Delivery Charges on Your Website: What Irish Law Says You Must Show

Section 106(10) of the Consumer Rights Act 2022 contains one sentence that most people selling online in Ireland have never read. If you did not give the customer the delivery charge before they were bound by the contract, the customer is not liable for it.

Not "you should have disclosed it", and not "you may receive a complaint". They do not have to pay it.

That clause reframes an argument that usually gets treated as a design preference. Where postage sits on a website is normally filed under conversion tactics, somewhere near button colours. It is a legal requirement with a defined consequence, and the consequence lands on the seller. This article sets out what the law asks for, what it costs you when the charge appears late, and how the four common ways of pricing delivery actually behave once real orders start arriving.

What the law asks for before the order

The governing provision for anything sold through a website is section 106 of the Consumer Rights Act 2022, which deals with distance contracts. Subsection (1) requires the trader, before the consumer is bound by the contract or any corresponding offer, to give or make available the information listed in Schedule 3 to the Act, in plain and intelligible language.

Two clauses of that schedule matter here.

Clause (f) is the total price of the goods inclusive of taxes, or the manner in which the price will be calculated where it cannot reasonably be worked out in advance. The one people miss is clause (g): "all freight, delivery or postal charges and any other costs additional to the price referred to in clause (f) or, where those charges cannot reasonably be calculated in advance, the fact that such additional charges may be payable."

Read that fallback carefully. The law does allow for parcels you cannot price in advance. What it does not allow is silence.

There is a second duty aimed squarely at websites. Section 106(8) says that where a distance contract is concluded through a trading website, the trader must ensure the site indicates clearly and legibly whether any delivery restrictions apply and which means of payment are accepted, and that this information appears at or before the beginning of the ordering process.

The beginning. Not the review step. A customer who has picked a size, chosen a quantity and pressed add to basket has begun ordering. Anything you reveal after that point is late by the statute's own definition. The same pre-contract information logic sits underneath the separate question of whether a wrongly displayed price has to be honoured, which trips up a similar number of shops for a similar reason.

The clause that changes the maths

Then comes section 106(10): "If the trader has not complied with subsection (1) in respect of clauses (g) and (n) of Schedule 3, the consumer is not liable for the charges or costs specified in those clauses."

Clause (g), as above, is delivery. And clause (n) is the cost of returning goods after a cancellation. So the exposure runs both ways. Hide the postage and you cannot collect it. Stay quiet about who pays return postage and you have just volunteered to pay it yourself on every cancelled order for the life of that page.

Contravening subsection (1) or subsection (8) is also an offence under section 106(11), and section 142 sets the penalties: a class A fine on summary conviction, or up to €60,000 and eighteen months on indictment.

I would not build the business case on the fine. Prosecutions of a small shop over a postage line are not what keeps me busy. The everyday cost is duller and far more likely. A customer disputes the charge, quotes the section back at you or simply raises a chargeback, and you refund the delivery because your own website cannot evidence that you disclosed it. Multiply that by a year of orders on a page nobody has revisited since launch.

Where the money goes when the charge arrives late

The legal risk is real but slow. Commercial loss is immediate, and it is larger.

Baymard Institute maintains a rolling average of documented cart abandonment across 50 separate studies, last updated in September 2025, which lands a little over 70%. Individual studies in that set range from the mid-50s to the mid-80s depending on the year and the sector, so treat the headline as a weather forecast rather than a measurement of your own shop.

What matters more is the reason breakdown. Setting aside the large group who were only browsing, roughly four in ten of the people who genuinely intended to buy said extra costs, meaning shipping, tax and fees, were what stopped them. Delivery being too slow came second, at about one in five. Baymard's sample is heavily American, so read it as direction of travel rather than an Irish benchmark.

Here is the part that should worry a shop owner. Those people had already chosen. They had a basket, a size and an intention. The cost of a late delivery charge is not paid in lost traffic, it is paid at the very end of the funnel, on visitors you already spent money and effort attracting.

Complaint volumes point the same way. The Competition and Consumer Protection Commission's helpline handled 42,791 consumer contacts in 2025, and contacts about online purchases rose by around 14% on the previous year. Faulty goods and services remained the largest single category for the fifth year running.

A confession, since it is relevant. I once told a retailer their delivery information was fine because they had a proper delivery page with a clear table on it. Technically true. It was also three clicks from any product and linked only from the footer, and their checkout drop-off said so plainly once we actually looked. Being able to point at the information is not the same as the customer having seen it. I do not give that answer any more.

Four ways to price delivery

Every shop lands on one of these four models, usually by accident. They are not equally good, and the differences show up in average order value rather than in conversion alone.

Model	What the customer sees	Where it goes wrong
Flat rate nationwide	One figure, on the product page	Subsidises heavy orders, overcharges light ones
Calculated by weight or basket	Nothing until an address is entered	Legally the weakest, commercially the costliest
Free above a threshold	A target to reach	Threshold set too high reads as a penalty
Priced into the product	No separate charge at all	Makes you look dear against listed competitors

Flat rate nationwide

One number, everywhere, printed on the product page. This satisfies clause (g) without argument, because the charge is known and stated before anything is added to a basket. It is also the easiest of the four to operate, since nobody has to maintain a weight matrix.

The cost is margin blending. Light orders subsidise heavy ones, and if your catalogue spans a candle and a case of jars, one of those two transactions is losing money. For most shops with a reasonably consistent parcel size, that trade is worth making, because the operational simplicity is worth more than the few euro of leakage.

Calculated by weight or basket value

Technically the most accurate, and commercially the worst of the four. The customer cannot see the figure until they have handed over an address, which means the number arrives at precisely the moment Baymard's data says people leave.

It is also the model most likely to breach section 106. Where the charge is only computed at step three of a five step checkout, and nothing earlier on the site indicated what the range might be, you are relying on the "cannot reasonably be calculated in advance" fallback for parcels you plainly could have banded. Live carrier rates are fine, but publish an indicative range on the product page alongside them. A line reading "delivery from €5.50, typically €5.50 to €9 within Ireland" discharges the duty and removes the surprise, and it costs you one field in the product template.

Free above a threshold

The strongest performer when the threshold is set honestly. Pick a number modestly above your current average order value, not double it, and it reads as an achievable goal rather than a toll. Set it at three times what people usually spend and it stops being an incentive and starts being a reminder that delivery is expensive here.

The one thing to verify is that the threshold is visible on the product page and in the basket, not just on a promotional banner that some visitors never see. A customer who reaches checkout and discovers they were €4 short of free delivery does not usually go back and add an item. They close the tab and the basket sits there.

Priced into the product

Delivery folded into the unit price, nothing added at checkout. Clean, compliant by default, and the model marketplaces have trained shoppers to expect. It works well for higher-margin goods where a few euro disappears into the price without anyone noticing.

It fails when a customer is comparing you against a listed competitor on price alone, because your number looks higher until they get to the end of both checkouts and most never do. For anything sold in a directly comparable form, this model quietly costs you the click.

Whichever model you land on, the operational requirement is the same: your shop, your product template and your basket all need to display the same figure, which is a content and hosting question as much as a pricing one. Running a WooCommerce shop on an Irish hosting plan that includes the SSL, the nightly backups and the caching for €60 a year removes the usual excuse for leaving the product template alone, because you are not paying a developer by the hour to change a line of copy.

Delivery restrictions and the addresses you quietly do not serve

Section 106(8) also requires delivery restrictions to be flagged at or before the start of the ordering process. This is the duty most often missed, because restrictions tend to be informal. A courier surcharge you absorb for some routes and refuse for others. Maybe a rule about not posting glass, or a quiet policy of not shipping outside the island.

None of those are unlawful. Neither Irish consumer law nor the EU Geo-blocking Regulation obliges anyone to deliver everywhere. What the Regulation prohibits, as the CCPC's guidance for business sets out, is refusing a customer access to goods on grounds of nationality or place of residence while serving comparable customers. A buyer in another member state is entitled to order and collect at your premises, or have the parcel sent to an address or pick-up point you already serve. The obligation is equal treatment, not universal shipping.

Consider a beekeeper in Offaly selling honey and beeswax wraps, a scenario that recurs constantly among small food producers. Glass jars in multiples are heavy and fragile, so the sensible answer is a weight band, a packaging surcharge and an honest note that some routes take longer. The unhelpful answer is silence at the product stage followed by a courier quote at checkout, which loses the order, and, if it was never disclosed, cannot be charged either. Offering local collection alongside delivery covers the customers a restriction would otherwise turn away.

The thirty day rule, and who carries the parcel

Two further duties sit alongside the disclosure rules and cost people money more often than they should.

Section 36(2) of the same Act: unless you and the customer have agreed otherwise, you must deliver without undue delay and in any event not later than 30 days after the contract is concluded. Miss it and the customer can set a further reasonable period, and if you miss that too they can cancel and recover everything they paid, delivery charge included. A dispatch estimate on the product page is not decoration, it is how you agree something other than the default.

Risk in transit is the other one. As Citizens Information summarises the position, where you offered and arranged the carrier, the goods are your responsibility until they reach the customer. A parcel that a courier loses is your loss to resolve, not the customer's. That shifts only where the customer arranged their own delivery, nominated someone else to take receipt, or used a proxy address service such as An Post's AddressPal, at which point your liability ends when the goods pass to that third party.

What you genuinely cannot promise

There is a real limitation in all of this, and pretending otherwise would be dishonest.

For some goods, an exact delivery figure before checkout is not achievable. Multi-parcel consignments, anything shipped on a pallet, bulky furniture, orders where the carrier prices by dimension rather than weight. The statute anticipates this and permits you to state that additional charges may be payable. Take the concession where you need it.

Just do not mistake it for a commercial answer. "Delivery charges may apply" is a legal minimum and a conversion disaster, because an unquantified cost reads to a buyer as an unlimited one. If you cannot give a figure, give a band and the basis, something like "delivery quoted after order, typically €25 to €45 depending on the county". That is defensible under clause (g) and it lets a customer decide.

One eye on what is coming, with an honest caveat. A Digital Fairness Act sits on the European Commission's 2026 work programme, aimed at dark patterns in consumer-facing design, with an indicative date late in 2026 on the Parliament's legislative train. What it will finally say about price presentation is still being negotiated and there is no text to comply with yet, so treat it as the direction of travel and nothing more.

Where a closed platform genuinely does this better

Being fair about it: if your entire catalogue is one product at one weight going to one country, Squarespace's built-in shipping settings will have you compliant in about four minutes with no plugin, no weight table and nothing to maintain. That is a genuine advantage over configuring shipping zones in WooCommerce, and if that describes your shop it is the honest recommendation.

It stops describing most shops the moment you add a second product with a different weight, or a wholesale tier, or a delivery band for one region. The point at which shipping rules become interesting is the point at which a closed platform stops being simpler and starts being a ceiling.

Auditing your own checkout in four steps

Open. Go to your own website as a customer would, from a phone, and add the single heaviest thing you sell to the basket without touching the admin.

Verify. Write down the first screen on which a delivery figure, a range, or the words "additional charges may be payable" appear. If that screen is after the basket, you have found the problem and its location.

Publish. Put the figure or the band into the product template itself, so it renders on every product rather than on a delivery page nobody visits, and state who pays return postage in the same block.

Test. Run one order through as a real customer to production, including a cancellation, and confirm the number the customer sees at the start is the number they are charged at the end.

Conclusion

Postage has always been treated as the boring end of an online shop, the bit configured once during the build and never opened again. The Consumer Rights Act 2022 puts a sharper frame around it. A charge you did not disclose is a charge you cannot collect, and the return cost you stayed quiet about is one you have agreed to absorb.

The commercial case arrives well before any of that. Anyone who leaves because a cost appeared late had already decided to buy, which makes them the most expensive visitor on the site to lose.

Open your own product page on your phone this week and see how far you get before a number appears. Whatever you find, it is a template edit, not a rebuild.

Frequently Asked Questions

Do I legally have to show delivery charges on my website in Ireland?

Yes. Section 106(1) of the Consumer Rights Act 2022 requires a trader to give the consumer the information in Schedule 3 before the consumer is bound by a distance contract. Clause (g) of that schedule covers all freight, delivery or postal charges additional to the price. Where those charges genuinely cannot be calculated in advance, you must at least state that additional charges may be payable.

What happens if I do not disclose the delivery charge until checkout?

Section 106(10) states that if the trader has not complied with subsection (1) in respect of clauses (g) and (n) of Schedule 3, the consumer is not liable for the charges or costs specified in those clauses. In practice an undisclosed delivery charge, and an undisclosed return cost, are not recoverable from the customer.

When exactly does the ordering process begin?

Earlier than most shop owners assume. Section 106(8) requires a trading website to indicate clearly and legibly whether any delivery restrictions apply and which means of payment are accepted at or before the beginning of the ordering process. That points at the product and basket stage, not the final payment screen.

How long do I have to deliver an online order in Ireland?

Under section 36(2), unless you and the customer have agreed otherwise, you must deliver without undue delay and in any event not later than 30 days after the sales contract is concluded. If you miss it, the customer can set a further reasonable period and then cancel for a full refund.

Do I have to deliver to every county and every address?

No. Neither Irish consumer law nor the EU Geo-blocking Regulation obliges a trader to deliver everywhere. What you cannot do is refuse someone because of their nationality or place of residence while serving comparable customers. If you restrict where you ship, say so clearly at or before the start of the ordering process, and offer collection or delivery to an address you already serve.

Who is responsible if a parcel is lost or damaged in transit?

The seller, in most cases. Where you offered and arranged the carrier, you carry the risk until the goods reach the consumer. That changes if the customer arranged their own courier, nominated someone else to take receipt, or used a proxy address service, in which case your liability ends when the goods pass to that third party.

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