E-Commerce Rules Under Consumer Protection Act: What Online Sellers Must Disclose
An online listing that looks complete to a shopper is often missing mandatory disclosures the platform is legally required to display — and marketplace operators specifically carry disclosure obligations that go well beyond what a single-seller website needs to show.
Mandatory disclosures for e-commerce entities generally
- Country of origin of goods — a requirement that has taken on particular significance given "Make in India" and related origin-transparency policy priorities.
- Return, refund, exchange, warranty/guarantee, delivery and shipment terms, along with modes of payment and grievance redressal mechanisms — must be clearly displayed to the consumer before a purchase is completed, not buried in fine print discovered only after the transaction.
- Grievance Officer details — every e-commerce entity is required to appoint a Grievance Officer and display their contact details, with a defined obligation to acknowledge complaints within a specified period and resolve them within a further specified timeline.
Additional obligations specific to marketplace entities
For marketplace e-commerce entities (platforms connecting third-party sellers to buyers, as distinct from an inventory-based single-seller model), additional disclosure obligations apply:
- Clear display of the seller's identity for each listing — name, registered address, website, and contact details of the actual seller, not just the platform's own branding.
- Ensuring sellers on the platform have made the required declarations regarding the genuineness of goods/services being offered.
- A prohibition on marketplace entities manipulating search results in a manner that gives unfair advantage to related parties or sellers with which the marketplace has a financial or other special relationship, without disclosing that relationship.
Prohibited unfair trade practices specific to e-commerce
The Rules specifically prohibit e-commerce entities from engaging in practices including manipulating prices to gain unreasonable profit through unjustified pricing during specified circumstances, and other conduct that would mislead consumers about the actual terms of a transaction, beyond the general unfair-trade-practice concepts that apply to commerce generally.
Why marketplace vs inventory model matters for consumer-facing obligations too
Beyond the FDI-policy classification implications, the marketplace/inventory distinction also drives which specific consumer-disclosure obligations apply — a genuine marketplace has the additional seller-identification and neutrality obligations described above, precisely because the actual transacting counterparty (the third-party seller) is a different entity from the platform itself, requiring the platform to make that relationship transparent to the consumer.
What this means practically for consumers
A consumer shopping online should expect to see clear seller identification (not just the platform brand) on marketplace listings, a clearly stated return/refund policy before completing a purchase, and accessible grievance-officer contact details if something goes wrong — the absence of these disclosures on a specific platform or listing is itself a compliance red flag worth noting.