I get your point that the digital one has to jump through hoops due to these regulations, but there are alternatives if you need one /now/
If you collect in your car in Germany, as I did, and drive it over the border yourself then you almost certainly won't get one (although I've ever been lucky!) so you need to purchase one (physical or digital) before (or as) you cross the border.
In Portugal, we use digital ones (Via Verde) and they are activated at time of purchase.
In Switzerland, physical vignettes are always available on rented cars.
https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A...
3. Unless the parties have agreed otherwise, the consumer may not exercise the right of withdrawal provided for in paragraph 1 in respect of contracts:
- for the provision of services if performance has begun, with the consumer's agreement, before the end of the seven working day period referred to in paragraph 1,
Of course they don't, but thanks for the specific link!
The "gold-plating" - or indeed misunderstanding - of EU regulations has a long and (in)glorious history.
If the 14 days do apply you have to inform the customer about it or it turns into 12 months.
If that's true then it's possible that Asfinag (the toll agency) haven't updated their website. On trying a test purchase just now to buy a two-month or annual pass it still states:
"I'm a consumer
Digital 2-month vignettes and digital annual vignettes purchased today are valid from 25.12.2023 at the earliest due to the right of withdrawal when purchasing online. All other toll products can be used immediately. (More info in the FAQ)
I represent a company
The right of withdrawal does not apply to commercial customers; purchased digital toll products are therefore valid immediately. (More info in the FAQ)"
"18-days-period Consumer protection is very important to us – especially as far as our digital products are concerned. Customers can withdraw from the online purchase of a digital vignette within 14 days. Taking into account a further three-day period for mail, your digital 2-months and annual vignette is only valid from the 18th day after purchase.
This deadline does not apply if you purchase a 1-day or 10-day vignette!"
Which is of course how you immediately know that it is not just unimportant to them but they will try to do anything to not have to abide by the rules and maliciously comply with anything they can't disregard completely.
Really the 14 days should start when you actually receive the item in a usable state and if the law actually allows these kind of workarounds around that then it should be changed.
One (unintended?) consequence of this is that as a consumer, you cannot buy an annual digital motorway toll pass in Austria with immediate validity. The earliest your pass can start from is 18 days from the date of purchase.
"Customers can withdraw from the online purchase of a digital vignette within 14 days. Taking into account a further three-day period for mail, your digital 2-months and annual vignette is only valid from the 18th day after purchase."
https://www.asfinag.at/en/toll/vignette/digital-vignette/
How glorious that it's necessary to include 3 extra days to cover the potential delivery time of postal mail in the event of a return for an entirely digital product :/
The workaround for this - which I discovered last time I drove a rental car in Austria - is to tick the box that says "I'm a business, not a consumer". You don't need to prove you're a business, just to tick the box. Consumer protection nullified, can purchase product valid immediately.... <sigh>