Alex is Sprintlaw's co-founder and principal lawyer. Alex previously worked at a top-tier firm as a lawyer specialising in technology and media contracts, and founded a digital agency which he sold in 2015.
If you run a small business, returns can be one of those “hidden” costs that quietly eat into your margins.
Between outbound shipping, return postage, packaging that can’t be reused, staff time, payment processing fees, and stock that comes back unsellable, it’s completely understandable to ask: can we start charging for returns?
The good news is that charging customers for returns can be lawful in the UK in many situations - but only if you do it the right way. Consumer law is specific about what you must refund, when you can deduct amounts, and what you must tell customers upfront. If your terms aren’t clear (or aren’t compliant), return charges can quickly turn into disputes, chargebacks, negative reviews, or even regulatory action.
Below, we break down what UK businesses can legally do, where the “red lines” are, and how to put a compliant approach in place from day one.
Can You Charge For Returns In The UK?
In many cases, yes - charging for returns is allowed in the UK, especially where a customer is returning an item because they’ve simply changed their mind.
But the legal position depends heavily on:
- How the sale was made (online/distance vs in-store)
- Why the item is being returned (change of mind vs faulty/incorrect)
- What you told the customer before they bought (your pre-contract information and terms)
- What you’re trying to charge (return postage, restocking fees, original delivery charges, deductions for diminished value, etc.)
From a legal perspective, the big framework to keep in mind is:
- Consumer Rights Act 2015 (mainly around faulty goods and remedies)
- Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013 (“distance selling” rules, including the 14-day change-of-mind right for many online sales)
- Consumer Protection from Unfair Trading Regulations 2008 (misleading actions/omissions - including unclear or hidden return charges)
So a policy like “we’ll charge £5 per return” might be fine in principle, but only if you apply it in the right scenarios and communicate it properly.
Return Charges Vs Refund Deductions: What’s The Difference?
Small businesses often mix these up, and it matters.
- Return charges usually mean you require the customer to pay the cost of sending the goods back (or you deduct the return shipping label cost from their refund).
- Refund deductions usually mean you reduce the refund amount for another reason - for example, a deduction because the customer handled the goods more than necessary and reduced their value.
Both can be lawful in limited circumstances - but both can also be unlawful if you treat them as a blanket rule.
When You Must Not Charge For Returns (And When You Must Refund Delivery)
There are clear situations where charging the customer for the return (or reducing their refund) is either not allowed or is highly risky.
If The Goods Are Faulty, Not As Described, Or Not Fit For Purpose
If an item is faulty, doesn’t match the description, or isn’t fit for purpose, your customer’s rights are largely driven by the Consumer Rights Act 2015. In those cases, you generally can’t “pass the problem back” to the customer by making them pay return costs as a default.
Practically, you should expect to cover (or reimburse) reasonable return costs for genuinely faulty/incorrect goods - and you should not apply “restocking fees” where the customer is using their legal remedies for a fault.
This is also where your internal process matters: you’ll want a consistent system for assessing faults, offering repair/replacement/refund where appropriate, and documenting outcomes. (If you need a refresher on the legal framework here, faulty goods rules are a good place to start.)
If You Sent The Wrong Item Or The Order Was Incomplete
If the return is happening because your business made an error (wrong size/colour sent, missing items, incorrect quantity), it’s best practice - and often the legally safer position - to cover the cost of putting things right.
Even if your policy says “customer pays return postage”, applying that in a scenario where you’re at fault can create an “unfair terms” risk and often escalates disputes.
If You Didn’t Clearly Tell Customers About Return Costs Upfront
For online/distance sales, you must provide certain information before the customer buys - including information about returns and who pays for them in a change-of-mind return.
If you don’t clearly tell customers that they must pay return postage (or that you’ll deduct a label cost), you may lose the ability to charge it in the way you intended.
This is where having a properly drafted website terms and conditions (and ensuring they’re presented to customers in the right way at checkout) makes a real difference.
Original Delivery Charges: Often Must Be Refunded (For Change-Of-Mind Cancellations)
When a customer cancels within the relevant “cooling-off” period for distance sales (where it applies), you usually have to refund:
- the price of the goods; and
- the cost of standard delivery (but not necessarily upgrades like express shipping).
Many businesses miss this and attempt to keep the original shipping as part of a “returns charge”. That’s a common trigger for complaints.
Because the rules can turn on the details (and the exceptions), it’s worth making sure your returns policy is aligned with the legislation and your actual operational process.
How The 14-Day Cooling-Off Period Affects Charging For Returns
For many online, phone, and mail order sales to consumers, customers have a legal right to change their mind and cancel within a set timeframe (commonly referred to as the “14-day cooling-off period”).
That doesn’t automatically mean “free returns”, but it does mean you need to be careful about what you charge and how you handle the refund.
What You Can Usually Do During A Change-Of-Mind Return
Where the customer is cancelling simply because they changed their mind (and the product isn’t faulty), you can often structure your approach so that:
- the customer pays return postage, as long as you informed them of this requirement before the contract was formed; and/or
- you supply a return label and deduct the cost from the refund, if your terms make that clear and it’s handled transparently.
In other words, charging for return postage (or deducting a label cost) can be compliant - but only when it’s clearly communicated and applied to the right category of return.
Common Exceptions Where The 14-Day Right Doesn’t Apply (Or Is Limited)
Not every product can be returned under the 14-day change-of-mind rules. Some common examples (with nuance in the details) include:
- custom-made or personalised goods
- sealed goods not suitable for return due to health protection or hygiene reasons, once unsealed
- perishable goods
- certain digital content after supply/performance has begun (where the customer agreed to this)
If your business sells items that fall into exceptions, your terms and checkout disclosures become even more important, because you’re relying on those legal exceptions to manage returns.
Many disputes happen not because a business is “wrong” on the law, but because the customer wasn’t properly informed upfront. If you want to rely on the cooling-off rules (and their exceptions), make sure you understand how the 14-day cancellation period works in practice.
What A Compliant Returns Charge Policy Looks Like (In Practice)
Once you’ve identified the situations where you can charge, the next step is making sure your policy is both legally compliant and operationally workable.
Here are the building blocks we typically recommend for small businesses that want to introduce return charges without creating unnecessary legal risk.
1) Clearly Separate “Change Of Mind” Returns From Faulty/Incorrect Returns
This is the single biggest “make or break” factor.
Your policy should clearly explain:
- Change-of-mind returns: what the timeframe is, what condition items must be in, and whether the customer pays return shipping
- Faulty or incorrect items: how customers report an issue, what evidence you may request (e.g. photos), and that you’ll put things right (including return costs where appropriate)
If you apply one blanket rule (“all returns cost £X”), you’re much more likely to run into Consumer Rights Act problems.
2) Decide What You’re Charging, And Describe It In Plain English
“Returns fee” can mean different things. Customers (and regulators) care about transparency.
Be specific. For example:
- “We don’t offer free returns for change-of-mind returns. You’re responsible for return postage.”
- “If you use our prepaid label for a change-of-mind return, we deduct £3.95 from your refund to cover the label cost.”
- “We do not charge restocking fees.” (or, if you do plan deductions, be very cautious - see below)
Avoid vague wording that looks like you’re trying to keep discretion to charge “whatever you want”. That can raise unfair terms concerns and tends to inflame disputes.
3) Be Careful With “Restocking Fees”
Restocking fees are a common idea, but they’re also a common complaint trigger.
If a customer is exercising a legal right to cancel an online purchase, a blanket “restocking fee” (or admin fee) is risky and can be difficult to justify. Under the Consumer Contracts Regulations, what businesses commonly rely on instead is a diminished value deduction where the customer has handled the goods more than necessary to establish their nature, characteristics and functioning (for example, wearing shoes outdoors, removing tags and using an item, etc.).
But even then, deductions should be:
- reasonable and proportionate
- based on actual loss in value (not punitive)
- explained in your policy (and you should have provided the required pre-contract information)
- supported by evidence where possible
If you’re considering a restocking fee approach, it’s worth getting legal advice on the structure and wording before you publish it.
4) Put The Terms Where Customers Will Actually See Them
It’s not enough to bury return charges in a footer link. The legal risk isn’t just what your terms say - it’s whether the customer was made aware of them before buying.
Common “good” placements include:
- checkout pages (ideally with a link and acceptance mechanism)
- order confirmation emails
- a dedicated returns page linked prominently in your website header/footer
- product pages (especially for items with return exclusions, like hygiene or personalised goods)
Getting your website terms and conditions right is a strong foundation, but also think about how you operationalise those terms on your site and in your customer comms.
5) Follow The Rules On Refund Timing
Even if you’re charging for returns appropriately, you still need to process refunds within the legally required timeframe once the cancellation/return is valid.
For change-of-mind cancellations under the Consumer Contracts Regulations, the refund deadline is generally 14 days from when you get the goods back or from when the customer supplies evidence they’ve sent the goods back (whichever happens first). You can usually withhold the refund until one of those events occurs.
Slow refunds are one of the fastest ways to turn a manageable return into a chargeback.
Set internal targets and workflow steps so refunds don’t fall through the cracks, and make sure your team knows what timelines apply. (If you want to sanity-check your process, refund timeframes are a helpful benchmark.)
Special Scenarios Small Businesses Often Miss
Returns get more complicated when you move beyond a standard “online shop selling physical products” model.
Here are a few situations where we commonly see small businesses accidentally step outside the rules when introducing return charges.
Services And Bookings (And “Returns” That Are Really Cancellations)
If you provide services (beauty, trades, coaching, events, venue hire, etc.), a customer isn’t “returning” anything - they’re cancelling.
This matters because the legal framework is different. You may be able to charge a cancellation fee if it reflects genuine costs and is fair, but you can’t just label it a “returns fee” and assume it’s enforceable.
If your business takes deposits or charges cancellation fees, make sure the fee structure is transparent and defensible. cancellation fees need to be set up carefully to avoid unfair terms and disputes.
Subscriptions And Ongoing Contracts
If you sell subscriptions (for products or services), you’re often dealing with:
- rolling billing cycles
- minimum terms
- cooling-off rights (depending on what’s supplied and when)
- partial refunds
In these models, “returns” can overlap with cancellation rights and pro-rata refunds. It’s important your customer documents align so you don’t accidentally promise one thing in your marketing and enforce another thing in your terms.
In-Store Purchases Vs Online Purchases
For in-store purchases, customers generally don’t have an automatic legal right to a change-of-mind return in the same way they do for distance sales.
That means you have more flexibility to set your own returns policy for in-store sales - but you still need to be careful:
- If you offer a voluntary returns policy, it must be clear and honoured.
- If goods are faulty, the Consumer Rights Act still applies.
- Any fees or deductions still need to be fair and transparent.
A practical approach some small retailers use is: “in-store returns are offered as store credit only” or “returns accepted within X days with receipt, customer pays return postage only where the customer posts it back to us.” The key is clarity and consistency.
B2B Sales (Business Customers)
If you sell to other businesses (not consumers), you generally have more contractual freedom. But don’t assume “B2B” is a magic label - whether someone is legally a consumer depends on what capacity they’re buying in.
For example, a sole trader can still be a “consumer” if they’re buying wholly or mainly outside their trade, business, craft or profession. If you sell to a mix of consumers and small businesses (especially through the same online checkout), it’s worth structuring your documents and processes carefully so the right terms apply to the right customers.
Practical Compliance Checklist For Charging For Returns
If you’re ready to implement return charges, here’s a practical checklist you can work through.
Step 1: Map Your Return Reasons
- Change of mind
- Wrong size/colour ordered
- Duplicate order
- Faulty item
- Incorrect item sent
- Item damaged in transit
Then decide what you’ll charge (if anything) for each category.
Step 2: Set A Clear Policy You Can Actually Run
- Return window (e.g. 14 days, 30 days)
- Condition requirements (unworn, tags attached, original packaging, etc.)
- How customers initiate a return
- Whether you provide a label and what it costs
- How refunds are processed and when
Make sure the policy aligns with your operational reality - if it’s too complex, your team won’t apply it consistently, and inconsistent application is where disputes start.
Step 3: Align Your Customer-Facing Documents
- Website terms
- Checkout wording
- Returns page
- Order confirmation emails
- Customer support scripts/templates
This is also where you reduce risk around “misleading omissions” - customers should not be surprised by return charges after they’ve paid.
Step 4: Train Your Team On The Red Lines
If you have staff handling customer support, make sure they know:
- faulty/incorrect goods are treated differently to change-of-mind returns
- what you can and can’t say (avoid overpromising refunds/rights)
- how to escalate edge cases
Step 5: Keep Records (In Case A Dispute Escalates)
For higher-value goods, keep a clear record of:
- order confirmations and delivery details
- customer communications
- photos of returned item condition (where relevant)
- why any deduction was applied and how it was calculated
You don’t want to be trying to reconstruct the story after a chargeback lands in your inbox.
Key Takeaways
- Charging customers for returns is often legal in the UK for change-of-mind returns, but it depends on the sales channel, the reason for return, and what you disclosed upfront.
- If goods are faulty, not as described, or incorrect, you generally shouldn’t make the customer pay to fix the problem - your obligations under consumer law usually require you to put things right.
- For many online sales, consumers have a 14-day cancellation right, and you need to handle refunds (including standard delivery charges) and refund timing carefully.
- Be cautious with blanket restocking fees - deductions should be proportionate, clearly explained, and tied to real loss in value (not used as a penalty).
- A compliant approach relies on clear wording in your terms, good checkout disclosures, and a returns process your team can apply consistently.
- Returns and refunds can become disputes quickly, so make sure your timeframes, communications, and documentation are solid from day one.
If you’d like help reviewing your returns approach, updating your website terms, or making sure your refund process is compliant, you can reach us at 08081347754 or team@sprintlaw.co.uk.
Make customer terms clear
How do you reduce customer-facing risk?
Retail and online customer issues usually come back to clear terms, refund wording, staff guidance and a process the business can follow consistently.




