictions at the latest when ordering begins. Article 6(1)(g) also requires pre-contractual information about delivery arrangements and the time by which the trader undertakes to deliver.

FAQ

Can you combine one national website's price with another's delivery options?

The Commission's Questions & Answers explains that an order uses the terms of the website on which it is placed. A delivery option available only under another national website's terms is outside that order's conditions.

Does the protection also cover business purchases?

Yes. Article 2(13) of the Geo-blocking Regulation includes businesses established in a Member State when purchasing solely for end use. Recital 16 excludes purchases for subsequent resale, transformation or processing.

Yes. Article 4(5) of the same Regulation permits a restriction where a specific provision of EU law, or national law consistent with EU law, prevents sales to certain customers or territories.

Sources

  1. European Parliament and Council, "Regulation (EU) 2018/302", 28 February 2018
  2. European Commission services, "Questions & Answers on the Geo-blocking Regulation in the context of e-commerce", 2018
  3. European Parliament and Council, "Directive 2011/83/EU on consumer rights", consolidated 27 September 2026

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