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Frequently asked questions
UK Fake Reviews and Hidden Fees Ban
Unpaid Invoice Recovery
Product Liability CPA1987
A business may face investigation by the Competition and Markets Authority, enforcement action, financial penalties, directions to change its practices, refund obligations and reputational damage. The practical risk is not limited to the fine. A business may also lose customer trust, receive complaints and face disputed invoices. Businesses selling products should also review wider consumer law risk, including product safety and liability. See our guide: What Is Product Liability in the Consumer Protection Act 1987?.
In most cases, the business itself will be the first target. However, directors should not ignore the risk. If misleading marketing, fake reviews or hidden fees are part of the company’s sales model, directors may face difficult questions about governance, compliance and consumer protection. A review of the business should include advertising, website claims, review systems, terms and product information. Product sellers should also check whether product descriptions and safety information are accurate: What Is Product Liability in the Consumer Protection Act 1987?.
Yes, potentially. If fake reviews make a product appear safer, more reliable or more suitable than it really is, they may strengthen the customer’s argument that they were misled. In a product dispute, reviews, descriptions, photographs, ratings and claims about performance may all become evidence. Businesses selling goods should make sure reviews do not create a false impression about product quality or safety. Read more here: What Is Product Liability in the Consumer Protection Act 1987?.
Start with the customer journey. Look at the advert, landing page, product page, reviews, quote, checkout, terms, invoice and after-sales emails. Ask whether the customer sees the real price, the real service scope and any important limits before committing. For product sellers, also check whether product claims, warnings and instructions are accurate. Product liability risk often begins with poor product information: What Is Product Liability in the Consumer Protection Act 1987?.
Businesses should remove misleading review wording, explain how reviews are collected, include mandatory fees upfront, avoid unclear “from £” pricing, and make key limits clear before the customer buys. Product pages should also be checked for exaggerated claims, missing warnings and unclear specifications. A legally safer website is not only about terms and conditions. It is about whether the whole page gives an accurate impression. For product risk, see: What Is Product Liability in the Consumer Protection Act 1987?.
A business should have a clear review policy explaining whether reviews are verified, whether incentives are offered, how fake reviews are reported, and how suspicious reviews are handled. Staff should not write reviews pretending to be customers. Friends, relatives or connected parties should not be used to create a false impression. Where reviews concern products, the review process should not exaggerate safety, durability or performance. Product sellers should also understand their wider liability risk: What Is Product Liability in the Consumer Protection Act 1987?.
Mandatory fees should be shown clearly and early. If a fee is unavoidable, it should not appear for the first time at checkout or invoice stage. Businesses should also check quotes, order forms, sales emails and payment pages. The customer should understand what is included, what is excluded and when extra charges apply. For product sellers, pricing clarity should sit alongside accurate product descriptions and safety information: What Is Product Liability in the Consumer Protection Act 1987?.
Yes. If a customer says a fee was not explained before they agreed to buy, they may refuse to pay that part of the invoice. The dispute may then become about the whole sales process: the advert, the quote, the website, the contract and the invoice. This is why hidden fees are both a consumer law issue and a cash-flow issue. Product businesses should also ensure product claims and pricing are consistent: What Is Product Liability in the Consumer Protection Act 1987?.
Yes, but only carefully. A “from £” price should be genuine and not misleading. The customer should be told what the starting price includes, what it excludes, and when the price may increase. If almost nobody can actually buy at the “from” price, the wording may create risk. For product sellers, the same principle applies to claims about quality, performance or suitability. Product information must not create a false impression: What Is Product Liability in the Consumer Protection Act 1987?.
Yes. Testimonials can create risk if they are false, selective, exaggerated or presented without context. A testimonial should reflect a real customer experience and should not promise results the business cannot reasonably support. Where products are involved, testimonials should not suggest that a product is safer, stronger or more effective than it really is. Product sellers should treat testimonials as part of the wider product information trail: What Is Product Liability in the Consumer Protection Act 1987?.
A business should keep records of quotes, website versions, customer approvals, review requests, complaint handling, fee disclosures and changes to terms. If there is a dispute, evidence matters. The business should be able to show what the customer saw, what they agreed to, and when they were told about important charges or limits. Product sellers should also keep product specifications, supplier documents, safety warnings and instructions. Product liability evidence is explained here: What Is Product Liability in the Consumer Protection Act 1987?.
The answer depends on the facts. If the business knows or suspects that reviews are fake, it should not ignore them. It should report suspicious reviews, avoid using them in marketing and keep a record of the steps taken. A business should not benefit from reviews it knows are misleading. For product sellers, this is especially important where reviews make claims about safety, performance or suitability. Wider product risk is covered here: What Is Product Liability in the Consumer Protection Act 1987?.
Yes. Fake negative reviews can damage reputation and may amount to unlawful conduct depending on the facts. However, businesses must respond carefully. A genuine negative review should not simply be labelled fake because the business disagrees with it. The best approach is to keep evidence, use the platform reporting process and respond professionally. Where a review complains about a defective product, the business should also check whether there is a real product safety or product liability issue: What Is Product Liability in the Consumer Protection Act 1987?.
Businesses should review their terms and conditions, pricing policy, cancellation policy, refund policy, review policy, complaints procedure, website wording and staff sales scripts. Product sellers should also review product descriptions, specifications, warnings, instructions and supplier documentation. The aim is to make sure the customer receives clear and accurate information before buying. If products are involved, the legal risk may go beyond reviews and hidden fees: What Is Product Liability in the Consumer Protection Act 1987?.
A business should get advice before launching a new website, changing its pricing model, using review campaigns, selling regulated or higher-risk products, or responding to a serious customer complaint. Legal advice is also sensible if invoices are being disputed because customers say fees were hidden or promises were unclear. We can provide free initial advice on your pricing, review process, terms and product risk. For product sellers, start here: What Is Product Liability in the Consumer Protection Act 1987?.
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