Data & measurement

The cooling-off cancellation is not churn: it is a 10-day right

Since Disposición 954/2025, every ecommerce selling in Argentina has to offer a visible cancellation link: 10 calendar days to cancel with no reason given. It is a legal right, not a dissatisfaction signal, and folding it into churn inflates that metric while hiding the problem worth solving.

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What matters

  • Disposición 954/2025 (Subsecretaría de Defensa del Consumidor y Lealtad Comercial, published in the Boletín Oficial on September 4, 2025) unified the cooling-off right and the service cancellation link into a single rule now in force.
  • The window is 10 calendar days from the moment the consumer receives the product or contracts the service, with no reason required and no extra paperwork.
  • The rule excludes products already used or consumed (Article 1116 of the Código Civil y Comercial) and purchases made for resale.
  • A legal cooling-off cancellation and a churn event triggered by dissatisfaction are two different signals: only the second one says anything about product, price, or experience.

A customer buys, receives the product, and cancels five days later with no reason given. If that event lands in the same counter as a cancellation caused by bad service, your retention dashboard is adding up two different things as if they were one.

What Disposición 954/2025 requires

Since September 4, 2025, the Subsecretaría de Defensa del Consumidor y Lealtad Comercial unified the cooling-off right and the service cancellation link into a single rule, replacing the earlier resolutions on the topic. Every provider selling online or through digital channels in Argentina has to show a visible link, the cancellation button, that lets a consumer cancel the purchase within 10 calendar days of receiving the product, with no reason required and no extra paperwork.

The rule carves out two cases: a product or service already used or consumed (Article 1116 of the Código Civil y Comercial) and purchases made for resale. Outside those two cases, the right is unconditional: a customer can return something in perfect condition for no reason other than changing their mind.

Why folding it into churn breaks the metric

Churn measures a decision to stop being a customer, usually tied to price, a bad experience, or a product that failed to deliver. We already covered how a one-time price increase produces a cancellation pattern distinct from baseline abandonment: that same distinction disappears once every cancellation lands in one bucket. A cooling-off cancellation needs none of those three causes: it can happen with a flawless product, a competitive price, after a smooth buying experience. If your churn report does not separate that event out, you will chase a cause that does not exist every time the number climbs.

The problem is not only definitional, it is also about where the data lives. The cancellation link is usually processed in logistics or payments, while churn gets calculated in the CRM or the lifecycle platform. If those systems do not share the cancellation reason, the information stays split across tools that do not talk to each other, the same gap a customer data platform exists to close, and rebuilding it by hand does not scale.

How to separate the two signals

  1. Tag the reason at the source: if the cancellation came through the cooling-off link, mark it in that same event, do not infer it later from the date.
  2. Pull cancellations inside the 10-day window with no other stated reason out of your churn calculation.
  3. Measure cooling-off cancellations as their own rate: a high number there says something too, but about how clear the offer was before purchase, not about the relationship with the customer afterward.
  4. Check the pattern by product category: a rate concentrated in a few products usually points to a description or photo that does not match what arrives, a pre-sale problem, not a retention one.

If your churn metric rises after a successful campaign, before looking for what went wrong in the relationship with those customers, check how many of those cancellations happened in the first 10 days. You may not have lost a customer. Someone may have used exactly the right the law gives them.

Frequently asked questions

What is the "botón de arrepentimiento" in Argentina?

It is a visible link every online store or digital sales channel has to show, letting a consumer cancel a purchase within 10 calendar days of receiving it, with no reason required and no extra paperwork. It is regulated by Disposición 954/2025 from the Subsecretaría de Defensa del Consumidor y Lealtad Comercial.

Should a cooling-off cancellation count as churn?

It should not be counted the same way. Churn measures a decision to stop being a customer, usually tied to price, product, or experience. A cooling-off cancellation is a legal right that can be used with no reason at all, even with a product that delivered exactly what it promised. Mixing the two inflates the churn metric without pointing at any real problem.

Are there exceptions to the cooling-off right?

Yes. The rule does not apply if the consumer already used or consumed the product or service (Article 1116 of the Código Civil y Comercial) or on purchases made for resale. No prior registration or extra paperwork can be required to use the right within the window.

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