Yes, a customer in Germany may return a parcel without a return label. The right of withdrawal does not depend on a label or a form: the customer states the withdrawal clearly, for example by email, and sends the goods back within 14 days of that statement. They pay the postage themselves if the store told them before the purchase that customers bear the cost of returns.
For the merchant, that is where the work starts. A parcel like this has no return number, often no note, and sometimes only a surname on the label. You still have to match it to the right order and answer the customer. The legal references are to German law, which implements the EU Consumer Rights Directive.
Can you return a parcel without a return label?
Yes. A return label is a service the store offers, not a condition of the withdrawal. German law asks the customer for a statement to the seller that clearly shows their decision to withdraw (§ 355(1) BGB). After that they have 14 days to send the goods back (§ 355(3), § 357(1) BGB), and sending the parcel in time is enough to meet that deadline.
The law does not care how the parcel travels. DHL’s own returns help page says that if no return label is enclosed, customers can buy postage through DHL Online-Frankierung or at a post office. No printer needed: according to DHL, the postage can also be a QR code that is printed at the drop-off point or by the courier (DHL returns, as of October 2026).
Keep the proof of postage. Under German law, the risk of a lost return sits with the merchant (§ 355(3) BGB; the EU directive leaves this to each country), but proving the parcel was sent at all is up to the sender, as DHL points out.
Withdrawal and return are two separate steps
Some customers think the parcel itself is the withdrawal. Since Germany implemented the EU Consumer Rights Directive, it is not. The German legislator’s explanatory memorandum says plainly that returning the goods without comment is no longer enough to withdraw (Bundestag document 17/12637, p. 60). The official German model withdrawal notice likewise asks for an unequivocal statement and gives a letter sent by post or an email as examples.
A note in the box changes that. Recital 44 of Directive 2011/83/EU lists a letter, a phone call or returning the goods with a clear statement as ways to meet the requirement. A note saying “I withdraw, please refund” with a name and order number can therefore be enough.
Then there is the parcel with no word at all. The same memorandum says seller and customer may agree that the return alone counts as a withdrawal. Even then you have to check whether the customer meant to withdraw or to report a defect. Defects follow the statutory warranty rules, covered in warranty vs. legal guarantee.
In practice: accept the silent parcel, match it to an order, and ask. One email tells you whether it is a withdrawal, a defect or an exchange.
Who pays postage and when you must refund
Return shipping. The customer bears the direct cost of the return only if you told them so beforehand (§ 357(5) BGB). If you said you would cover it, that still applies without your label. The statute does not expressly say whether you must reimburse postage that cost more than your own label, so set a rule on your returns page.
Refund deadline. You refund within 14 days of receiving the withdrawal statement (§ 355(3), § 357(1) BGB). If it came by email, the clock starts with the email. If the note in the parcel is the statement, it reaches you with the parcel.
Holding the refund. You may hold the refund until the goods are back or the customer proves they sent them (§ 357(4) BGB), unless you offered to collect the goods. A photo of the proof of postage shows you that the parcel went out and when.
Amount. You refund the price plus outbound shipping up to your cheapest standard option, using the same payment method (§ 357(2) and (3) BGB). Value deductions and deadlines are covered in the EU right of withdrawal guide.
Unannounced returns: how to find the order
Without a return number, every parcel is a small puzzle. Work through these steps in order and stop once two details match for certain.
- Photograph first, then open. Start with the shipping label showing sender and tracking number, then the contents with their product tags. You need the photos for the customer email and for any later question.
- Look for paperwork. If the packing slip or invoice is in the box, the order number is on it.
- Search the sender in your store. In Shopify or WooCommerce, search by surname, street and postcode, not only the full name. The label sometimes shows whoever dropped the parcel off.
- Match the contents to orders by SKU, variant and size, narrowed to orders delivered in the last few weeks.
- Search your inbox for the name, the address, and words like “returned”, “sent back” or “withdraw”. The customer may already have written, just without an order number.
An example: the label says “Schneider, Leipzig”, the box holds a black hoodie in size M, no note. Your store has three open orders: Maria Schneider from Leipzig with a black hoodie in L, Michael Schneider from Hamburg with the same hoodie in M, and Jana Schneider-Kraus from Leipzig with two T-shirts. The address points to Maria, the size to Michael.
Guessing gets expensive here. Refund the wrong order and the money is gone while the right customer keeps waiting. First check what actually shipped to Maria. If the warehouse packed an M instead of an L, everything fits. If not, email Maria with a photo of the contents, since the address is the stronger signal, and check your inbox for anything from Michael.
When a parcel cannot be matched
Some parcels stay open. Log them as unresolved with arrival date, photos, tracking number, sender and contents, and keep the parcel apart from the regular returns shelf. When someone later asks about a refund for a return you cannot find, check that list first and ask for the tracking number on their proof of postage. If it matches the label on the shelf, you are done.
Reply templates
The customer asks whether they can return without a label:
Hi Jonas, yes, that works. The easiest way is our returns portal, where you get the label right away: [link]. Without a label is fine too: send us a short note that you want to withdraw from order 10388, put a slip with the order number in the parcel and keep your proof of postage. As soon as the parcel arrives, we refund you.
A parcel arrived without a message:
Hi Maria, a parcel with a black hoodie in size M arrived today, sender Schneider from Leipzig. A photo is attached. Is this your return for order 10412? Would you like to withdraw from the purchase, or is it about a defect or an exchange? Let us know and we will take care of it right away.
How to get fewer parcels without a label
- A return portal. The customer registers the return with order number and email and gets a label or clear instructions. What a good one needs is in the return portal guide.
- A prefilled label, even when the customer pays. DHL Retoure has an option for this, a link to DHL Online-Frankierung: your customer buys prefilled postage through your link. Customers without a printer use the QR code, and the label is printed at the drop-off point (as of October 2026, per DHL).
- One line on the packing slip: “Please add a note with your order number to every return.” It costs nothing and saves you the detective work.
What Sondercase handles
Sondercase includes a returns portal for Shopify and WooCommerce. Your customer finds the order with order number and email address. Depending on your rule, they download a prepaid label that you upload as a PDF from your own carrier account, or get instructions to ship the parcel themselves.
If they write “I sent it back” by email, WhatsApp, Instagram or Facebook instead, Sondercase recognises the return request, matches it to the right order and opens a return case. The refund comes fully prepared, and you release it with one click. Replies to “where is my refund?” can run fully automatically per category. Opening and checking the parcel in your warehouse stays with you. The full flow is on the returns management page.
This article is a practical overview for merchants and not legal advice. Carrier services can change. Have your withdrawal notice and return policy reviewed by a lawyer.