February 20, 2026
The UK’s e-commerce compliance landscape shifted materially with the Digital Markets, Competition and Consumers Act 2024 (the DMCC Act)—especially for consumer-facing brands selling ingestible and wellness products online.
From 6 April 2025, key consumer protection provisions and the Competition and Markets Authority’s (CMA) upgraded enforcement model began to apply. The headline change for online sellers is simple: the CMA can now directly enforce certain consumer law breaches and impose significant monetary penalties—with reporting widely noting fines of up to 10% of global annual turnover for substantive infringements, plus additional penalties for non-compliance with enforcement measures.
For CBD and hemp-derived THC-adjacent (“hemp‑THC”) brands, the DMCC Act’s early enforcement focus areas—drip pricing, fake reviews, and (soon) subscription contract reforms—intersect directly with common growth tactics: auto-ship programs, influencer/affiliate marketing, and checkout flows optimized for conversion.
This article is informational only and not legal advice.
The DMCC Act modernizes UK consumer protection rules and strengthens enforcement. On 6 April 2025, the UK brought into force a set of consumer law changes and the CMA’s enhanced enforcement regime, enabling the CMA to pursue certain breaches without first going to court. Law firm summaries and compliance commentary emphasize that the CMA can now impose penalties for relevant infringements, with maximums frequently described as up to 10% of worldwide turnover for substantive infringements (and up to £300,000 in some contexts, depending on the mechanism and the breach). See, for example, Cooley’s overview of the April 2025 shift and related UCP changes, and broader enforcement analysis from firms tracking the new regime.
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CBD and hemp-derived product companies often:
In other words, the DMCC’s core targets map onto the sector’s most common acquisition and retention mechanics.
The CMA and legal commentary describe “drip pricing” as presenting a headline price and then revealing mandatory charges later in the checkout journey. Updated UK rules and guidance emphasize that consumers should be shown the total price up front in an “invitation to purchase,” including mandatory fees, taxes, charges, or other payments they must pay.
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Watch for these recurring patterns that often trigger drip-pricing concerns:
If the fee is mandatory, it should generally be baked into the total price displayed early and clearly—not discovered on the final payment step.
If delivery is unavoidable (for example, there is no free collection option), many interpretations of the guidance expect the mandatory delivery charge (or the cheapest mandatory delivery option) to be reflected in the total price at the right stage.
“Free shipping over £X” is popular, but businesses should ensure the customer can understand the true payable total as they build the basket, and that any mandatory charge is not presented as a surprise.
The DMCC changes include new banned practices around fake and misleading reviews. The CMA’s published guidance (April 2025) discusses expectations for businesses that publish consumer reviews or consumer review information, including taking “reasonable and proportionate steps” to prevent and remove:
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If compensation, free product, or affiliate revenue is involved, the review is not purely organic. Under the new approach, the problem isn’t only the influencer’s wording—it’s also whether the brand’s systems and the publisher’s systems allow concealed incentivisation.
If your product page mixes customer reviews with brand-selected “success stories,” ensure consumers can distinguish independent reviews from marketing content.
Global brands often syndicate reviews into UK storefronts. If those reviews were collected under different incentives or moderation standards, they can create UK compliance risk.
CBD and wellness sellers often rely on subscriptions (“subscribe & save,” trial-to-paid programs, auto-ship replenishment). The DMCC Act introduces major subscription contract reforms, but multiple legal updates indicate these reforms are not yet in force as of the early April 2025 commencement and are expected later (with commentary suggesting a timeline no earlier than Spring 2026 in some sources).
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Even before the subscription provisions commence, brands should treat DMCC subscription principles as the direction of travel and begin building compliance-by-design.
Ensure consumers see key subscription terms close to the point of sign-up:
Start designing automated notice systems now:
A common compliance gap is making sign-up frictionless but cancellation buried in customer service loops. Prepare for:
With the CMA’s enhanced toolkit, businesses should assume enforcement can involve:
Law firm and industry commentary around the DMCC rollout highlights that the CMA signaled a phased approach in some technically complex areas (often citing fake reviews as an example) while also stating it can act earlier for serious or egregious conduct.
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The DMCC Act targets consumer protection and online selling practices, but CBD brands in the UK also operate within a broader compliance stack.
For ingestible CBD products, the Food Standards Agency (FSA) has ongoing guidance and a “public list” approach linked to novel food applications, and it has communicated provisional safety guidance (including a provisional adult daily intake level for CBD). Industry commentary and shared materials reference an expectation that products not on relevant lists may face local authority action in certain contexts, and that businesses may need to reformulate/relabel to align with updated safety positions.
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If your marketing or review content implies medical benefits, or your product compliance posture is unclear, you can create a compound risk: consumer law exposure (misleading practices) plus product-regulatory scrutiny.
If you sell into the UK now, a short, structured remediation sprint can reduce risk.
If you’re updating UK pricing displays, rebuilding subscription flows, or auditing reviews and influencer pipelines, you don’t have to do it from scratch. Use https://cannabisregulations.ai/ to track fast-moving compliance requirements, document your consumer journey controls, and operationalize cannabis compliance best practices across marketing, e-commerce, and product claims.
