Customer Complaints, Returns and Refunds: What Indian Law Requires of Sellers
Quick answer: If you sell online in India, the Consumer Protection (E-Commerce) Rules, 2020 require you to show clear return, refund, warranty and delivery terms, appoint a grievance officer who acknowledges complaints within 48 hours and resolves them within one month, and not refuse returns or refunds for defective, wrongly described or late goods. Unhappy customers can go to the National Consumer Helpline (1915) or a consumer commission, so a fair written policy and quick replies protect you. Amendments notified in September 2026 add more duties from 1 January 2027.
Who these rules apply to
The Consumer Protection Act, 2019 (which replaced the 1986 Act) covers anyone who buys goods or services, including online. The E-Commerce Rules, 2020 sit under it and apply to all goods and services sold over digital networks, whether through a marketplace or your own store. They do not apply to an individual who sells something occasionally in a personal capacity, not as part of a business.
| How you sell | How the rules see you |
|---|---|
| On Amazon, Flipkart, Meesho or another marketplace | A seller on a marketplace (Rule 6 duties) |
| Your own website or app holding your own stock | An inventory e-commerce entity (Rule 4 and Rule 7 duties) |
| WhatsApp, Instagram or shop counter | The Consumer Protection Act still applies to any sale; following the same standards is the safe course |
What you must do as a marketplace seller
According to the rules, a seller on a marketplace must:
- Have a written contract with the marketplace and give it your legal name, address, customer care contact, and GSTIN and PAN where applicable.
- Appoint a grievance officer, show their contact details, and make sure complaints are acknowledged within 48 hours and resolved within one month.
- Show the total price with a breakdown of other charges, any expiry date, country of origin, and the importer’s details for imported goods.
- Show clear return, refund and exchange terms, including who pays return shipping, plus delivery details and any warranty or guarantee.
- Accept returns and give refunds where goods or services are defective, deficient, not as described, or delivered late, unless the delay was due to force majeure.
- Not post fake reviews or pose as a customer, and make sure product photos and ads match the actual product.
What you must do on your own website
If customers order from your own site, you are the e-commerce entity, so the duties fall on you directly:
- Display your legal name, address, website and customer care email and phone.
- Appoint and display a grievance officer, with the same 48-hour and one-month timelines, and give a ticket number for each complaint.
- Clearly display return, refund, exchange, warranty, delivery, shipping costs, payment methods and cancellation procedures.
- Charge a cancellation fee only if you would bear similar charges when you cancel an order yourself.
- Record a buyer’s consent only through a clear action, not a pre-ticked box.
- Process refunds within a reasonable time, following RBI payment rules.
- Not refuse returns or refunds for defective, wrongly described or late goods.
- If you claim your products are authentic, you are responsible if they are not.
Liability: when the seller pays, not just the maker
Under the Act, product liability can fall on the manufacturer, service provider or seller. A seller who is not the manufacturer can still be liable if, for example, they:
- Controlled the design, packaging or labelling of the product.
- Altered or modified it, and that caused the harm.
- Did not pass on the maker’s warnings or instructions.
- Gave their own express warranty that the product did not meet.
- Sold a product whose manufacturer is unknown or cannot be reached.
- Did not take reasonable care in assembling, inspecting or maintaining it.
This matters for resellers and white-label brands. If you put your own label on a product, you carry more of the risk.
Misleading claims carry separate risk. The Central Consumer Protection Authority can fine a manufacturer or endorser up to ₹10 lakh for a false or misleading advertisement, and up to ₹50 lakh for a repeat offence. Claims like “100% organic” or “chemical-free” need proof.
What changes from 1 January 2027
On 10 September 2026, the Department of Consumer Affairs notified the Consumer Protection (E-Commerce) (Amendment) Rules, 2026, effective 1 January 2027. According to the PIB release, they require e-commerce entities to:
- Join the National Consumer Helpline’s convergence process.
- Give complainants a copy of the complaint as recorded by the grievance officer.
- Label sponsored listings clearly and not manipulate search results.
- Show the earlier price next to any discounted price, with the earlier price defined as the lowest price offered in the 30 days before the discount.
- Follow the 2023 dark pattern guidelines, complete a yearly self-audit and display a compliance certificate.
- Disclose importer details and country of origin for imported goods.
Most of these duties sit with platforms and stores, but if you run your own website, plan for them now. Fake “was ₹1,999, now ₹999” prices are the easiest mistake to avoid.
Where an unhappy customer can go
National Consumer Helpline (NCH). Customers can call 1915 (8 am to 8 pm, 17 languages), message on WhatsApp at 8800001915, or file on consumerhelpline.gov.in, the NCH app or UMANG. NCH forwards complaints to companies in its free, voluntary convergence programme, which are expected to reply within 30 days. As of August 2026, 1,853 companies had joined. NCH handled 17,71,622 grievances in 2025, and about 29% were about e-commerce.
Consumer commissions. If talks fail, the customer can file a case. Cases are filed online on e-Jagriti, launched on 1 January 2025, which brings together the older e-Daakhil and other systems.
| Value of goods or services paid | Forum |
|---|---|
| Up to ₹50 lakh | District Commission |
| Above ₹50 lakh up to ₹2 crore | State Commission |
| Above ₹2 crore | National Commission |
For most small sellers, any case would go to the District Commission. Defending one costs time even when you are right, so solving complaints early is cheaper.
How to handle complaints well
- Write a one-page policy. Return window, condition of returned goods, who pays shipping, refund method and timeline, and items you cannot take back for hygiene reasons (innerwear, opened cosmetics, custom orders). Put it on your site, listings and order confirmation.
- Name a grievance contact. Even a one-woman business can list herself with an email and number. Reply within 48 hours, even if only to say you are checking.
- Keep evidence. Packing video or photos for higher-value orders, courier tracking, chat history and the customer’s photos of the issue.
- Fix fast when you are at fault. A refund or replacement on a ₹600 order is cheaper than a lost review or an NCH ticket.
- Put your answer in writing. If you decline a return, explain why with reference to your published policy.
- Log every complaint. A simple sheet with date, issue, outcome and days to resolve shows patterns, like a supplier batch that keeps failing.
- Reply to NCH notices. If a complaint reaches you through NCH or a platform, respond on time and keep a record.
Common mistakes
- “No returns, no refunds” in your bio. You cannot refuse a refund for a defective or wrongly described item.
- Photos edited so much that the product looks different.
- Charging cancellation fees you would not pay yourself.
- Ignoring complaints because the order value is small.
- Copying a big brand’s return policy without being able to follow it.
FAQ
Q: I only sell on Instagram and WhatsApp. Do these rules apply to me?
A: The Consumer Protection Act applies to any sale to a consumer. Whether a particular E-Commerce Rules duty applies to a social media seller is not always clear, so follow the same standards: clear policy, named contact, quick replies.
Q: Must I accept returns if the customer simply changed her mind?
A: The rules require returns and refunds for defective, deficient, wrongly described or late goods. For change of mind, your published policy decides, so state it clearly.
Q: Who is my grievance officer if I work alone?
A: You can be. Display your name, email and phone, acknowledge within 48 hours and resolve within one month.
Q: A customer filed a complaint on NCH. What happens?
A: If you or your platform are a convergence partner, the complaint is forwarded for a reply, expected within 30 days. Answer it in writing and keep proof of what you did.
Q: Can a customer take me to a consumer court for a small order?
A: Yes. Claims up to ₹50 lakh go to the District Commission, filed online on e-Jagriti.
Q: What is the new “earlier price” rule?
A: From 1 January 2027, a discount must show the earlier price, defined as the lowest price offered in the previous 30 days.
Official links
- National Consumer Helpline: https://consumerhelpline.gov.in
- e-Jagriti (consumer commission filing): https://e-jagriti.gov.in
- Department of Consumer Affairs: https://consumeraffairs.nic.in
- PIB (press releases on consumer rules): https://pib.gov.in
Last checked: October 2026. Rules, limits and fees change; confirm with the official source before you apply. This guide is general information, not legal, tax or financial advice.
Sources: PIB release on Consumer Protection (E-Commerce) (Amendment) Rules, 2026 (September 2026); Department of Consumer Affairs, CPA 2019 and online transactions note (October 2026); IndiaLaw summary of the E-Commerce Rules, 2020 (October 2026); PRS Legislative Research, Consumer Protection Bill 2019 summary (October 2026); K&S Partners, Consumer Protection Act 2019 overview (October 2026); National Consumer Helpline website (October 2026); PIB NCH backgrounder (October 2025); News On AIR, NCH in Lok Sabha (August 2026); PIB year-end review, e-Jagriti (December 2025); Moneylife, revised pecuniary jurisdiction (December 2021).