Who pays for a return
An online shop in Ukraine currently operates under Consumer Protection Law No. 1023-XII. A buyer may terminate a distance contract within 14 days of the information being confirmed or the goods being received (Article 13, part 4). Parts 5–9 of Article 12 apply to such contracts (Article 13, part 7), and Article 12, part 5 is explicit: any costs related to returning the goods are borne by the seller, and the seller must reimburse the consumer's return costs.
Another rule in the same article affects markdowns: a drop in the goods' value because the packaging was opened, or the goods were inspected or tested, does not take away the buyer's right to terminate (part 7). An opened box is not a reason to refuse.
This changes the question itself. A "free returns" label on a shop's site today is not a marketing offer but a description of what the law already requires. An offer clause saying "the buyer pays for return delivery" contradicts it; more on such clauses in the article on the legal minimum for an online shop.
What will change. The new Consumer Protection Law No. 3153-IX has the status "entering into force" as of 28 October 2026: it takes effect one year after publication, but not before martial law is ended or lifted. Under its Article 21 (part 8) the consumer returns the goods at their own expense. There are three exceptions: the seller offered to collect the goods at its own cost; the seller did not inform the buyer of the return method and costs when the contract was concluded; or digital content was supplied without proper consent. Only then will free returns become the shop's choice, and it is worth knowing their price now.
What one return consists of
A return after purchase is not the same as a refused cash-on-delivery parcel. With a refusal, the parcel goes back from the branch without the buyer's involvement; how to price that is covered in the article on cash on delivery. Here we mean goods the buyer collected, paid for and then sent back.
On such an order the shop loses six things:
- Delivery to the buyer, if the shop paid for it.
- Packaging of the first shipment.
- Return delivery: under the current law the seller pays for it — as the recipient of the parcel at the branch, or by reimbursing the buyer.
- Handling time: unpacking, inspecting, repacking, updating stock records.
- Markdown: some returned goods are sold at a discount or written off.
- The payment fee, if the payment provider does not refund it when money is returned to the buyer. Check this in your contract.
An illustrative example: a UAH 1,200 order, cost of goods UAH 660, parcels up to 2 kg within Ukraine. Under Nova Poshta's rates effective 10 September 2026, delivering a small parcel between branches costs UAH 90, and a box with packing costs UAH 15. Under the detailed tariff terms, the declared value fee is included in the rate up to UAH 500; above that it is 0.5% of the declared value, which is UAH 6 for a UAH 1,200 order. The buyer sends the goods back at the same rate. The card payment fee is 1.3%, LiqPay's standard rate for Ukrainian cards. Handling is estimated at UAH 30 and the markdown at 10% of the cost of goods; both figures are illustrative.
Delivery: UAH 90 for a parcel up to 2 kg within Ukraine + 0.5% of a UAH 1,200 declared value. Nova Poshta and LiqPay rates checked on 28 October 2026. Handling and markdown are illustrative estimates.
One return costs UAH 318.60 — 27% of the order value. Add the advertising that brought the order: if the order cost UAH 200 to acquire, the return takes UAH 519, and there is no profit from it.
The threshold: what return rate eats the profit
Let us calculate profit per shipped order. A kept order earns its margin: order value minus cost of goods minus the payment fee. A returned one brings zero revenue plus the costs from the previous section. Delivery, packaging and advertising are spent on every shipped order.
In the same example, the margin on a kept order is UAH 524.40, and after delivery, packaging and advertising UAH 213.40 remains if there are no returns. Each return takes the order's margin plus its extra costs: 524.4 + 207.6 = UAH 732. So every percentage point of returns costs the shop UAH 732 per 100 shipped orders.
| Return rate | Profit per shipped order |
|---|---|
| 0% | UAH 213 |
| 5% | UAH 177 |
| 10% | UAH 140 |
| 15% | UAH 104 |
| 20% | UAH 67 |
| 25% | UAH 30 |
| 30% | −UAH 6 |
The break-even point is 213.4 / 732 = 29.2%. The formula for your own numbers:
threshold = (margin − delivery − packaging − advertising) / (margin + return delivery + handling + markdown + fee)
The threshold depends heavily on the markup. Below is the same shop with a UAH 1,200 order but different costs of goods. The third column is the threshold under the current law; the fourth applies if the buyer pays for return delivery, as the new Law No. 3153-IX provides.
| Markup on order value | Profit with no returns | Threshold under No. 1023-XII | Threshold if the buyer pays return delivery |
|---|---|---|---|
| 30% | UAH 33 | 5.9% | 7.0% |
| 35% | UAH 93 | 15.0% | 17.7% |
| 40% | UAH 153 | 22.6% | 26.4% |
| 45% | UAH 213 | 29.2% | 33.6% |
| 50% | UAH 273 | 34.8% | 39.6% |
| 60% | UAH 393 | 44.0% | 49.3% |
Two things follow from the table.
Return delivery is not the main item. Shifting it to the buyer, once the new law allows it, raises the threshold by only 1.1–5.3 percentage points. For every 100 shipped orders at a 10% return rate, that is UAH 960: ten return parcels at UAH 96. The main loss is the margin of the order that no longer exists.
A low markup cannot absorb returns at all. At 30%, a shop spending UAH 200 on advertising per order earns UAH 33 with no returns and breaks even at 6%. How to test your model at the level of one order is covered in the article on online shop unit economics.
Calculator
The default values are the illustrative example above. Enter your own: delivery including the declared value fee, and your return rate for the last three months.
What lowers the cost of returns
- Count returns by product and reason. A shop-wide return rate hides a few items that account for most returns. Size, colour, "not as in the photo" — each reason has its own fix: a size chart, unretouched photos, a description of the material.
- Pay for returns as the recipient. The law requires reimbursing the buyer's return costs. If the shop pays for the return parcel at the branch itself, the buyer does not have to send a receipt and the shop does not have to make a separate transfer.
- Do not put anything in the offer that contradicts the law. "Returns only in undamaged packaging" or "the buyer pays for return delivery" will not cut costs; they give grounds for a complaint.
- Check the threshold for low-markup goods. If the threshold is below your actual return rate, the problem is not returns but the price or the advertising for those goods.
- Prepare the offer for the new law now. Once No. 3153-IX takes effect, a shop that has not told the buyer the return method and costs will still pay for returns itself.
Our position
Do not treat "free returns" as a marketing cost that can be switched off: under the current law it is mandatory. Calculate the break-even return rate for each product group and compare it with the actual rate. When the new law allows shifting return delivery to the buyer, the difference for a shop with a 40–50% markup will be 3.8–4.8 percentage points of threshold. Compare that with how many points you can cut the return rate itself for your goods.
This position does not hold if your goods are heavy or bulky. For parcels up to 30 kg, Nova Poshta charges UAH 200, and for heavier ones from UAH 12 per kilogram; return delivery then becomes the main loss rather than a detail. Run your case through the calculator.
Rates checked on 28 October 2026 on the Nova Poshta site (rates from 10.09.2026, the "Return" service terms, detailed tariff terms) and LiqPay; legal provisions checked in the texts of Laws No. 1023-XII and No. 3153-IX on zakon.rada.gov.ua. The calculation is an illustrative example; substitute your own order value, cost of goods and return rate.