UK Consumer Law: Important Rules for Luxury and Consumer Brands

UK consumer protection enforcement is tightening, with the CMA able to impose fines up to 10% of global turnover and the ASA utilizing AI for unlawful ad detection. New regulations on fake reviews began in 2025, and companies must ensure transparency in incentives. Late 2025 saw restrictions on advertising unhealthy foods, requiring compliant nutrient profiling. 

UK consumer protection enforcement is becoming stricter. The Competition and Markets Authority (CMA) can fine companies up to 10% of their global annual turnover, while the Advertising Standards Authority (ASA) is increasingly using AI to detect unlawful advertising.

These developments affect luxury fashion, beauty, jewellery, hospitality, food, wellness and other consumer-facing businesses.

New rules on fake and incentivised reviews took effect in 2025, and the CMA is already investigating several businesses.

Brands should have procedures for preventing, detecting and removing fake reviews. Any incentives offered for reviews must be transparent and properly controlled.

Restrictions on advertising and promoting less-healthy foods were introduced in late 2025.

Food, drink and hospitality businesses should identify which products fall within the restrictions by using the required nutrient profiling model. Influencers and marketing teams should also be trained on what may be promoted.

Businesses with fewer than 250 employees are exempt from certain requirements, while incidental or background food images are unlikely to trigger the restrictions.

Beauty, supplement and wellness brands must not claim that ordinary products can prevent, treat or cure medical conditions unless the product is authorised for that purpose.

For example, non-medicinal products should not be promoted as treating acne, menopause symptoms, hair loss or anxiety.

Sensory claims such as “skin feels smoother” may be used if supported by evidence. Health claims for food and supplements must comply with the applicable authorised claims rules.

Prize draws, VIP experiences, product launches and reward campaigns must be fair, transparent and not misleading.

Important terms and conditions must be clearly communicated before customers participate and should not be changed during the promotion. Competitions must also comply with the rules on free entry and genuine skill-based participation.

Businesses using a recommended retail price to advertise savings must show that the price reflects the product’s genuine normal selling price.

For exclusive or own-brand products sold only by one business, “was/now” pricing may be more appropriate.

Since April 2026, where a product price appears in an advertisement, the relevant unit price must also be displayed close to the product description.

New subscription rules are expected to apply from spring 2027.

Businesses will need to clearly explain subscription costs, renewal arrangements and cancellation procedures. Customers must receive reminders before automatic renewals and be given an easy way to cancel.

Online sales journeys should also avoid pre-ticked boxes, misleading buttons, false urgency messages, artificial countdown timers and unnecessarily difficult cancellation processes.

AI may support content creation and campaign development, but AI-generated material can create copyright, accuracy and reputational risks.

Marketing teams should be trained to use AI responsibly, and all output should be reviewed by a person before publication.

Influencers should receive clear instructions covering advertising disclosures, product claims, AI-generated content, less-healthy food restrictions and environmental claims.

The CMA and ASA continue to focus on greenwashing.

Claims about recycled materials, sustainable sourcing, responsible production or environmental benefits must be accurate, balanced and supported by reliable evidence.

Luxury positioning does not reduce regulatory scrutiny. Claims concerning craftsmanship, materials and sustainability must be carefully verified.

For luxury and premium brands, compliance is not only about avoiding fines. Misleading advertising, unfair promotions or unclear customer journeys can also damage reputation and consumer trust.

Businesses should regularly review their advertising, pricing, promotions, subscription models, influencer arrangements and online sales processes to ensure they comply with current UK consumer protection rules.