Small online retailers should check how they show delivery costs before the Christmas shopping rush, following a fresh warning from the Competition and Markets Authority. Its 2 November letter focuses on the prices customers see while browsing, comparing products and building a basket.
This is a reminder about existing requirements, rather than a new Christmas-only rule. For an independent shop, the useful next step is a focused test of delivery settings across the whole customer journey.
What the CMA has highlighted
The regulator says an unavoidable delivery charge belongs in the total price wherever that price is shown, when it can reasonably be calculated. That includes advertising and product pages as well as baskets and payment screens. A flat charge per order does not remove the need to show an inclusive total.
The letter also addresses optional delivery services. Customers must be told clearly about applicable charges throughout the process; that information should not depend on opening a hidden menu or separate page. The CMA says it will keep monitoring online retail and may take enforcement action where non-compliance continues.
Separate the delivery choices first
Before asking a developer to change a theme, list the ways someone can receive an order. Is standard delivery compulsory? Is there a genuinely free collection option? Does an express service cost extra? Which postcodes change the available choices?
The CMA’s detailed price-transparency guidance distinguishes mandatory charges from optional upgrades. Where the total cannot reasonably be worked out in advance, customers need equally prominent information enabling them to calculate it. Once the charge can reasonably be calculated, it belongs in the total. Variable charges need careful attention; a generic statement that delivery costs extra is not a substitute for checking the relevant guidance.
For example, test a single product and then add another to the basket. If delivery is charged once per order, make sure the display does not accidentally suggest it is charged separately for every item. The CMA letter notes that retailers can show prices both with and without delivery, while still meeting the requirement to provide the inclusive total.
A practical review for a small shop
Start with a customer’s first encounter with an offer. Open a product advert, a search listing and a link from your newsletter. Record the price each one presents, then compare it with the product page. Treat this as a practical audit, keeping screenshots and notes rather than relying on memory.
Next, build a test basket on a phone and a computer. Try the delivery choices your shop actually offers, including any free-delivery threshold. Look for a total that changes unexpectedly, a delivery message pushed below the main price, or an explanation that becomes difficult to find on a smaller screen.
Check marketplace listings separately from your own website. Ask the platform or agency which settings control the displayed price and delivery information. Give whoever maintains the shop a concrete example of the problem: the product, delivery destination, screen and price shown. That makes a repair easier to specify and verify.
After any change, repeat the same journey. Keep the before-and-after evidence and note who approved the release. A corrected checkout should also be compared with any adverts or product feeds that still display the earlier offer.
Keep the review focused on this warning
BritishSME’s earlier coverage of the CMA’s hidden-fee enforcement case explains the wider pricing issue. This week’s letter adds a specific reason for goods retailers to examine delivery, including flat basket charges and the visibility of optional services.
Set aside time before seasonal promotions go live, identify the pages needing attention and assign each fix to a named person. Use the CMA guidance for the charging model you operate, and seek advice where the treatment remains unclear. The aim is a buying journey whose price information stays understandable from the first offer through to payment.
