Online retailers must include unavoidable delivery costs in the total price customers see, the Competition and Markets Authority has reminded traders as the Christmas shopping period approaches. The regulator is asking businesses to check the way charges appear across websites, mobile applications, and online advertising, rather than relying on explanations at checkout.
Where a shopper cannot buy an item without paying a delivery fee, the minimum mandatory delivery charge must be incorporated into the total price throughout the sales process. The requirement applies to product listings, advertising, baskets, and order summaries. Retailers can still explain separately how much of the total relates to the goods and how much to delivery, provided the full price is clear and timely.
An online marketplace may list products from several independent sellers, each with different delivery terms. Where an item can be bought individually, the displayed total must reflect that seller’s compulsory delivery charge. The obligation therefore reaches beyond the retailer’s own checkout system to the product feeds and marketplace listings through which customers compare offers.
The distinction between compulsory and optional delivery is central. A premium express service that customers can choose does not need to be included in the starting price as though it were mandatory. Its terms and cost must nevertheless be made clear before the customer commits. Concealing optional charges in dropdown menus, links, separate pages, or late checkout screens is among the practices the CMA says it will monitor.
The rules sit within the consumer protection framework strengthened by the Digital Markets, Competition and Consumers Act. They are intended to stop what is commonly called drip pricing: presenting an attractive initial price and adding unavoidable amounts later, after a customer has invested time in making a purchasing decision. The CMA says the first price a shopper sees should represent the price they pay.
The regulator identifies four patterns of concern: omitting mandatory delivery from displayed product prices, leaving it out of basket or order totals, obscuring information about optional fees, and revealing delivery charges only near payment. Its guidance also recognises that some prices cannot be calculated precisely at the first interaction; traders must still explain when additional charges may arise.
Enforcement is already active. The CMA says it has acted against four businesses over drip pricing, imposing fines totalling more than £5.1m and securing over £1.35m in consumer refunds. Under the current regime it can impose substantial penalties directly and require redress for affected customers where the legal conditions are met.
Retailers selling through multiple channels will need their advertising, catalogue, and checkout information to work consistently. The CMA’s immediate focus is transparent presentation of the full purchase cost before shoppers reach the final payment stage, including when products are offered through third-party marketplaces.
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