Product reviews and EU law: what an online shop may and may not do

The story turns up on merchant forums again and again, in slightly different words. A small shop opens with a hundred products and no reviews. The owner asks friends and family to leave five stars, uses an app to copy a few hundred reviews from the supplier's marketplace listing, and offers 10% off the next order to anyone who leaves a review. Two one-star reviews about late parcels quietly disappear. The product pages look busy and trusted.

Every one of those steps is a problem under EU consumer law, and some of them are on the list of practices that are banned in all circumstances, with no need for a regulator to show that anybody was misled. The owner usually finds out from a competitor's lawyer, a platform suspension or a consumer authority, not from the law itself. The rest of this post is so you find out here instead.

The rules come from the Omnibus Directive, (EU) 2019/2161, which added them to the Unfair Commercial Practices Directive, and every EU country has written them into its own consumer law. They apply from 28 May 2022.

• You must say how reviews are checked. Where a trader gives access to consumer reviews, information about "whether and how the trader ensures that the published reviews originate from consumers who have actually used or purchased the product" counts as material information (Article 7(6)). Leaving it out can be a misleading omission.
• You may not call reviews genuine without checking. Point 23b of Annex I bans stating that reviews come from people who used or bought the product "without taking reasonable and proportionate steps to check" that they do.
• You may not fake or bend them. Point 23c bans submitting, or getting somebody else to submit, false reviews or endorsements, and misrepresenting reviews, to promote products. Recital 49 gives the textbook example: publishing only positive reviews and deleting the negative ones.

The Commission's guidance on the directive reads Article 7(6) broadly. The information is not only about the checks you make, but about how reviews are handled in general: whether all reviews are published, how they are collected, how the average score is worked out, and whether any were sponsored or influenced by a contract. It has to be clear and available where the reviews are shown, either next to them or behind a prominent link, not buried in your terms and conditions.

It also applies to shop reviews, not just product reviews, where they rate things like delivery speed or reliability, and to reviews you show from another service, such as a widget from a review platform. A short, honest paragraph does the job. For a small shop it can be as simple as this:

• Who can review: only customers who placed an order, from a link we email after the order ships.
• What we publish: every review, positive or negative, except ones that break the rules below.
• What we remove: reviews that are abusive, contain someone's personal data, or are about something other than the product or our service. We do not remove reviews because they are critical.
• Incentives: we do not pay or reward reviews. (Or, if you do: what you offer, and that it is the same whatever the rating.)
• The average: the simple mean of all published star ratings.

The guidance spells out what the two banned practices cover. Point 23c includes paying people, or real customers, to post positive reviews, and the guidance adds three more examples of manipulation: giving buyers pre-filled positive review templates, contacting reviewers to get them to change or withdraw negative reviews, and showing an overall rating based on undisclosed or opaque criteria.

These come up every week on ecommerce and Amazon seller forums. The short answers, under EU rules:

• Can I give 10% off the next order for a review? Risky. A reward that is not disclosed makes the review misleading, and German courts have stopped exactly this. If you do it, offer it for any review, good or bad, and say so on the review itself. Italy's new 2026 law goes further for restaurants and hotels and rules out incentives entirely, but it does not cover online shops.
• Can I send a quick survey first and only ask the five-star customers for a public review? No. That is review gating: the reviews you publish then come only from the people you picked.
• Can I import my supplier's reviews from a marketplace to get started? No. They describe another seller's product, delivery and service, and presenting them as your customers' reviews misrepresents them. Moving reviews between your own products (an old model's reviews on the new one) has the same problem.
• My cousin really did buy the product. Can she review it? If she paid for it like any customer and writes her own opinion, unprompted, it is a real review. If you asked her to, or she got it free, it is not a neutral one, and a regulator will look at the relationship.
• Can I delete a one-star review that is simply unfair? Not because it is unfair to you. You can reply to it, and you can remove it if it breaks your published rules (abuse, personal data, not about the product). Write down why.

In January 2022, before the new rules even applied, consumer authorities in 26 EU countries plus Iceland and Norway checked 223 major websites for their review practices. In 144 of them, authorities could not confirm the trader did enough to make sure reviews were genuine, almost half did not explain how reviews were collected and processed, and at least 55% were judged to potentially break the directive (Commission press release). The authorities then contacted the traders to fix their sites.

Since then, cases have come one country at a time:

• Italy. The competition authority (AGCM) fined a home renovation company and its parent €4.5 million in December 2023, in part because positive reviews on Trustpilot and Opinioni.it were traced to the company's own staff (AGCM). In March 2026 it fined Trustpilot itself €4 million, finding inadequate checks on review authenticity, including on reviews labelled verified, and review-invitation tools that let businesses pick which customers were asked; that decision can still be appealed (AGCM).
• Netherlands. In August 2024 the ACM said it had already acted against webshops that bought and used fake reviews, was investigating the sellers of fake reviews, and could fine up to €900,000 per violation. It also reminded shop owners that they stay responsible for what is on their own website (ACM).
• Germany. The duty to explain your checks sits in § 5b(3) UWG. Enforcement often comes from competitors and associations rather than the state: the Wettbewerbszentrale reported 72 complaints about advertising with bought reviews from early 2022 to March 2023 and sent formal warnings in 19 cases, and a Hanover court stopped a shop from advertising reviews it had paid one euro off for, without saying so (beck-aktuell).
• Portugal. The rules were written into the unfair commercial practices law (Decreto-Lei 57/2008) by Decreto-Lei 109-G/2021, from 28 May 2022, and the fines followed in Lei 10/2023.

Each country sets its own fines, so the amounts for a small, local case vary. For widespread cross-border infringements handled through coordinated action between authorities, the directive requires the maximum fine to be at least 4% of the trader's annual turnover in the countries concerned, or at least €2 million where turnover figures are not available. In practice, for a small shop the bigger costs are often a warning letter with legal fees, a court order, or a marketplace or ad account suspended over review manipulation.

The UK has its own regime since 6 April 2025, under Schedule 20 of the Digital Markets, Competition and Consumers Act 2024. It bans fake reviews and reviews that hide an incentive, and requires anyone publishing reviews to take reasonable and proportionate steps against them. The CMA can fine up to 10% of global turnover without going to court. In March 2026 it opened its first five investigations, covering questions such as whether one-star reviews were kept off a site's ratings, whether staff were asked to write positive reviews, and whether customers got undisclosed discounts for five-star reviews (CMA). No findings had been made when they were announced.

1. 1

   Ask every buyer, after delivery

   Send one request to every customer whose order shipped, a few days after it arrived, whatever you think they will say. Asking everyone is what keeps the result honest, and it is also what gets you the most reviews.

2. 2

   Check your email rules

   A review request is an email to a customer, and some countries treat it as marketing. Germany's Federal Court of Justice held in 2018 (VI ZR 225/17) that a satisfaction survey sent with an invoice email was advertising, so it needs consent or must fit the existing-customer exception. Ask your adviser what applies where you sell.

3. 3

   Tie each review to an order

   A link that only works for one order, or a check against your orders, is the "reasonable and proportionate step" the guidance has in mind, and it lets you call reviews verified honestly.

4. 4

   Publish the policy next to the reviews

   A few lines, as in the example above, linked from where the reviews appear. Say what you remove and how the average is worked out.

5. 5

   Keep the bad ones

   A product with 4.6 stars and a few honest complaints is more believable than a wall of fives. Remove only what your published rules say, and apply them the same way to praise.

6. 6

   Reply, briefly and politely

   A reply to a negative review, with what you did about it, often does more for the next customer than the review did harm. Do not ask the customer to change or withdraw it in exchange for a refund.

7. 7

   Disclose any reward, or skip it

   If you send free samples or offer anything for reviews, it must be clear on the review, and never depend on the rating. Most small shops are better off not doing it.

WhizzyCommerce has product and shop reviews built in, designed around these rules. A review can only be written from a link emailed to the customer a number of days after their order ships, which you choose between 1 and 60. The link is signed for that one order, so every review comes from a buyer and carries a Verified buyer mark. Every shipped order is asked once, cancelled and refunded orders are not asked, and there is no open review form for anybody else to fill in.

You can hide a review and show it again, but you cannot edit what a customer wrote. The hide button is meant for the cases in your policy, not for one-star reviews. There is no review import, because reviews you cannot show came from your buyers would make the Verified buyer mark untrue. You still write the review policy yourself and check the email rules where you sell.