The caravan went out of the showroom door weeks ago. The awning, the Cadac barbecue and the toilet fluids leave through your web shop, and that is where the Competition and Markets Authority is now looking.
On 2 November the CMA wrote an open letter to every online retailer in the UK. The message runs to one line: the first price a customer sees should be the price they pay. A delivery charge the customer cannot avoid has to be in that price from the start, not bolted on at the basket.
So if your accessory shop shows a product at £89 and then adds £6.95 delivery at checkout, the CMA now treats that as a fining matter, not a quirk of your courier. Four businesses have already paid for getting it wrong.
What the CMA Has Actually Said
Strip out the legal language and the rule is short. Under the Digital Markets, Competition and Consumers Act 2024, when you show a price, that price must be the total, including any mandatory delivery charge.
The CMA calls the moment you show a price an “invitation to purchase”. It applies everywhere a price appears: the product page, the basket, the checkout, a search ad, a Google Shopping listing.
The letter is signed by Sorcha O’Carroll, the CMA’s senior director for consumer, and timed for the run-up to Black Friday on 27 November and the Christmas weeks behind it. It points retailers to the regulator’s own guidance, CMA209, published last November. Chapter 4 covers the core rule. Paragraphs 5.2 to 5.21 deal with delivery.
This is not a new law catching anyone out. The Act has been in force since April 2025. What the letter does is remove the excuse. In the regulator’s own framing, no retailer can now say it did not know how the CMA reads the law on delivery fees.
The teeth are real. In the letter the CMA says it has already fined four businesses more than £5.1 million for this kind of pricing and ordered more than £1.35 million in refunds. It can decide a case and set the penalty itself now, without going to court first. You can read the full open letter on gov.uk.
The trade has already picked this up. The National Caravan Council has flagged the letter to its retailing members and is telling them to review and update their pricing now. Its worked example is a caravan sold with a set delivery charge, where the advert has to show the total, van plus delivery, in the headline. When your own trade body repeats a regulator’s warning inside a fortnight, the quiet period is over.
Why This Lands Hardest on Your Web Shop
A caravan sold with a fixed delivery charge is the simple case. The harder one is the accessory shop, because that is where the rule meets the messy way you actually price delivery.
Most caravan and motorhome accessory sites run one of two setups. Free delivery over a threshold, £40, £75 or £100, with a charge on anything below it. Or a flat charge worked out by weight or order value. Both are standard across the trade. Both are now a compliance question.
Take the threshold first. “Free delivery over £75” is fine on the orders that clear it. The problem is the order that does not.
The guidance is blunt here. Until the basket reaches the threshold, the full delivery charge must sit in the total price from the outset. A £30 set of wheel chocks advertised at £30, with delivery appearing only at the basket, is the practice the letter is written about.
Then there are the heavy and bulky lines. Awnings, caravan covers, levelling ramps, leisure batteries, portable toilets. Plenty of sites carry a note like “most orders qualify for free delivery, but some large items carry a charge you will see at checkout”.
Read the letter and that sentence is a flag. A delivery charge that first shows up late in checkout is one of the four practices the CMA lists by name.
And it reaches your feeds. The letter is explicit that the rule covers marketplaces, comparison sites and search engines too. If your Google Shopping feed shows a price without the delivery a customer cannot avoid, that listing is caught, not just the product page on your own site.
What To Fix Before Black Friday
You have about two weeks before the busiest ordering fortnight of the year. Here is where to spend them.
Put the delivery charge in the price, not just the basket. Walk your own shop as a customer buying one cheap item. If a mandatory delivery charge only appears at the basket or checkout, that is the first thing to change. The compliant routes are simple: show the total with delivery already in it, show the base price with the delivery charge beside it and a running total that carries it, or build delivery into your prices and call it free delivery.
Fix the threshold wording. “Free over £75” is allowed. What is not allowed is hiding the charge on the orders below the line. Show the delivery cost in the total price until the basket clears the threshold, then drop it. The “you are £12 away from free delivery” nudge still works, and it still sells.
Check your heavy items one by one. The awnings, covers, ramps and leisure batteries that carry their own delivery charge are the highest risk, because that is where the fee is most often revealed late. Put the real delivery cost on the product page for each one. If it genuinely varies by postcode, say so plainly and show it as early as you can work it out.
Audit your Google Shopping and marketplace feeds. The price in your feed is an invitation to purchase in the CMA’s eyes. Make sure the figure a shopper sees on Google or a marketplace already includes unavoidable delivery, or you are exposed on a page whose design you do not even control.
The Signal Past Christmas
It is tempting to read this as one more compliance chore landing at the worst time of the year. Read it the other way.
The buyer shopping for a £300 awning is weighing you against three other sites with the same stock. Clear, all-in pricing is what makes your price trustworthy and the next one look like it is hiding something. The dealers who already put honest numbers on the page, the way the parks winning the static market do, turn a legal requirement into the reason the order lands with them.
The margin point matters too. Free delivery is never free. You pay the courier out of the sale, the same way a forecourt discount comes straight off the margin you fought to protect. Pricing delivery in the open forces you to decide what you actually absorb, rather than surprising the customer and yourself at the till.
None of this is legal advice, and the detail sits in the CMA’s own guidance, CMA209. Read it, or put it in front of whoever runs your site.
So before the Black Friday traffic arrives, buy one thing from your own web shop. A cheap one, under your free-delivery line. Watch when the delivery charge shows up. If it waits until the basket, you have found this week’s job, and the answer to the question the CMA is now putting to every retailer in the country. Is the first price you show the price they pay?
