Stung by fees

Executive Summary

Consumer confidence is critical for economic growth. 

However, data from the BEIS Consumer Protection study estimated that two-thirds (69%) of consumers experienced an issue with a product or service over the course of a year, causing them time, financial and/or emotional harm [1]. Even where consumers do not experience a specific problem with a product or service, certain practices from businesses can lead to the sense that some markets are not working in consumers’ favour. This can erode consumer trust and ultimately damage the market itself.

This report delves into the practice of drip pricing, where consumers are advertised a cost for a product or service upfront, only to have extra fees added on (or ‘dripped’) as they approach the checkout. This has become widespread within digital markets. Online shopping has become a crucial part of the way people consume in the UK, with internet sales making up a quarter of total retail sales according to ONS statistics [2]. It is therefore crucial that consumers are protected from harmful practices when shopping online.

This report explores the types of harm generated by drip pricing, and its impact on consumer decision-making. Our qualitative interviews and quantitative survey explore consumers’ views on, and reactions to, drip pricing practices in three markets where they are commonplace: online food delivery, event ticketing and airlines.

The current law affords some protection to consumers which could apply to drip pricing practices. The Consumer Protection from Unfair Trading Regulations (CPRs) [3] prohibits traders from engaging in unfair commercial practices which harm consumers’ economic interests. They impose a general prohibition on traders in all sectors from engaging in unfair or misleading commercial practices and oblige traders to trade fairly and honestly with consumers. However, there are significant evidential and legal hurdles in showing a breach of these broadly worded provisions [4], and our research illustrates that harmful drip pricing practices are common in some markets.

Drip pricing can come in several forms. It can include prices that consumers have to pay in order to make the transaction, which may be a fixed price (such as a fee for buying an e-ticket for an event) or a variable price (such as a delivery or service charge). In some cases, dripped fees are for optional services that are applied depending on the choices that consumers make to suit their needs (such as extra luggage or additional legroom when selecting a flight). These practices need to be dealt with in different ways. However, the overriding principle that sits across all of these practices is the need for much greater transparency at the beginning of the buying process. This transparency is essential to ensure that consumers know what to expect and are in a position to make comparisons with other options that are available to them. Without price transparency, markets fail, competition is weakened, and the economy suffers.

Our research found that online shoppers generally had a pessimistic view of drip pricing, with 86% of consumers seeing it as sneaky and only 10% seeing it as fair. This negative outlook came from a sense that there is a lack of transparency in how these prices can be applied – whereby businesses “entice” consumers with competitive initial prices, adding charges later on. Generally speaking, consumers saw drip pricing as a money making exercise for businesses at the expense of consumers, aiming to make as much profit as possible, and potentially misleading or “tricking” customers in the process. Though this was the general, high level reaction, drip pricing can come in many forms and there were factors that made these practices either more or less damaging for consumers.

Consumers were most frustrated by charges that were unexpected and not clearly signposted earlier on in the buying process. They were also frustrated in situations where they did not understand what the charges were for, or why they were charged at a particular cost. 81% of online shoppers thought such fees were more acceptable when shown upfront. Additionally 69% thought they were more acceptable when accompanied by a clear explanation of what they were for.

Consumers’ perception of value for money played a role in their views about drip pricing. They were somewhat more accepting of these prices when they represented added value, such as delivery fees for takeaways or fees for luggage and seat costs (67% of online shoppers agreed that optional extra charges are more acceptable than mandatory ones), where they could easily understand the purpose of the fee. On the other hand, they expressed more dissatisfaction with examples like processing fees for e-tickets, because they could not see the value added by this service and why it incurred a charge.

Whilst consumers were more accepting of dripped fees they saw as adding value, there were still aspects of these charges and the way they were presented that frustrated consumers. Many were dissatisfied with the level of these fees, seeing the charges as excessive. It was also common for consumers to interpret seat selection charges on airlines as mandatory when they are, in fact, optional. Furthermore, they raised questions about whether some 'optional’ charges were genuinely a choice. This was especially evident among parents who would need seats next to their children on a flight. Overall, this meant that even optional ‘dripped’ prices were viewed negatively by online shoppers, with 73% seeing the charges as ‘sneaky’ even in the optional example for airlines.

Action needed

The findings of our research reinforce the need for the government to take immediate action to address drip pricing. The Digital Markets, Competition and Consumers (DMCC) Bill, currently being considered in Parliament, is a crucial opportunity to update consumer and competition law and ensure that it is fit to deal with current practices that can cause harm for consumers when shopping online. There needs to be appropriate regulation of drip pricing practices by supplementing the existing provisions within the CPRs to restrict drip pricing practices that can mislead or confuse consumers.

The Bill includes a schedule of commercial practices which are considered in all circumstances to be unfair (currently Schedule 18 of the Bill), which is being carried over from the CPRs. The Bill includes powers that would allow the Secretary of State to update this list once the Bill has been enacted. But we believe that the government should go further and explicitly include drip pricing on the face of the Bill as an unfair and therefore banned practice within the schedule to the Bill to take account of the following:

• To ensure consumers can make informed choices, all mandatory charges(both fixed and variable) must be included in a consistent way in the upfront price for a product or service displayed within or across digital services, ie by retailers, platforms and intermediaries.
  • Mandatory fixed charges should be clearly stated upfront, rather than being revealed later in the buying process.
  • Where the exact amount of the mandatory charges cannot be provided upfront, information about how they will be calculated and added to the price must also be clearly and promptly stated. This information must be given in a clear, intelligible, unambiguous and timely manner to allow the total cost to be easily calculated by the average consumer as soon as possible.
• To highlight necessary charges upfront so that consumers are clear that they will be included in the final price. These charges, while not mandatory for all consumers, become unavoidable in specific situations for a significant proportion of consumers. For example, families with young children may pay extra to sit together on a flight, and long-haul travellers often require luggage check-in.

Our survey also highlights the potential harm caused by dripping optional charges for non-essential items or services. These charges, such as for express delivery or additional product suggestions, can make shopping more complicated, increase the total cost, and prevent consumers from comparing prices. To improve this situation, these charges should be:

• Clearly labelled as optional fees for extra benefits and presented after showing the mandatory prices,
• An unselected option by default, requiring a consumer to make an active choice for the extra item or service,
• Displayed early in the transaction so consumers are clear about additional costs.

For all of these charges, clear and unambiguous language should be used whether they are mandatory, necessary or optional. This will enhance transparency and enable customers to better assess their value for money and the service provided by the trader.

As well as updating the list of unfair commercial practices to take account of drip pricing, the government and CMA should produce comprehensive guidance on how these charges should be presented within different scenarios across different sectors.

1. Introduction

It’s Friday night and you’re ordering that well-earned takeaway on your preferred app – only to find, after you’ve made your considered selection, that the bill is a good few pounds higher than you thought thanks to a service fee, as well as the delivery charge. 

You’re booking flights for your longed-for (and long-saved-for) holiday, only to find the deal that you selected from the comparison site is significantly dearer when you add in hold luggage, and make sure you can sit with your travel companions. And finally, you’ve reached the front of the virtual queue to buy tickets for that concert you’re desperate to see – only to find you have to pay a processing fee and an e-ticket charge that makes it even more expensive than you expected.

These are examples of ‘drip pricing’ practices, where the price of a good or service is split into multiple parts, with some parts of the price only being revealed to the customer later in the buying journey. This happens both online and in stores, but can be particularly pernicious online, where elements of the total price are often only revealed as a customer clicks through in a lengthy journey towards a checkout. This experience is a common feature of modern consumer life, with new government research finding that nearly half (46%) of online and mobile app providers included at least one dripped fee, not including delivery charges, as part of their checkout process [5]. We are well used to being tempted by headline prices, only to find extra costs mount before we enter our payment details. Often, having compared prices to begin with and faced with the rigmarole of going through the whole process again with another provider, we acquiesce and pay the extra fees, grumbling as we do so but feeling we’re not likely to do better elsewhere.

Many additional charges are mandatory, with common examples including postage and packaging, delivery charges, handling charges, service fees and booking fees. Such fees may be fixed or variable, depending on other characteristics of the transaction like its value and the location of the customer. Charges for optional extras, such as premium seating, can also be ‘dripped’. While this can provide beneficial flexibility for consumers to tailor purchases to their own tastes [6], it can also make it harder for consumers to shop around and check they are buying the best value package for their needs. In the government’s 2023 study, the average dripped mandatory price was 6% of the base price of the product, while optional dripped fees were, on average, 14% of the base price [7].

Drip pricing leaves consumers facing three types of harm: 

1. Financial harm – when we pay over the odds for goods and services where prices are inflated by untransparent and uncompetitive fees and charges [8]. Consumers can spend more than they intended, get stung by hidden charges, or fail to choose the cheapest option as prices are more difficult to compare. As well as causing harm to individuals paying fees in specific cases, drip pricing can have market-wide effects, as businesses compete on headline pricing rather than total cost [9], undermining price competition. 
2. Psychological harm – the frustration of feeling like we’re being ripped off by these charges, but that we can’t do much about it. 
3. Time harm – if we’re committed to shopping around, and have to go through the same lengthy purchasing journey multiple times with different providers in order to obtain a set of accurate prices to compare. 

Through drip pricing, businesses take advantage of common, well-established behavioural biases. Consumers presented with drip prices are usually anchored by the first, headline price they see and struggle to adjust their decision-making to account for these additional costs [10]. The effort consumers have committed to a purchasing journey before they are able to see the full price can also discourage them from returning to the searching stage and comparing with other providers [11], ultimately rewarding businesses who engage in these practices. While not all businesses using these practices will set out to rip consumers off, and some may simply be following the practices of their competitors, the impact is the same: consumers get a worse deal [12]. The CMA has stated that “drip pricing causes real detriment to consumers” and that it is considered, among a range of other pricing framing practices, “clearly the most harmful frame for consumers in terms of purchasing and search errors [13]."

Under existing UK consumer law, businesses are already expected to provide consumers with clear information about pricing and additional charges upfront, to help us make informed decisions. Failing to do so in a way that could impact a consumer’s decision could be considered a misleading action or omission, and unfair practice, under the Consumer Protection from Unfair Trading Regulations 2008 (“CPRs”). Specifically, the CPRs protect consumers from unfair or misleading trading practices. They prohibit businesses from using misleading tactics, concealing important information (misleading omissions) or using pushy sales tactics. Instead, the regulations require businesses to engage in fair and honest dealings with consumers. They give consumers rights of redress if they have been the victim of misleading actions or aggressive selling. Crucially, the CPRs apply before, during and after a consumer contract is made. Now that the UK has left the EU and the transition period has ended, the CPRs remain in force as part of retained EU law. However, despite this existing law, drip pricing remains widespread, and has been the subject of multiple consumer law enforcement cases, including online hotel booking, [14] car rental intermediaries [15] and airline payment card surcharges [16] (the last in response to a 2011 Which? supercomplaint [17]). This whack-a-mole enforcement of existing legislation has been insufficient to stop the spread of these practices. And in practice, breaches of these general provisions of the CPRs can be hard to establish against traders who are not willing to comply with the law unless pursued in court.

The pressure on household budgets through the cost of living crisis has sharpened scrutiny of drip pricing practices beyond economic regulators, and led to calls for a more holistic intervention to end these harmful pricing practices. Following criticism of drip pricing practices by the Prime Minister in June 2023 [18], the UK government has committed to exploring this issue, and is currently consulting on the potential to update the law through the Digital Markets, Competition and Consumers Bill, currently moving through parliament [19]. The introduction of this landmark Bill will modernise and update the UK’s competition and consumer laws as it supports greater competition, and consumer choice and protection by addressing fundamental short and long-term challenges in the UK economy. The Bill provides an opportunity for the government to bring consumer protection from harmful drip pricing practices into line with other advanced economies, such as Canada, which strengthened consumer protection legislation in 2022 to prohibit all drip pricing where compulsory fees or charges are not included in the upfront price presented to consumers [20]. In the US, President Biden and regulators have also taken steps to eliminate these ‘junk fees.’ [21] Similar action in the UK is likely to be popular, with 85% of respondents who had experienced misleading online practices reporting concern about hidden charges in a 2022 CMA survey [22]. The CMA has also made clear that they would welcome such action, which would facilitate swifter enforcement [23].

1.1 Our new research

 Qualitative research

While our technical understanding of the harm created by drip pricing is well-established, the best route to tackling this harm is less clear given the complexity between fixed and variable charges, and those which are mandatory compared with those which are optional. This paper explores consumer reactions and responses to drip pricing in a range of markets where these practices are common, to gain greater understanding of how consumers experience and feel about drip pricing, and to inform debate about how related harms can best be tackled. 

To explore consumers’ responses to drip pricing in depth, we undertook new qualitative journey mapping research with 31 consumers from diverse backgrounds. Participants were recruited to ensure a mix of gender, age, ethnicity and household structure. Our research covers three markets where drip pricing practices are known to be common: air travel, takeaway food delivery, and event tickets [24].

All participants completed the same basic task, progressing through the online purchasing journey on a laptop or desktop computer for at least two major providers in one of our three markets. Their screens were recorded while they responded to questions aiming to elicit their opinions, thoughts and feelings about the way prices were being presented and the additional fees and charges they were being shown. Participants were asked to choose from a list of providers, which was created based on similarity of business models and market share [25]. These providers, and the breakdown of our sample across markets, is provided in Table 1. In each market, the sample included a mix of consumers who were familiar with the market and those lacking specific experience. 

Table 1: Providers included in research

Ten participants completed this task while taking part in an online depth interview with one of our researchers. They shared their computer screen, which allowed us to ask questions to understand the participant’s experiences and perceptions as they navigated the purchasing journey. This informed the development of a detailed online activity. Participants moved through the same journeys independently and were asked questions about their experience in an online research environment. This included both written questions and recording videos of themselves and their screens while navigating purchasing journeys, narrating their responses to questions. This task was completed by a further 21 participants. All video recordings were transcribed and, together with written response data, thematically analysed to identify recurring themes in how participants responded to drip pricing practices. 

To further contextualise this research exploring consumer perceptions of drip pricing in specific markets, we also explored drip pricing with the Which? Consumer Insight panel, a group of 29 households from across the UK who regularly participate in monthly online tasks and in-depth interviews. Households were asked to reflect on whether or not they believe companies are open about any added charges to purchases such as flight tickets, event tickets and food deliveries. Following this they were asked to explain why they feel companies may act in these ways.

Quantitative research

To supplement these qualitative insights and obtain a wider population view on drip pricing among consumers, we ran a short online poll conducted by Yonder on behalf of Which? with 2,074 consumers, weighted to be nationally representative of UK adults. We explored their attitudes towards drip pricing and their reactions to examples of the practice. We excluded those who never shop online from the base for most questions, which accounted for only 2% of consumers. See the methodological note at the end of this report for full details on the survey.

1.2 Report structure

The next chapter of this report presents the findings of our new research, identifying four key characteristics which influence consumer responses to drip pricing, and which could inform the design of regulation of these practices. 

Chapter 3 presents our policy recommendations for how these practices should be dealt with. 

2. What’s the harm? Exploring consumer responses to drip pricing

At a headline level, consumers have a strong, decidedly unfavourable reaction to drip pricing. In our online survey, we asked respondents what they thought about the mandatory and optional charges associated with drip pricing. An overwhelming majority – nearly nine in ten online shoppers (88%) – expressed their annoyance with these charges, while an equally substantial portion (86%) said they are “sneaky”. Meanwhile, only one in ten (10%) agreed that these charges could be considered fair. It’s safe to say that the general sentiment toward drip pricing is far from positive. 

Figure 1: The vast majority of consumers had a negative view of these charges, with only a small minority thinking they are fair

Whilst in our qualitative research, when asked if they felt businesses were open about their added charges, research participants responded with clear frustration.

 “I don’t think they are trying to be very transparent. Rather, they try to pull a fast one”

Consumer Insight Panel Respondent​​​​

“I think they hide their charges and add ons or it’s in the small print.”

Consumer Insight Panel Respondent

“Often things are advertised as a set price but once through to delivery it fees, handling fees etc then the price creeps up and it isn’t such a great deal after all.”

Consumer Insight Panel Respondent

Research participants recognised the ways in which drip pricing makes it harder to get a good deal. Some specifically noted the anchoring effect of lower headline prices. 

“It definitely draws your eye when something is promoted online as a great flash deal. Then by luring the customers in to add something to their basket, the additional charges are often hidden.”

Consumer Insight Panel Respondent

“They make it appealing for the prices etc and offers but take part of it back in the hidden charges.”

Consumer Insight Panel Respondent

“Companies will always try to entice you in with the cut back basic price, but to get the item or package that suits you will always cost a bit more.”

Consumer Insight Panel Respondent

Others recognised how the time taken to navigate a purchasing journey can leave them disinclined to shop around when the final price becomes apparent – a demonstration of loss aversion and the sunk-cost fallacy. Participants recognised how website design and the decomposition of the purchasing process left them reluctant to go back and compare with another provider. 

“It can be quite wearing, it can be tiring … Each screen does slow down the booking process and you get to the end and think ‘oh let’s just get this ticket’”

Rachel, Flight Tickets

“If I spend 4 or 5 minutes ordering my food on one app, then that could be 20 minutes comparing between the different sites”

Amir, Takeaway Food

Respondents also recognised how drip pricing interacts with other features of online choice architecture, such as countdown timers, which aggravate pressures to simply accept the additional charges as they are presented, rather than shopping elsewhere. This was particularly the case for one participant with a visual impairment, who found navigating websites with a screen reader took longer, suggesting these practices may particularly disadvantage certain groups of consumers.

“From an accessibility standpoint it is quite annoying having a timer. If the website isn’t very accessible then it will take longer to get around it which means you’re then trying to rush to choose something and end up choosing something you may not have done normally had you had more time”

Serena, Event Tickets 

Participants in our research repeatedly ascribed these extra charges and the design of drip pricing practices to businesses trying to maximise profits, often attributing malign motives to businesses and suggesting that they were deliberately confusing or manipulating customers.

“[Their websites are] designed to exasperate and designed to confuse. When you’ve compared two or three companies … you’ll be tired and just want to book it”

Oscar, Flight Tickets

“Money, profit. To squeeze as much out of [customers] as possible.”

Consumer Insight Panel Respondent

“Make as much profit as possible”

Consumer Insight Panel Respondent

“To trick customers into paying these added charges”

Consumer Insight Panel Respondent

However, while consumers are generally cynical about drip pricing, designing appropriate regulation is not entirely straightforward, particularly when it comes to variable fees, which are not finalised until total basket size is known, and optional fees, where the consumer needs to make a decision about their preferences. 

Our detailed exploration of how consumers react to specific elements of drip pricing practices, and the factors that influence how consumers respond to these practices, aims to inform decisions about the optimal scope of regulation. 

Through this analysis we identified four core characteristics of additional charges that influence consumer feeling towards drip pricing:

1. The extent to which consumers expect the charge (expectations)
2. Whether consumers understand the charge (understanding)
3. Perceptions of value for money
4. Perceptions of choice over paying the charge

These four characteristics interact to affect consumers’ overall perceptions of and reactions to drip pricing within a specific transaction. More detail is provided on each characteristic, and its impact on consumers’ response to drip pricing, in turn, through the remainder of this chapter. 

2.1 Expectations 

Consumers were most frustrated when their basket included charges that they did not expect, and which had not been flagged early on in the shopping journey.

When participants expected an additional charge, and had a clear expectation of how much that charge would be, they tended to react more positively to the charge. This suggests that the issue for consumers is not the principle of added charges, but the lack of transparency and upfront information about them which prevents consumers from anticipating total costs and making full comparisons. In our survey, four in five (81%) online shoppers thought that fees are more acceptable if they are shown upfront in the buying process.

 “I always expect additional costs but I don’t think it’s fair to the consumer. Because you might not go on to look for other options thinking you have already found the best deal. But when you get to the checkout it might be too much for you then you might regret not taking the other option you saw earlier”

Leila, Event Tickets

“It’s just very very annoying … I’ve gone through all the process of ordering and then they’ve added these extra fees which has annoyed me so much that I would want to cancel that order. But then I’ve got to have to go back and start again with somebody else” 

Elizabeth, Takeaway Food

There were three common ways participants learned to expect a charge:

Clear inclusion of obligatory fees within the basket or within the price of the product early in the purchase journey;

Clear signposting that obligatory fees would be charged (with or without the amount) early in the purchase but where the charge is not included in the basket until later in the purchase; or,

Where there is no inclusion or signposting but the consumer knows to expect added charges through prior experience with the website, product or from similar products.

Participants in the research may also have been primed to expect charges because we asked about this as they progressed through the journey, particularly in the online task, although care was taken not to frame the exercise in advance as being about drip prices specifically. Nevertheless, differences in expectations were still noticeable in the sample, particularly where participants were navigating a market they were not previously familiar with.

Image 1: Takeaway food desktop website displaying all fees as items are added to the basket

Image 1 illustrates an interface where fees are visible in real time as the basket is constructed. One of our participants specifically praised this clear, up front representation of fees:

“I think it’s pretty clear, they show you on the right hand side at all times how much it will be”

Joshua, Takeaway Food

Image 2: a small banner displaying that a handling fee of £2.85 will be added to the basket at checkout

Image 2 shows an alternative approach, with a banner on the page used to inform users of additional fees. Another participant exposed to this banner noticed it, and suggested it was sufficient to help her know what to expect.

“I was expecting the handling fee”

Leila, Event Ticket

Image 3: The event ticket site gives a small warning that handling and delivery fees may apply

By contrast, this small warning in Image 3 was not spotted by another participant, who subsequently didn’t expect the fees, and voiced a sense that the charges were unfair as a result.

“I wasn’t expecting these. I don’t think it’s very fair as the website hasn’t warned me at any point in time that they are going to be adding these fees”

Lewis, Event Tickets

Across all the markets we tested, most participants indicated that they preferred situations where the fees were included in the basket or in the price of the product early, meaning they knew how much extra they were going to spend. For example, Ben was satisfied with the charges, describing them as “fair” because from the start, the event he had chosen included all additional charges and these were clearly displayed. Similarly, Serena said she appreciated it when some of the fees were included within the initial price.

“The added fees were advertised with the ticket, there’s nothing you weren’t expecting … they seem to be very open”

​​​​Ben, Event Ticket

“I do appreciate that the booking fee was included within the headline price”

Serena, Event Ticket

Other participants who didn’t see the cost of the charges before the checkout, expressed a clear preference for charges being advertised early in the purchasing journey. 

“I would very much prefer it if I saw the full ticket price up front”

Dan, Event Ticket

“I think they should make the charges clearer every step of the way”

Zainab, Event Tickets

“These hidden extras should be made clear [from the start], not just when you get a shock at the end. It would make me think about who I order with”

Ada, Takeaway Food

Where precise fees could not be detailed up front, any communication that helped a consumer know to expect a charge was preferred to having none at all. Where participants did not know of or did not expect a charge at all, they described feeling “shocked” and were often annoyed by its inclusion. This happened often when a ‘small order charge’ appeared on the takeaway delivery websites we tested, where it was not clear to many of the participants before they began adding items that a minimum order value was required to avoid an additional charge.

“I’m shocked at the small order fee, I didn’t know this was something they charged for… I don’t think they are being open because there is nothing stated as you’re making the purchase… The delivery fee I’m not surprised about because you know you have to pay for delivery”

Sadie, Takeaway Food

“I would not have chosen [takeaway delivery platform] because [of] the small order fee which was completely unexpected. I think adding that is very mean”

Elizabeth, Takeaway Food

“I think they should give you some kind of warning that the small order charge before you go to the checkout”

Samantha, Takeaway Food

Some also expressed a similar feeling of frustration when they experienced unexpected event ticket charges. Leila, for example, was confused when a handling fee was flagged before the checkout, but a service charge was not, while Lewis would have liked a simple disclaimer at a minimum. 

“I was expecting the handling charge but not the service charge, I’m a bit confused by the service charge. It would have been better if they told you about it on the page before the checkout”

Leila, Event Ticket

“I think it’s almost false advertising if you show an event to be one price and then when you come to pay it’s a different price”

Ben, Event Ticket

“No, I didn’t expect them at all. I don’t think they are fair and I don’t think the website informed me that there would be these random fees before I got to the checkout. It really should say a little disclaimer somewhere that these fees may be applied”

Lewis, Event Ticket

“It would have been more fair to know about the £3.75 extra cost at the very start but I decided to pay anyway”

Melissa, Event ticket

2.2 Understanding 

Consumers frequently did not understand, or misunderstood, what additional fees were for, leading to frustration and a sense that additional charges are arbitrary. 

Participants in our research frequently expressed confusion about what the additional fees they were being charged were for. This led to frustration, and a perception that fees were “arbitrary” and unfair.

For consumers to make a decision about whether or not a fee represents fair value, they have to understand what they are paying for. However, the sellers we looked at varied in how much information explaining the charges was offered to consumers, and how clear the participants found this information. Some websites did not explain charges at all. As a result participants were sometimes in the dark about what the fees were for.

This was clearly visible in our event tickets examples, where many participants expressed a lack of clarity about what the fees being charged were meant to cover. 

“I have to pay £10 for something but I am not sure what it would involve”

​Lewis, Event tickets

“I didn’t get an [explanation] of what that fee meant. What it included or why it was there. So, I don’t think it was clear at all”

Elliot, Event Tickets​​​​

“It’s called a booking fee so I guess it must be some kind of service fee for the theatre. I think it must go to the performers and the venue in some way”

Serena, Event Ticket

Online shoppers in our survey were also unsure about the justification for these charges. When shown an example of drip pricing for event ticketing, the plurality (48%) did not think it was clear what the charges were for.

In the takeaway example, similar confusion was observed around the service charge. Participants made assumptions about this, sometimes drawing on their experiences of restaurant dining, to assume this was a payment to the staff of the food provider.

“I’m not exactly sure but I believe the service charge is some sort of tip for the workers at McDonald’s”

Amir, Takeaway food

 “I assume the service charge goes to the restaurant, but I might be wrong”

Samantha, Takeaway Food

 “I suppose the service charge goes to the people in the McDonald’s”

Elizabeth, Takeaway Food

​In reality, across all the platforms tested, the service fee is paid to the platform itself.

 This lack of clarity about what fees are for led to frustration, and a perception that businesses were purposefully obscuring what consumers were paying for in an attempt to rip them off. 

“What on earth is a service fee?”

Max, Takeaway Food

“They could give me an box to find out more information but then they’d have to justify what the charge is for so they’re probably not going to do that”

Lewis, Event Tickets

“Service charge is £1.05 which seems reasonable though I’m not really sure why I am paying that – it seems like it’s an additional charge just to increase the amount I am going to spend”

Nathan, Takeaway Food

This confusion was particularly notable where multiple separate fees were levied on a transaction, often drawing out the participant’s lack of clarity about the destination and justification for different fees. 

Image 4: Food delivery checkout showing a small order, service and delivery fee

“They do not explain why there’s both a small order fee and a service charge. Where do these two go? Understanding what they go to would make it less confusing”

Lauren, Takeaway Food

Image 5: Event tickets checkout showing a service charge, facility charge and handling fee

“It’s confusing because I would say this [handling fee] is the same as that [service charge] and these [ per item fees] are the same as that [order processing fees], it’s a bit misleading and I find that confusing … they are adding arbitrary things just so they can add fees on”

Lewis, Event Ticket

This perception that multiple fees were duplicative due to a lack of clarity about their purpose, destination and justification, sparked further frustration among participants, and a sense that businesses were using fees to extract money from them. Lack of appropriate information about fees may also influence customer behaviour, leading to suboptimal outcomes. If consumers are misinformed about where their money is going, and who they are paying, they may be unknowingly paying some companies when they believe they are paying another, giving a false representation of value which may influence consumer decision making. For instance, if consumers had better information about fees, they may decide to use a different platform with lower or a different arrangement of fees, strengthening competition or they may make different decisions about optional charges, such as tips. 

“I think a service charge is fair because if you’re not going to tip for the deliveries then a service charge is quite normal”

Maryam, Takeaway Food

By contrast, where participants understood the fees, either because the charge was intuitive, such as delivery fees or paying for extra leg room, or because they were clearly explained, they often responded better to the charge.

“I liked [website] the most because it told you exactly what the fees were at every stage and it explained what they would cover.”

Zainab, Event Tickets

“[Event ticketing platform] actually explained that they add the booking fee because they need to make a profit, which is fair enough”

Ben, Event Tickets

2.3 Perception of value for money

Consumers are frustrated when charges are levied for services that do not appear to add value, or require additional effort or cost from the business, and when fees are high either individually or as a proportion of the total price. 

Participants’ perceptions of whether charges represented value for money reflected two factors: whether they felt there was genuine value being provided in exchange for the charge,  and whether the level of that charge was felt to be appropriate. Participants assessed value for money both at the level of individual fees, and relative to the total cost of the transaction. 

2.3.1 Does the fee represent added value? 

Where the service that was being paid for through the charge was easily understood and the added value was clear, participants were often happy to pay. This was frequently the case, for example, with delivery fees for takeaways. 

“With the delivery I’m not really surprised about because of course you know you have to pay for delivery.”

Sadie, Takeaway Food

“Obviously, I understand that a delivery charge should be included”

Dimitris, Takeaway Food

“I think we should only be paying a delivery charge. You don’t expect to get stuff delivered to you for free, we all appreciate that it does cost money to deliver the food”

Nathan, Takeaway Food

This was also the case for optional add-ons to flights, for example luggage and extra leg room. In our survey, two-thirds (67%) of online shoppers agreed that optional extra charges are more acceptable compared to mandatory ones. Participants from the qualitative study explained how they understood these would add costs for the airline, meaning the fee felt justified. 

“I am absolutely fine with [paying for] extras, especially baggage … it all adds to the petrol”

Rachel, Flight Tickets

“I get it for extra leg room as they are a premium and there’s not many of them”

Oscar, Flight Tickets

“Yeah I can understand that if you have heavier luggage then you would pay extra and I think that’s perfectly fair”

Kieron, Flight Tickets

By contrast, where the service nominally being charged for was felt to be integral to the standard fulfilment of the transaction, or the added value was obscure, participants expressed greater dissatisfaction with additional fees. E-ticket handling charges caused considerable consternation among participants, with these fees particularly likely to be described as unfair because the seller ‘wasn’t doing anything’ or ‘just sending an email’. 

Image 5: Checkout with an e-ticket charge

“It’s strange that they would charge you a delivery fee when there’s no human involvement. I’m the one who has done the work”

Harry, Event Tickets

“You have to pay for an e-ticket? You didn’t have to pay for that with [alternative event ticket provider]”

Zainab, Event Tickets

“No idea why a fee for an e-ticket exists. Seems unreasonable to charge £2.75 for sending an email”

Serena, Event Ticket

2.3.2 Does the level of the charge reflect the added value? 

When consumers perceive the charge as adding clear value to their purchase, they may still be unhappy with the amount charged, disputing the level of the fee, if not its existence. Respondents were more likely to see optional extra charges for seats and luggage on airlines as fair compared to mandatory charges on event ticketing (16% vs 7%). However, when it comes to these airline charges, the vast majority (81%) of them think they are too high.

When individual charges, or the total of all charges, felt too high, this was often the first thing the participants we spoke to pointed out. Some, through experience with similar websites or with buying the product, had a sense of what was and was not a fair level for a particular charge. Others reacted to the difference in the level of charges between the websites we asked them to visit. 

“£14 for a seat is a rip off. They are twice as expensive as the other website”

Aleksander, Flight Tickets

“The price has gone up by about £50 or so, which is quite a lot when you consider the flights. It’s around 25% of the total or more”

​Jim, Flight Tickets

“That is ridiculous. £3.50 delivery and 99p service charge on a £7 order. I did not expect these fees given the cost of the order. They’re not fair, it’s half the total cost for delivery… Three different charges for a meal of £7, it’s unbelievable really”

Max, Takeaway Food

Some participants recognised that while some individual fees may be small initially,  they can add up if they were due to be applied multiple times or are part of a bundle of charges. One prominent example is where charges were levied per-ticket, rather than per-transaction, meaning if you were buying multiple tickets they can add up significantly. Another example was flights, where charges applied per person and/or per leg of the flight, can add up quickly for a family with return flights.

“I’m ok with £7 per seat if going one way, but it gets much more expensive if you have a return flight and there’s three of you. Then £6.99 becomes £21 one way and £42 for return which is much more expensive.”

Aleksander, Flight ticket

2.4 Choice

Our research demonstrated how drip pricing deadens competition, with consumers reporting that they didn’t think it was worth shopping around as fees would be the same across platforms. In some cases, consumers were also confused about the extent to which additional fees were optional, potentially meaning consumers are paying for extras they do not need. 

Participants’ perceptions of whether they had a choice in paying dripped fees and charges depended on two factors – the prevalence of such charges across the market, and to what extent they truly had a choice over whether to buy ‘optional’ extras. Where consumers believe that all sellers have similar levels of dripped charges, or that they effectively have to pay additional charges to use a product or service, this deadens the notion of choice, but with differing implications. A perception that there’s no real choice in paying mandatory fees makes consumers, begrudgingly, accept them, reducing propensity to shop around and limiting competitive pressure. A sense that prices are being raised by charging separately for additional services which are not truly optional, by contrast, caused significant frustration among participants, and was perceived as unfair. 

2.4.1 Cross-market prevalence of mandatory fees 

We found that participants assumed additional fees would be similar across providers, particularly for event tickets and takeaway food, and that additional charges were not sufficient to motivate consumers to want to shop around. 

“I presume they [food delivery platforms] are all the same. Sometimes they have different food or are easier to navigate but that’s it”

Elizabeth, Takeaway Food

“In terms of fees I think all the ticketing websites would probably be the same”

Dan, Event Tickets

Participants exploring flight purchasing journeys showed a somewhat higher propensity to think fees differed across providers, which probably does reflect the reality of this market where airlines compete with different bundles. However, we cannot be clear that this will lead to more shopping around in practice, particularly given that the purchasing journey for flights is typically longer than for food delivery or event tickets, which would lead us to believe sunk costs and anchoring have particular power. 

Across all markets, it was clear that other factors mattered more to participants in determining their choice of provider than dripped fees and charges. Some participants expressed a preference for a particular provider, usually on the basis of inherent characteristics such as ease of use or due to habit. 

“I prefer premium airlines like [example airlines]. The experience is easier and I know I get things like baggage included. I don’t like to travel light”

Anna, Flight Tickets

“With [food delivery platform] there’s often better offers to get free delivery, but the main reason is ease of use. I’m also loyal to [food delivery platform] as I have been using them for a long time”

Amir, Takeaway Food

“I have always used [event ticket platform] because that’s the first I heard of when I was a teenager … and in terms of fees I think they are probably the same as the others to be honest”

Dan, Event Tickets

This suggests that competitive pressure on additional fees and charges is low, creating space for businesses to increase markups. This lack of perceived choice around whether to pay additional fees across the market leads to a reluctant acceptance of drip pricing, but may inform the general perception among consumers that such pricing is a ‘rip-off’ as illustrated earlier in the chapter. 

2.4.2. Are added-extras really optional? 

In our food delivery and event ticketing purchasing journeys, additional fees were mandatory. The market for flights, by contrast, is defined by a high range of optional charge for items such as luggage, additional legroom, and allocated seats with your travel companions. In some cases, it was not always clear to participants whether fees were optional or mandatory, leading to a situation where some consumers do not understand they have a choice, and could pay over the odds.

Across airlines included in the study, we regularly found that participants mistakenly believed that a seat selection charge was mandatory, when in fact it was optional.

“It seems to me that the seat is an additional charge, the seat doesn’t seem included. I’m reading this as the original price is the flight of the plane and then you have to pay for your seat”

Rachel, Flight Tickets

While information explaining that this was not the case was available on each airline’s website, most participants in our research did not spot this as they passed through the buying journey. This is an example of potentially deceptive online choice architecture, where the way a choice is presented to a consumer leads them to behave in certain ways – in this case, to pay for a seat when they do not need to do so. Participants felt this was unfair. 

Further complexity arose when we asked participants to ensure they could sit with a travel companion as part of the exercise. Airlines consistently charge passengers an additional, optional fee to sit together. This fee often represents poor value for money, with recent Which? research finding that many airlines frequently seat passengers together even when they do not pay this charge: for all three of the airlines included in this research, the rate was 90% or over [26]. However, participants in our research were not aware of this and all chose to pay for seats next to their companion. Again, participants felt this was unfair. 

“[The airline] charges you to be able to book seats together… it’s unfair but you’re doing it anyway”

Amber, Flight Tickets

“I don’t see why I should select to sit together, I should be allocated together if I book together”

Mahmoud, Flight Tickets

Where participants were considering travelling with children, these charges felt even more unfair, with even participants who understood these charges to be notionally optional feeling they didn’t really reflect a true choice; they had to sit next to their child. While airlines do have policies setting out their approach to seating families, none of our participants located this information as they navigated the booking journey.

“They do not say whether or not you are assigned a seat next to the child… I have a child and I cannot imagine not knowing whether I am sitting with my child or not”

Aleksander, Flight tickets

“In this instance I am booking for me and a child and it seems unfair to have to pay to have us sat together, rather than the assumption that you’d want to travel with the child”

Kieron, Flight tickets

“You can’t take the risk that you won’t be sat with your child”

Oscar, Flight Ticket

If participants had located the relevant information on the airlines websites, in some cases they would have found that this charge may effectively be mandatory, if the airline does not automatically seat children with parents, but requires parents to be in charge of children at all times.

While only one example, this illustrates how choice around ‘optional’ charges is not always binary, and how the degree to which a consumer really has, or perceives that they have, a choice about whether to incur the fee, affects their perception of its fairness. 

2.5 Summarising the harms 

Our detailed exploration of how consumers experience drip pricing in online purchasing journeys in three key sectors has highlighted four factors which drive consumer frustration, and weaken competition leading to negative outcomes: 

• Participants were most frustrated when their basket included charges that they did not expect, and which had not been flagged early on in the shopping journey.
• Participants frequently did not understand, or misunderstood, what additional fees were for, leading to frustration and a sense that additional charges are arbitrary. 
• Participants were frustrated when charges offered poor value for money: either when they were levied for services that do not appear to add value to the consumer, or when fees were high individually or as a proportion of the total price. 
• Participants reported feeling that they lacked choice over whether to pay fees, either because fees were perceived to be largely the same across the market, or because the way choices were presented (particularly by airlines) made optional purchases seem mandatory. 

2.6 What consumers want to happen

Our research participants freely shared their thoughts about what would help to alleviate the frustrations, confusion and financial harm which result from drip pricing, and specifically the four factors identified above. Participants asked for three things: 

1. Inclusion of added charges within the headline price, where possible or very  clear signalling at a minimum (for example, where fees vary with transaction size);
2. A clear explanation of what additional fees and charges are paying for; and
3. Simpler charges which are combined wherever possible.

First, consumers regularly stated that added charges should be included within the price or at a minimum signalled as early as possible, and that all costs and signals should be clear.

“I think making the fees more obvious and having clearer instruction that there will be these fees added would make it less confusing for me, instead of it being last minute”

Sadie, Takeaway Food

“Priority for me would be to communicate the fees upfront and be clear with them”

Serena, Event Tickets

“They should just have the total cost… just this ‘this is the ticket price and it covers everything’

Elliot, Event Tickets

Second, where additional fees are payable, a clear explanation should be provided as to what this is for, and whether it is mandatory or optional. 

“I’d like the fees to be a little more clear as to what they are. If you’re paying for something it would be good to know exactly what that is. It seems easy for the sites to throw in a fee and give it a random title and you agree to pay for it because the site says you have to pay for it”

Kieron Flight Tickets

“If we make it a legal obligation for these companies to disclose exactly why they are adding these costs and what these costs do then consumers may have a little more understanding of them”

Lewis, Event Tickets

Third, additional charges should be simplified and combined where possible, to make it easier for consumers to compare charges. Eight in ten (80%) of online shoppers surveyed thought that mandatory fees should be included in the original price of the product or service.

“If I do a job for someone they just want to know the final price, they don’t need it itemised – just tell me what the total cost will be”

Harry, Event Ticket

3. Conclusions and recommendations

Although new and emerging online markets offer many benefits, the increased reliance on online services, accelerated by the Covid pandemic, means that consumers are even more exposed and vulnerable to the drawbacks that these online markets bring.

Our research provides further evidence that drip pricing practices used by online markets can cause multiple harms to consumers. We have found consumers experience frustration due to unexpected charges and that they frequently misunderstand the nature of such charges. Our survey describes consumers having trouble in assessing whether a charge is optional or mandatory; and they can struggle to determine whether a good or a service represents value for money. Ultimately, these frustrations, confusion, and misunderstandings are causing consumers to pay more than necessary for products and services and experience inertia in seeking alternatives. 

Our findings demonstrate that drip pricing remains common practice across multiple sectors and that current regulation remains inadequate to fully protect consumers from these harms. For example, when additional fees and charges are not optional, it is likely that they are required under the CPRs [27] to be signalled to the consumer from the outset, so that consumers can make an informed decision before completing the transaction. However, our research illustrates that this is not always happening in practice. It follows that such online harms are not currently covered by the same protections as their offline equivalents, and consumers remain vulnerable to these new and evolving digital threats which are difficult to tackle within the current legal framework. 

A recent CMA study identified drip pricing practices as a particular category of ‘misleading dark patterns’ which include behavioural techniques and choice architectures that can manipulate consumers enough to distort their choice and distract them from their original and real intention when visiting the internet [28] As this report demonstrates, drip pricing practices are impacting on consumers’ transactional decisions online. This not only harms consumers in a tangible and immediate way but also distorts the market by introducing unfair competition for those businesses which do not use these tactics to lure consumers into making purchases.

In order to better protect consumers from the harms of drip pricing there needs to be a dual pronged approach with both some radical reforms to law and better industry guidance, to add clarity for businesses and enable effective enforcement.

Action needed

The DMCC Bill provides a vehicle to urgently address these harmful practices and the Department for Business and Trade (DBT) is currently consulting on how to deal with drip pricing, as part of a wider consultation on improving price transparency for consumers [29].

As currently drafted, the Bill includes a schedule of commercial practices which are considered in all circumstances to be unfair (Schedule 18) which is being carried over from the CPRs. The Bill includes powers that would allow the Secretary of State to update this list once the Bill has been enacted. But the government should go further and explicitly include drip pricing as an unfair and therefore banned practice within the schedule on the face of the Bill,  along with other practices that have emerged in recent years and which cannot be adequately dealt with under existing law, such as fake reviews. Changes to the schedule should be made to address the following: 

Mandatory charges

First and foremost, in line with the findings of our research, legislation must be updated to prevent the dripping of mandatory charges. Here, mandatory dripped charges refer to those which a consumer must pay, but are not included in the base price. These charges can be divided into two subcategories: mandatory fixed and mandatory variable charges [30].

• Mandatory fixed charges are fixed charges such as non-optional administration fees, set cover charges, and airport landing charges. These mandatory fixed charges must be included in the upfront price for a product or service.
• Mandatory variable charges are charges which vary in accordance with the consumer’s choice or circumstance. Examples of these include a delivery fee that varies by an item’s weight or the distance to the delivery point, or the cost of an insurance product that varies based on the age of the insured individual. These mandatory variable charges must also be included in the upfront price because the consumer is obliged to pay for them. However, the way that these prices are displayed to consumers will be different from mandatory fixed charges. Businesses should alert consumers to the variable charge at the outset. Businesses should give information about how the variable charge will be calculated in a clear, intelligible, unambiguous and timely manner while still allowing the total cost to be easily and readily calculated by the average consumer as soon as possible [31]. For example, a website selling goods that require postage should clearly display up front the factors that contribute to variations in postage costs, such as weight or delivery location. Similarly a website selling insurance should be transparent about the factors that could result in a higher price, such as the age of the insured or the location requiring cover (eg postcode, region, country).

Necessary, but not mandatory charges

Our research also highlights a further category of ‘necessary charges’. These refer to those charges which are not technically mandatory for all consumers in order to purchase a good or service, but unavoidable for a significant proportion of consumers. For instance, families with young children may pay extra to sit together on a flight, or travellers on long haul flights are likely to need to check in luggage. These must also be clearly communicated to consumers up front in the transaction process. The identification and treatment of necessary fees may require guidance from sector specific regulatory authorities.

Optional charges

Our survey also confirms the potential harm created by the dripping of optional charges for unnecessary goods or services where they contribute to raising the transaction cost (ie the time spent arriving at checkout) preventing the consumer from shopping around or confusing the consumer into believing they are mandatory. Retailers, platforms and intermediaries should simplify optional charges by making efforts to ensure:

• Optional charges are clearly labelled as fees for additional benefits, not essential for the basic use of a product or service; 
• Optional charges should only be presented after the mandatory and necessary prices have been clearly established;
• Any optional charges shown should be presented as deselected options (requiring a consumer to make an active choice for the extra item or service to be included in their purchase); and
• Their presentation should be undertaken in a timely manner upfront in the transaction so that consumers are clear that additional charges will be applied and what these are expected to be.

Enhancing transparency

Our research demonstrates that the wording used to itemise charges can be ambiguous and so there is also a general need to clarify the meaning of any extra charges for consumers – whether they are mandatory, necessary or genuinely optional. We found, for example, that the use of ‘service charges’ often confused consumers, as they can mistake these fees from intermediaries for charges imposed by retailers. Therefore efforts must be made to clarify the meaning of charges and their purpose up front. Consistency of presentation across different platforms and, to the extent possible, channels, will also be important to help consumers easily compare. This will enhance transparency and enable customers to better assess their value for money and the service provided by the trader.

Proposed banned commercial practice

The list of banned practices in the DMCC Bill should therefore be expanded to explicitly include drip pricing practices. It should therefore be a criminal offence for a trader to, at any stage of a purchase process, present a price for a product which omits mandatory (or not genuinely optional) fixed charges, or fail to give information about variable charges and how they will be calculated in a clear, intelligible, unambiguous way. This would go some way to removing the consumer harms identified by our report, and the government would also mirror other countries that have introduced similar regulatory principles [32]. This action would also be in line with the CMA’s work which has found its enforcement against drip pricing has been inhibited by the absence of an explicit ban on these practices.

As well as updating the list of unfair commercial practices to address drip pricing, the government and CMA should produce comprehensive guidance on how these charges should be presented within different scenarios across different sectors.  

Footnotes

[1] BIES research (2022), Consumer Protection Study 2022: Understanding the impacts and resolution of consumer problems  ↑

[2] ONS (2023), Internet sales as a percentage of total retail sales (ratio) (%)  ↑

[3] In particular, Regulation 5 – Giving false information to, or deceiving, consumers (misleading actions) and Regulation 6 – Giving insufficient information to consumers (misleading omissions) of the CPRs could deal with aspects of the misleading practices observed during drip pricing  ↑

[4] For example, that a drip pricing practice alleged to be a misleading action prohibited by Regulation 5 of the CPRs causes or is likely to cause the average consumer to take a transactional decision they would not have taken otherwise  ↑

[5] Department for Business & Trade (2023). Smarter Regulation: Consultation on Improving Price Transparency and Product Information for Consumers  ↑

[6] Office of Fair Trading (2010) Advertising of Prices  ↑

[7] Department for Business & Trade (2023). Smarter Regulation: Consultation on Improving Price Transparency and Product Information for Consumers  ↑

[8] Ahmetoglu, G., Furnham, A. and Fagan, P.(2014) Pricing practice: A critical review of their effects on consumer perceptions and behaviour. Journal of Retailing and Customer Services 21(5): 696–707  ↑

[9] Gabaix, X., and Laibson, D. (2006). Shrouded attributes, consumer myopia, and information suppression in competitive markets. The Quarterly Journal of Economics, 121(2): 505–540  ↑

[10] ‘Anchoring’ is a common behavioural bias whereby judgements are disproportionately influenced by initially presented values, with insufficient adjustments made for information made available later in the process. Tversky, A. and Kahneman, D. (1974) Judgement under Uncertainty: Heuristics and Biases. Science 185(4157): 1124–1131  ↑

[11] This is an example of the ‘sunk cost fallacy’, a common behavioural bias whereby people are reluctant to abandon a course of action once they have invested in it, even if overall doing so would be expected to reduce total costs. Arkes, H.R. and Blumer, C. (1985) The psychology of sunk cost. Organizational Behavior and Human Decision Processes 35(1): 124–140. Loss aversion may also play a role here, with consumers who have ventured through the purchasing journey to checkout feeling a sense of ownership of the product or service, meaning they would experience deciding not to purchase as a loss. Kahneman, D. and Tversky, A. (1979) Prospect Theory: An Analysis of Decision under Risk. Econometrica 47(2): 263–292  ↑

[12] Department for Business, Energy and Industrial Strategy (2021) Reforming competition and consumer policy  ↑

[13] Competition and Markets Authority (2021) Reforming Competition and Consumer Policy: Delivering growth and delivering markets that work for consumers, p.44  ↑

[14] Gov.UK (2017) Competition and Markets Authority consumer enforcement case: Online Hotel Booking  ↑

[15] Gov.UK (2017) Competition and Markets Authority consumer enforcement case: Car rental intermediaries  ↑

[16] Gov.UK (2012) Office of Fair Trading consumer enforcement case: Airlines: payment cardsurcharges investigation  ↑

[17] Which? (2011) Super-complaint: credit and debit surcharges  ↑

[18] Smyth, C. (2023) Airline hand luggage fees could be banned. The Times, Saturday 10 June 2023  ↑

[19] Department for Business & Trade (2023). Smarter Regulation: Consultation on Improving Price Transparency and Product Information for Consumers  ↑

[20] Mahbubani, R. and Dufour, E. (2022) Drip pricing practices prohibited under Canada’s Competition Act. Miller Thomson  ↑

[21] Deese, B., Mahoney, N. and Wu, T. (2022) The President’s Initiative on Junk Fees and Related Pricing Practices. The White House  ↑

[22] Gov.uk (2022) 7 out of 10 people have experienced potential rip-offs online, worrying new CMA research reveals  ↑

[23] Competition and Markets Authority (2021) Reforming Competition and Consumer Policy: Driving growth and delivering competitive markets that work for consumers  ↑

[24] Which? research has previously explored issues around drip pricing in each of these markets. For further details, see: Which? (2023) Why airline seat selection is a waste of money. Which? (2021) The hidden costs of the food delivery revolution: the surprising premium added to your next takeaway  ↑

[25] Design decisions were also made to exclude certain websites with larger market share due to their business model being significantly different to others. For instance with event ticketing websites we decided to not include ticketing sites that primarily host ticket resellers as fees can vary significantly platforms primarily offering primary sales  ↑

[26] Which? (2023) Why airline seat selection is a waste of money  ↑

[27] In particular, Regulation 5 – Giving false information to, or deceiving, consumers (misleading actions) and Regulation 6 – Giving insufficient information to consumers (misleading omissions) of the CPRs could deal with aspects of the misleading practices observed during drip pricing  ↑

[28] CMA (2022) Online Choice Architecture How digital design can harm competition and consumers  ↑

[29] Consultation on Improving Price Transparency and Product Information for Consumers,Department for Business and Trade, 4 September 2023  ↑

[30] DBT Consultation (2023) Smarter regulation: improving price transparency and product information for consumers  ↑

[31] Chartered Trading Standards Institute (2018) Guidance for traders on pricing practices  ↑

[32] Canada recently prohibited some drip pricing activities under its recent Competition Act and the Junk Fee Prevention Act has recently been proposed in the USA. The Canadian legislation is already being tested in court in an application against a major cinema chain due to be heard in early 2024  ↑

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