Australian Returns Policy Page: ACL Rules and Conversion

Quick answer: In Australia, a returns policy cannot take away a customer’s consumer guarantees. If a product is faulty, not as described or otherwise fails a guarantee, the customer can be entitled to a refund, repair or replacement whatever your page says, and the ACCC has flagged no-refund rules, time limits, restocking fees and manufacturer-only wording on faulty goods. Change-of-mind returns are your choice, but if you offer them you must follow your own policy. I suggest a page with two clearly separated parts, one for faults and one for change of mind, under a short summary, and I cover the wording below as general information, not legal advice, so have a lawyer review yours.

Most returns policies are written once, in a hurry, from a template, and then forgotten. The shopper wants one answer: if this is not right, what happens?

Two things raise the stakes. The first is regulatory. The Australian Competition and Consumer Commission (ACCC) reviewed the returns policies and terms of more than two thousand Australian retail websites, and in September 2026 it announced penalties paid by an online retailer over statements about returns. The second is commercial. Google’s Merchant Center help calls return policy a key factor for people making a purchase decision, so a page that reads like a legal wall may cost you orders as well as add risk.

This guide covers the text of the policy page: what the ACCC has said, how to structure the page, what goes in each part, how to set it up in Shopify and how to check it reads well. Where the policy appears (product page, cart, checkout, footer) is a separate question, covered in our guide to shipping and returns messaging for Australian Shopify stores.

One boundary first. This is not legal advice, and nothing here declares any wording compliant. I read the regulator’s own pages and report what they say, as at 31 October 2026. Consumer law changes and facts differ by product, so have a lawyer review your final text.

What the ACCC has actually said

The 2025 sweep of retail websites

On 4 February 2025 the ACCC published the results of a sweep of more than two thousand Australian retail websites. It reviewed return policies and terms and conditions and found some that may contravene the Australian Consumer Law (ACL). The release does not say how many of the sites had a problem, so I will not repeat a number it does not give.

The ACCC grouped its concerns into four kinds of statement:

• time limits for returning a faulty product;
• blanket no-refund conditions on sale items or specialised items;
• naming the manufacturer’s warranty as the only way to claim for a faulty product;
• limits on the remedy itself, such as saying delivery fees paid for a faulty item are non-refundable, or charging a restocking fee when a faulty item comes back.

The ACCC wrote warning letters to several businesses and said its action led the majority to change or remove the statements. It also said it was pleased to find many sites that explained consumers’ guarantee rights, which is the model to copy.

The September 2026 penalty notice

On 9 September 2026 the ACCC announced that Sydney-based online retailer Dysck Pty Ltd, trading as Neptune Blanket, had paid $59,400 in penalties after three infringement notices. The ACCC alleges that emails to two customers who had asked for refunds were false or misleading, because they implied limits on remedies the customers might have been entitled to. The statements it describes: returns or exchanges at the store’s discretion or as store credit only, an item needing to be unopened, unused and in its original condition to be eligible for exchange, and the customer paying non-refundable return shipping. The third notice was about a warranty on the store’s returns page that lacked the mandatory consumer guarantee wording.

Two details matter. The ACCC says paying an infringement notice is not an admission of a contravention. And the statements at issue were in emails to customers, not only on the website, so your support replies need the same review as your policy page. The ACCC also said that steps taken after it makes contact may not prevent enforcement action.

Reform in progress

The ACCC’s 2025 release welcomed the Federal Government’s commitment to work with state and territory ministers on designing civil penalties, including for businesses that fail to provide a remedy they are legally required to provide. Treasury’s Decision Regulation Impact Statement page (19 December 2025) says consumer ministers agreed in November 2025 to strengthen the consumer guarantees framework, including civil penalties and expanded enforcement powers, and that Treasury would develop draft laws. I did not find final legislation as at 31 October 2026, so check Treasury’s site. Both sources point to stronger enforcement, not weaker.

Overseas stores selling into Australia

If you are a US-based founder selling to Australian customers, the ACCC says an overseas business that provides goods directly to consumers in Australia must follow the ACL, including the consumer guarantees. An all-sales-final page written for a US audience does not switch that off.

The rule underneath: guarantees are not your policy

Everything on the page hangs off one distinction.

Consumer guarantees are automatic. The ACCC says anything a business says or does cannot take them away, and gives examples: a no-refunds sign, saying you are not responsible for problems, or suggesting the customer must buy an extended warranty to keep their rights. For products the guarantees include acceptable quality, fitness for a purpose the customer told you about, and matching the description.

Your own terms are the extras: change-of-mind returns, a longer window, free return postage. You decide those, but the ACCC says that if you have a change-of-mind policy, you must follow it.

The remedy side, as the ACCC describes it on its repair, replace and refund page:

Supporting points from the same ACCC page:

• A major problem includes a product that is unsafe, very different from its description, has a problem serious enough that the customer would not have bought it, or cannot be used normally and cannot be easily fixed in a reasonable time.
• Businesses must not tell consumers to go to the manufacturer for a remedy.
• There is no entitlement where the customer misused the product or knew about the problem before buying.
• If the business confirms a problem, it must reimburse reasonable return costs the customer paid. For large, heavy or hard-to-remove goods, the business pays for shipping or collects them. If there turns out to be no problem, the business can charge collection and inspection costs, but only if it gave a reasonable estimate first.
• The product does not need its original packaging, but you can ask for proof of purchase.
• The ACCC’s warranties page says the guarantees continue for a reasonable time depending on the product.

That last point is why a 30-day limit can be your own choice as a change-of-mind rule, yet is one of the statements the ACCC flags when it is applied to faults. The same sentence can be your choice in one context and a flagged statement in another.

A page structure that serves both goals

The ACCC’s concern is wording that blurs the two categories. The shopper’s concern is not finding the answer. One structure fixes both: a short summary on top, then two labelled parts.

The summary box

Four plain lines, with real numbers:

1. If something is wrong with your order, contact us and we will sort it out in line with your rights under the Australian Consumer Law.
2. If you change your mind, you can return unused items within [your number] days of delivery.
3. Here is how to start a return: [link].
4. Questions: [phone or email, and how fast you reply].

Part A: If something is wrong with your order

This is your floor. In plain language it should say:

• the customer has rights under the Australian Consumer Law that apply whatever your return terms are;
• what counts as a problem: faulty, damaged, not as described, not what they ordered;
• what you will do (refund, repair or replacement, depending on the problem) and how fast you reply;
• how to report it and what you need (the ACCC says you can ask for proof of purchase and have the right to assess the product);
• that you cover reasonable return costs when the fault is confirmed.

Avoid a reporting deadline for faults, a restocking fee on faulty items, and sending people to the manufacturer: all three are on the ACCC’s list of statements businesses should not make about faulty products. Also avoid requiring original packaging (the ACCC says a faulty product does not have to be in it) and store-credit-only wording (the Neptune Blanket release alleges that implied a limit on remedies).

Part B: If you change your mind

This is your commercial offer, and it should say it is separate from Part A. Cover:

• whether you accept change-of-mind returns at all (you may choose not to; say so honestly and keep Part A);
• the window and when it starts (delivery date is clearer than order date);
• condition rules, who pays return postage, and how you refund and how long it takes;
• exclusions such as opened skincare or personalised items, phrased as applying “if you change your mind” so nobody reads them as a limit on fault claims.

Make every term something you will do every time. The ACCC says a stated change-of-mind policy must be followed, so do not promise what you cannot deliver.

Part C: How to start a return, and who you are

Three or four numbered steps, then your contact details. The ACCC’s online shopping advice tells consumers they have a better chance of resolving problems if they buy from a business that displays clear steps for problems, replacements and refunds, and displays a phone number, a physical address and an ABN or other registration number. That is the regulator’s list of what helps consumers resolve problems, and a ready-made checklist for the bottom of your page.

Part D: Awkward cases

• Sale items. If sale items cannot be returned for change of mind, say that. A flat statement that sale items cannot be refunded is one of the ACCC’s concerns when it reads as covering faults.
• Gifts. The ACCC says gift recipients have the same basic rights as the buyer. One line saying so helps.
• Your own warranty. If you offer a warranty against defects, the ACCC says it must include specified information and mandatory text, and the mandatory information must be available with the actual product, not only on a website. The sentence for goods begins: “Our goods come with guarantees that cannot be excluded under the Australian Consumer Law.” The full required text is on the ACCC warranties page and must be used exactly. Ask your lawyer how it applies to your products.

Wording audit: patterns to find and fix

Put your current page and your support email templates next to this table. Column one describes a pattern in my words, drawn from the ACCC’s lists. Column three is the shape of a safer rewrite for a lawyer to check, not wording I am declaring compliant.

If your lawyer rewrites any of these, ask them to keep the two-part structure.

What shoppers want from the page

Now the conversion side. The study I trust is Baymard Institute’s, which publishes checkout usability research. Its cart abandonment page (last updated 22 September 2025) reports a study of US online shoppers: 42% said they had abandoned a cart because they were just browsing. Setting those aside, Baymard lists the remaining reasons. Extra costs led at 40%, slow delivery followed at 20%, and 13% said the returns policy was not satisfactory. The page gives no sample size or survey date, and it is a US survey. The listed percentages total well over 100%, so shoppers evidently gave several reasons, and the page does not spell out the base, so the 13% is not “13% of carts”.

My reading: returns policy is not the biggest reason people leave. Unexpected costs (see surprise checkout costs) and delivery rank higher. But it is one of the cheaper reasons to fix, because it is mostly words. That is my interpretation, not a measured result for any store. Google’s Merchant Center help, mentioned earlier, makes a similar point from its side. That is Google’s statement, not a measurement for your store.

Plain-language rules that help

• Lead with the answer. The summary box is the single biggest improvement on most pages.
• Use numbers. “Return unused items within 30 days of delivery” beats “a reasonable period”.
• Use the shopper’s questions as subheadings. Is it free? How long do I have? How do I start? When do I get my money?
• Keep it as real text, not an image or PDF. Text can be read by screen readers and by crawlers, and it is easier to keep in step with your return rules. See product data for AI shopping agents.
• Say the same thing everywhere. Product page, cart, checkout footer, FAQ, order emails and the policy page must agree. Google’s Merchant Center rules ask for this consistency too.
• Date the page. A “last updated” line shows it is current.

Generosity is a margin decision

A more generous change-of-mind policy might help conversion, but it raises returns, and you pay for them. I have not found a primary source for return-rate benchmarks I would trust, so use your own numbers.

An illustration, not a benchmark: if return postage is A$9 and 10 in every 100 orders come back for change of mind, free returns cost A$90 in postage per 100 orders, or A$0.90 an order, before the lost margin on returned items and handling time. Compare that with your contribution margin per order before you decide. Any fee or store-credit option belongs in Part B only.

What to test

An illustration, not a forecast: a store with 20,000 product page sessions a month and a 2.0% conversion rate takes 400 orders. If clearer returns wording moved it to 2.1%, that is 20 extra orders, about A$1,800 at an average order value of A$90, before returns and margin. It shows why the change is worth an afternoon, not a month.

A shift that small is hard to detect with an A/B test at this traffic (see A/B testing with low traffic). So compare before and after, and watch behaviour: do support emails asking “can I return this?” drop after the rewrite? Support tickets are free data.

Setting it up in Shopify

This section draws on two Shopify Help Centre pages, “Setting up return and cancellation rules” and “Adding store policies”, which I read on 31 October 2026. Shopify changes its admin often, so check the current screens.

1. Two settings, not one. In Settings, then Policies, you have the written return and refund policy and, separately, the return and cancellation rules. The text is one thing. The rules drive what customers can request.

2. Automated or written. Shopify can generate an automated policy from your settings. On an existing store, turning it on replaces the current content, so save a copy first. If you turn it off, you must update the text yourself whenever the rules change. Shopify says its automated templates are informational, are not legal advice and do not guarantee compliance, and that you are responsible for the accuracy of your policies and for following them. Read any generated text against the ACCC statements above. I have not assumed it fits the ACL.

3. Set the return rules deliberately. Options include the return window (14, 30, 90 days, unlimited or custom), when the window starts, free return shipping, a flat fee or a customer-bought label, a restocking fee, final sale items and per-item overrides. For an Australian store:

• A restocking fee is a percentage of the return, and Shopify does not deduct return fees from refunds automatically; you deduct them manually. Make sure staff apply it only to change-of-mind returns, never a confirmed fault.
• Customers cannot submit a return request through Shopify for items marked final sale. Shopify’s examples include personal care items and items with large discounts. If you use final sale, the written policy should say it applies to change of mind and tell customers with a faulty final-sale item how to reach you, because Shopify’s self-serve route will not take their request. Test this on your own store.
• If several window overrides apply to an item, the shortest is used, and changes apply to future orders only.

4. Put the link where people look. Shopify says that by default your policy links appear in the checkout footer, and a return policy link also appears on the order review page. It suggests you also link policies in your store menus or store footer: add them under Content, then Menus, or link /policies/refund-policy directly. Shoppers deciding whether to buy are on the product page, not the checkout footer; that is the placement question in the messaging guide.

5. Selling across borders. Shopify’s per-market return rules were in early access, for certain merchants only, as at 31 October 2026. If you sell from Australia overseas, or from the US into Australia, see selling overseas with Shopify Markets and check which policy each customer sees.

6. Shop app. Shopify says return policy details may appear on Shop app product pages (early access), taken from your configured return window. A policy written only as free text will not appear there.

A side note on search and Merchant Center

This matters only if you use Google Shopping or free product listings.

Google’s Search Central documentation on MerchantReturnPolicy structured data says Google can use it to show return policies alongside products and in knowledge panels. It recommends one page describing your return policy, markup nested under Organization, and product-level overrides only where terms differ. Its properties let you describe customer-remorse returns and item-defect returns separately, with their own fees, which is the same split as Part A and Part B. Check whether your theme or an app outputs the markup. I have not assumed yours does or does not.

In Merchant Center, Google’s help page asks for clear return and refund information on your site, consistent across Merchant Center and the site, and accessible without logging in. It also says policies should apply beyond defective products to cases such as buyer’s remorse. That is Google’s programme requirement, not an Australian legal rule. If you do not accept change-of-mind returns, read Google’s current page before submitting. For policy mismatches that disapprove products, see Merchant Center disapprovals on Shopify.

The pre-publish checklist

Law and wording (for your lawyer to confirm)

1. The page has two labelled parts: faults and change of mind.
2. Part A sets no fault-reporting deadline, fee, packaging requirement or manufacturer-only instruction.
3. Exclusions (sale, opened, personalised) say they apply to change of mind.
4. Change-of-mind terms are ones you will honour every time.
5. Any extra warranty carries the required information and mandatory text.
6. Support email templates and chat replies say the same as the page.

Reading experience

7. A four-line summary sits at the top, with subheadings that are the shopper’s questions.
8. Every term has a number: days, cost, reply time.
9. Contact details include a phone number, a physical address and an ABN or other business registration number, the three items in the ACCC’s online shopping advice.
10. It is real text, readable on a phone, with a “last updated” date.

Shopify and systems

11. Return rules in Settings match the written policy; restocking fee and final sale apply only to change of mind; a faulty final-sale item has a route to you.
12. The policy is linked from the footer menu, product pages and cart, and any Merchant Center or structured data settings match it.

Review the page every quarter and whenever you change a return rule, add a made-to-order range or start selling to a new country. Keep a short dated change log, and state the dates of any seasonal return window on the page.

Key takeaways

• Consumer guarantees cannot be taken away by a returns policy. The ACCC lists no-refund wording, time limits, restocking fees, delivery fee refusals and manufacturer-only wording as concerning for faulty goods.
• Change-of-mind returns are optional, but if you offer them, follow them.
• Split the page into Part A (faults) and Part B (change of mind), with a four-line summary on top.
• Check support emails and chat templates too. The September 2026 ACCC penalty notice involved emails to customers.
• A US store selling directly to Australian customers still has to follow the ACL.
• In Baymard’s US survey, 13% cited an unsatisfactory returns policy among their reasons for abandoning a cart. It is not the biggest reason, but it is mostly words to fix.
• In Shopify, the written policy and the return rules are separate settings. Make them match.
• Judge the rewrite by support tickets and before-and-after behaviour, and have a lawyer review the wording.

FAQs

Do I have to have a returns policy on my Australian online store?

I did not find an ACCC statement that says a store must publish one, so I cannot say it is a legal requirement. The ACCC does say consumer guarantees apply to every sale whether or not you have a policy, that a change-of-mind policy you state must be followed, and, in its advice to shoppers, that clear steps for returns and refunds are a sign of a business worth buying from. Google’s Merchant Center has its own requirements. Ask your lawyer about your situation.

Can I put “no refunds on sale items” on my Shopify store?

Not as a blanket statement. The ACCC lists no refunds for sale items among statements businesses should not make about faulty products. A statement that sale items cannot be returned if the customer changes their mind is about your own terms, and it is a different statement. Have a lawyer check the exact wording.

Do I have to accept change-of-mind returns?

No. The ACCC says consumers are not entitled to a repair, replacement or refund under the guarantees just because they changed their mind, found it cheaper or no longer like the product. If your business has a change-of-mind policy, though, you must follow it.

Can I set a 30-day limit on returns?

For change of mind, the window is your decision. For faulty goods, the ACCC lists a limited time after receipt as a statement businesses should not make, and says the guarantees continue for a reasonable time depending on the product. Keep the two separate on the page.

Who pays for return shipping?

For change of mind, you decide and should say so. For a confirmed fault, the ACCC says the business must reimburse reasonable return costs the customer paid, and pays for shipping or collection of large or heavy goods. If the product has no problem, the business can charge collection and inspection costs, but only after giving a reasonable estimate.

Does this apply if my store is based in the US?

If you provide goods directly to consumers in Australia, the ACCC says you must follow the ACL, including the consumer guarantees. The ACCC also says it can be hard in practice for Australian consumers to get remedies from overseas businesses, but that does not remove the obligation.

Can I use Shopify’s automated returns policy as it is?

Shopify says its automated templates are informational, are not legal advice and do not guarantee compliance, and that you are responsible for their accuracy and for following them. Read the generated text against the ACCC statements in this guide, and make sure your return rules and written policy match.

Is your returns page helping shoppers decide, or only protecting you?

Once the wording has been through your lawyer, the next question is how it reads on the product page and at checkout, alongside everything else between a visit and an order. That is the kind of thing our Shopify CRO service looks at. We do not review legal wording; that stays with your lawyer. To start, book a free 30-minute diagnostic and bring your returns page with you, or tell us about your store. We share your Shopify store on screen and name two or three conversion leaks live, and tell you whether they are worth fixing. No pitch.