CMA urges online UK retailers to review pricing and delivery fee transparency

Summary of actions for online retailers selling goods to UK customers

The Competition and Markets Authority (CMA) has issued a reminder to all retailers of the importance of ensuring that they make prices – including delivery fees – clear to customers up front. They are encouraging any business who has not already done so to review their website, mobile app and online advertising to ensure that their pricing is clear and complies with the law.

Based on the reminder letter – see attached here, we are alerting all our retailing members to review and update the pricing now, so customers receive clear, prominent and timely information about the total price from the outset.

•    Review all sales channels and stages. Check websites, mobile apps and online advertising, including product pages, carts and baskets, order summaries, checkout and payment pages.
•    Show the total price whenever a price is given. Include all unavoidable fees, taxes and charges. Where delivery or collection is mandatory, include the minimum mandatory charge throughout the sales process—not just at checkout.
•    Include flat delivery charges in total prices. If one mandatory delivery fee applies to a multi-item order, ensure the total prices shown throughout shopping include that fee. A breakdown or prices excluding delivery may also be shown, provided the total price remains clear and prominent.
•    Make optional delivery charges clear throughout. Tell customers clearly that these charges apply. If the amount cannot reasonably be calculated in advance, explain that an additional charge may be payable. Do not hide this information behind links, separate pages, pop-outs, expandable sections or drop-down menus.
•    Check marketplace and comparison listings. Online marketplaces, comparison sites and search engines must also show complete pricing information. Where individually purchasable products each have their own mandatory delivery charge, include that charge in each product’s total price.
•    Read the CMA guidance and correct any gaps now. Review pricing against the DMCC Act and the CMA’s Price transparency guidance (CMA209), particularly Chapter 4 and paragraphs 5.2–5.21 on delivery fees. Make the changes needed to remove incomplete prices, missing basket charges and late disclosure of delivery fees.

Example:
If you sell caravans through your website or another online platform the advert must state the total price in the headline followed by the price inclusive of VAT, and any mandatory delivery charges:

In the basket and at checkout
NCC 2027 Special Edition Caravan - £30,500
Caravan £30,000
Standard Delivery £500  
Total price: VAT@ 20% included = £30,500 

Where delivery is unavoidable and the charge is known, show the delivery-inclusive total as the main price, rather than adding delivery at checkout. The CMA says unavoidable charges should normally be included in the upfront total; showing them separately is not normally enough. [gov.uk]

Another example: 
A kettle costs £30 including VAT, standard delivery costs £4.99, and there is no free collection option or other charge.
On the advert, search listing and product page:
Electric kettle
£34.99 including standard delivery
Item £30.00 · Delivery £4.99 · VAT included
[Add to basket]
Make £34.99 the clear, prominent price. The breakdown explains the total—it does not replace it.

In the basket and at checkout:

The customer sees the same complete total throughout, with no unavoidable charge appearing later. This follows the CMA’s principle that pricing must be clear, complete and accurate from the outset. [gov.uk]

What to avoid

Electric kettle — £30
Delivery calculated at checkout

Under these assumptions, that hides a known, unavoidable £4.99 charge until later—the type of “drip pricing” the guidance addresses. [gov.uk]

This is an illustrative layout, not a guarantee of legal compliance. A retailer offering free collection, location-dependent delivery or a single delivery charge across several items needs to reflect those arrangements accurately in its pricing.