"No Refunds" Is Not a Policy. In Ireland, It Is an Offence.

At the end of July the Competition and Consumer Protection Commission published its latest round of enforcement actions: 31 notices issued to 18 traders, most of them for failing to display prices properly ^[1]. Four of those notices went somewhere quieter, to online sellers who had told customers the wrong thing about their rights.

Those four are the ones worth your attention. Nobody walked into a shop to catch them. Somebody read a website.

Your returns page is not house copy. It is regulated text, and there is a section of Irish law that names the exact sentences it will not accept.

The section nobody reads until a notice arrives

Section 7 of the Consumer Rights Act 2022 makes it an offence for a trader to display a notice, publish an advertisement, supply goods bearing, or otherwise furnish a document containing a representation that a consumer's statutory rights are restricted or excluded ^[2].

Then it does something unusually helpful for Irish legislation. It lists what it means:

• a representation that reimbursement will not be made for goods that are not in conformity with the contract
• a representation that reimbursement will be made only in the form of credit notes or gift vouchers
• a representation that non-conforming goods will not be replaced, repaired or otherwise brought into conformity

In shop English: no refunds, credit note only, and talk to the manufacturer.

Why this reaches your website, not just your shop window

The definition of "representation" in subsection (4) is where this lands on your site. It covers "any oral, written, visual, descriptive or other representation by a trader, including any commercial communication, marketing or advertising", plus any notice or document a trader relies on in connection with a consumer contract.

A returns page qualifies. So does the small print under your basket, the third answer in your FAQ, and the automatic reply your shop sends when somebody emails about a fault. Website copy carrying legal weight is not unique to returns, and the same question arises when the price shown on your website is wrong.

That distinction matters commercially, not just legally. A laminated sign beside a till is seen by whoever walks in that day. One sentence on your website is seen by every customer who ever considers buying from you, and it sits there, word for word, until somebody edits it.

What it costs when somebody notices

The penalties sit in section 142 ^[3]. On summary conviction, a class A fine, capped at €5,000 under the Fines Act 2010, or up to twelve months. Conviction on indictment raises the ceiling to €60,000. A CCPC fixed payment notice is a set fine of €300, and a compliance notice is a written legal direction to stop, which you ignore at the risk of prosecution ^[1].

The fine is rarely the expensive part. Every notice the CCPC issues is published with the company name, the trading name and the county, and that page does not come down. Search your own business name in eighteen months and see what the third result is.

What your customer is actually owed

Before rewriting anything, it helps to know exactly what you are conceding, because it is narrower than the folklore suggests.

Where goods are faulty, misdescribed or not fit for purpose, the Act gives the buyer a defined ladder of remedies ^[4]:

• a short-term right to terminate the contract and get their money back, which section 24 sets at 30 days from delivery
• repair or replacement, free of charge and without significant inconvenience
• a price reduction or a refund, where repair and replacement fail, are impossible, or would cost the trader disproportionately

Section 22 adds the part traders find hardest to swallow. For the first twelve months, a fault that appears is presumed to have existed at delivery unless you prove otherwise. The burden is yours. After twelve months it flips back to the customer, and the outer window can stretch to around six years under the Statute of Limitations, though how far a claim actually gets depends heavily on the product and what it ought reasonably to last.

Notice what is absent from all of that. A change of mind. Somebody who buys a jumper in your shop, gets home and decides the colour is wrong has no statutory right to anything at all, and if you choose to offer something as goodwill, that is your commercial call with your own conditions attached. What you cannot do is present the goodwill limit as the legal one.

The fourteen days that only exist online, and the twelve months you inherit by staying quiet

Selling through a website adds a second right that has nothing to do with faults. Under section 113, a consumer buying at a distance can cancel for any reason at all within 14 days of receiving the goods.

Section 114 is the one that should send you to your own site this week ^[5]. If you fail to give the customer the cancellation information the Act requires, that 14-day window does not simply run out. It extends by twelve months.

Think about what that means on an ordinary trading week. An order placed in March, dispatched, delivered, invoiced and long forgotten. The following February an email arrives asking to cancel it, and if your site never explained the right to cancel, the customer is within theirs. You cannot argue the timing, because the timing is your own omission. Supply the information late and the clock restarts at 14 days from the day they receive it.

What has to be on the page

The cure is small. A customer needs to be told, in one findable place:

• that a 14-day right to cancel exists, and the day it starts running
• how to exercise it
• who pays return postage
• where to find the model cancellation form

Most shops already have three of those four somewhere on the site. Very few have all four in one place a customer can find without hunting. The same pre-contract disclosure logic governs what your site has to show about postage before an order is placed, so the two usually want fixing in the same sitting.

Four lines to take off your site this week

"No refunds. All sales final."

Named almost verbatim by section 7(3)(a). It does not become lawful just because you only ever meant it to apply to change-of-mind returns, because a customer reading it has no way of knowing that. If the sentence would stop somebody with a genuinely faulty product from asking, it is doing the thing the section prohibits.

"Exchange or credit note only."

Section 7(3)(b) names this one on its own. Consider a common enough situation: a kitchenware shop in Meath sells a blender that dies in week three. The counter has always handled that with a credit note, and when the shop's website went up, the counter policy went onto the returns page word for word. Nobody drafted anything. A habit got typed up, and the habit is an offence.

"No returns on sale items."

Reduced prices do not reduce statutory rights. You may exclude a specific known fault from remedy where you clearly communicated that fault before purchase, which is exactly what "seconds" and "ex-display, scratched door" tags are for. A blanket disclaimer over the whole sale rail is not that.

"Returns within 7 days, with receipt only."

Two problems in seven words. The statutory window for faulty goods is 30 days rather than 7, and proof of purchase does not have to be the original till receipt: a bank statement or card record will do. Set whatever house rule you like for goodwill returns, but do not dress it up as the legal position.

Line on your site	Why it is a problem	Write this instead
No refunds, all sales final	Named by section 7(3)(a)	"Faulty or misdescribed items: full refund within 30 days of delivery."
Exchange or credit note only	Named by section 7(3)(b)	"Refunds go back to your original payment method."
No returns on sale items	Statutory rights survive a discount	"Sale items carry the same rights, apart from any fault we flagged at purchase."
Returns within 7 days, receipt only	Understates the window and the proof	"30 days from delivery. Any proof of purchase is fine."

For a long time I treated policy pages as the last item on a launch checklist, something to paste in on the morning a site went live. That order was wrong. The pages nobody admires are the ones a regulator reads first.

What you are still allowed to say

Plenty, as it turns out.

The 14-day online cancellation right comes with a defined list of exclusions. It does not apply to:

• goods made to the consumer's specification, or clearly personalised
• anything liable to deteriorate or expire rapidly
• sealed items unsuitable for return on health or hygiene grounds, once unsealed
• audio, video or software supplied sealed, once unsealed
• newspapers, periodicals and magazines

You can also require goods back in resaleable condition, charge for return postage where you said so in advance, and decline a change-of-mind return in a physical shop.

One honest limitation, because a rewritten page is not a force field. It will not stop a customer arguing, and it will not make a genuinely awkward dispute pleasant. What it does is move the argument onto ground where you know the answer and can point at it, which is worth a great deal with a queue building behind the person at the counter, and worth nothing at all if the page contradicts you. Note too that "custom made" does less work than owners assume: it means made to that customer's specification, not simply ordered in for them.

There is a genuine exception to this whole article. If you shift a handful of items a month and never want to own a policy page at all, selling through a large third-party marketplace is the honest answer. The marketplace writes the returns terms, runs the refund, and carries most of the compliance weight. You pay for that in commission on every sale and you never learn who your customers are, but for a side business run around a full-time job, that trade is defensible.

Audit your returns page in four steps

1. Audit. Read every place on your site where a refund is mentioned: the returns page, the checkout small print, the FAQ, and any automated email your shop sends. Most sites carry three copies of the policy and only one of them is current.
2. Rewrite. Replace anything matching the four lines above with the plain version from the table. State what you must, then state what you offer on top as goodwill, clearly marked as goodwill.
3. Verify. Confirm the cancellation information is present for online orders, all four parts of it. A missing right is the expensive omission, not clumsy wording.
4. Deploy. Push the change and read it on a phone, because that is where most people will meet it.

Step four should take four minutes and cost nothing. On plenty of setups it does not, and if editing one paragraph means logging a support ticket and waiting on somebody's hourly rate, the page stays wrong for months. That is exactly how a habit from behind a counter ends up on a public regulator's list. Full WordPress access is the difference, and it is part of what you get with everything included for €60 a year and no hourly change fees. Which policy pages a trading site needs in the first place is covered in our guide to the legal pages an Irish business website should carry.

Conclusion

Roughly two in five enterprises in Ireland were selling online by 2025, and among small firms it was closer to one in three, according to the CSO's information society figures published in February ^[6]. A good share of those shops moved their counter habits onto a webpage without anyone stopping to ask whether the habits were lawful to begin with. That is not carelessness. It is what happens when the words on a website get treated as decoration rather than as terms.

The useful thing about section 7 is how specific it is. You are not asked to guess. It names three statements, and if none of them appear anywhere on your site, you have dealt with the part of Irish consumer law most likely to produce a letter with a harp on it. An afternoon, once.

Frequently Asked Questions

Is a "no refunds" sign or website line legal in Ireland?

No. Section 7 of the Consumer Rights Act 2022 makes it an offence for a trader to display a notice, publish an advertisement or furnish a document representing that a consumer's statutory rights are restricted. A representation that reimbursement will not be made for goods that are not in conformity with the contract is named specifically. The definition of representation covers commercial communications and advertising, so a website counts alongside a physical sign.

Do I have to refund a customer who simply changed their mind?

In a physical shop, no. Irish consumer law gives no right to a refund, exchange or credit note for a change of mind, so anything you offer there is goodwill and you can set your own conditions. Online is different. A distance buyer has 14 days from receiving the goods to cancel for any reason, subject to a defined list of exclusions such as personalised items and sealed hygiene goods.

Can I offer a credit note instead of a refund?

For goodwill returns, yes. For goods that are faulty, misdescribed or not fit for purpose, no. Section 7(3)(b) of the Consumer Rights Act 2022 specifically names a representation that reimbursement will be made only in the form of credit notes or gift vouchers as a prohibited statement.

How long does a customer have to return faulty goods in Ireland?

Section 24 of the Consumer Rights Act 2022 gives a short-term right to terminate the contract and obtain a refund within 30 days of delivery. After that the remedies are repair, replacement, price reduction or refund, and for the first twelve months the trader carries the burden of proving the fault was not present at delivery. The outer window runs considerably longer, although what a customer can realistically recover depends on the product and what it ought reasonably to last.

What happens if my website does not mention the 14-day cancellation right?

Under section 114 of the Consumer Rights Act 2022, the cancellation period extends by twelve months. If you supply the information later, the period instead ends 14 days after the customer receives it. In practice, silence turns a two-week exposure into a year-long one.

Do these rules apply if I only sell to other businesses?

The Consumer Rights Act 2022 governs contracts between traders and consumers, so genuine business-to-business sales sit outside it. Be careful before relying on that. If any part of your site sells to the public, or a buyer could reasonably be an individual purchasing outside their trade, the consumer rules apply to those sales and your published wording has to reflect it.

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