What the CMA’s drip pricing letter means for Christmas delivery fees
Drip pricing rules have applied to UK retailers since April last year. On 2 November 2026, ahead of the Christmas trading period, the Competition and Markets Authority (CMA) wrote to online retailers about one fee in particular: delivery.
The CMA’s open letter to online retailers sums up its position in one sentence: “The first price consumers see should be the price they pay.” Where a customer has to pay for delivery, the total price including the minimum mandatory delivery charge must appear throughout the sales process, from the advert and the product page to the basket and the payment page. At nShift, we work with retailers on the delivery options and prices their shoppers see, and we recommend checking how early in the shopping journey those prices appear.
The letter welcomes the changes many retailers have made since the Digital Markets, Competition and Consumers Act 2024 came into force, then lists what the CMA is still looking out for: product prices shown without the delivery charge, basket totals that leave it out, optional delivery fees tucked behind links or drop-down menus, and delivery costs that appear late in checkout. So far the CMA reports four drip pricing enforcement cases, with fines above £5.1 million.
The guidance behind the letter already covers a standard peak offer: free delivery above a spend threshold.
Free delivery offers under the drip pricing rules
The CMA’s price transparency guidance (CMA209) uses a £40 example: shoppers see the full delivery fee in the total until the basket qualifies, and the site can tell them the fee will go once they pass £40. A Black Friday banner offering free delivery over £50 works the same way. For example, a £35 jumper bought on its own carries the standard delivery fee in its total, and the fee drops out once the basket passes £50.
The banner also needs to meet the advertising codes. The Committee of Advertising Practice, which writes the UK advertising codes enforced by the Advertising Standards Authority, says in its guidance for marketers on delivery charges that the minimum spend must be clear in the headline claim. The £50 goes in the banner’s headline rather than the small print, and so does any postcode the offer excludes.
Check these peak offers against the guidance too:
- Next-day upgrades. A paid next-day or nominated-day option is an optional charge. It has to be shown, but it can appear separately from the total.
- Paid delivery with no free route. If every option costs money, offering several does not make delivery optional. The first total includes the cheapest option and updates if the shopper chooses a faster one.
- Delivery passes. Deliveries a customer has paid for upfront through an annual subscription should not be advertised as free.
- Free click and collect. When shoppers can collect for free, paid home delivery becomes optional, and its price can be shown alongside the total rather than inside it.
Show the delivery price before checkout
Some retailers calculate the delivery price at checkout, once the address and basket are known. The total-price rule applies earlier than that: adverts, product pages, marketplace listings and comparison-site feeds need the delivery charge, or a clear explanation of how it is calculated.
Where an address-dependent charge cannot yet be calculated, CMA209 allows retailers to explain how it is worked out, with the same prominence as the price itself. One of its examples is a department store with five delivery charges by region, listed on the product page. They range from free delivery to mainland Great Britain to £15 for the Channel Islands, and the right one is added to a running total once the customer signs in.
Business Companion, the trading standards guidance service for businesses, warns that shoppers may read an offer of UK delivery as including Northern Ireland, the Scottish islands and the Highlands. “Highlands and Islands” also has no single definition, so name the postcodes a surcharge covers rather than the region.
When different teams keep separate copies of the delivery rules, a shopper can see one delivery price on the product page and another at checkout.
We recommend that retailers using nShift Checkout hold one set of delivery price rules, by postcode, basket value and parcel weight, and show the same delivery options in both places. With nShift’s Product Page Widget, shoppers preview and choose delivery options on the product page from the same configuration the checkout uses, so a retailer changes a Black Friday threshold or a Highlands surcharge once.
Test the delivery fees before the first promotion goes live
Shop your own site the way a customer will this season, starting from an advert or a marketing email rather than the home page.
- Place test baskets below, at and above your free-delivery threshold.
- Enter postcodes from mainland Great Britain, Northern Ireland and the Highlands, and check that the product page, basket and payment page agree on the delivery charge.
- Read every “free delivery” headline for its minimum spend and postcode exclusions.
- Check the prices you send to marketplaces and comparison sites.
The CMA says it will keep monitoring pricing across online retail, so repeat the checks whenever a promotion changes the threshold or the postcodes it covers.
Our guide to drip pricing and UK delivery charges sets out the CMA’s delivery requirements case by case, including basket-level fees and variable charges. For how to choose a free-delivery threshold, see our free delivery guide.
Common questions about drip pricing and delivery fees
Does a free delivery threshold count as drip pricing?
Not if the total price is right at each step. Until the basket qualifies, the total includes the full delivery fee. Once it passes the threshold, the total can drop. The advertised minimum spend must appear in the headline claim.
Must the delivery charge appear before a shopper enters a postcode?
If the charge depends on the address and cannot yet be calculated, retailers must explain how it is worked out, with the same prominence as the price. Once the address is known, the charge goes into the total.
Gregory Mannix is a Delivery Expert at nShift with more than 20 years of experience in SaaS, ecommerce and logistics. He helps retailers and logistics providers improve their delivery operations, from carrier management and tracking to returns.
