Customer reviews on an online shop in France: the mandatory information

Who is covered

The obligation applies to any natural or legal person whose activity consists, as a main or ancillary activity, of collecting, moderating or publishing online reviews from consumers. That person must provide fair, clear and transparent information on how these reviews are published and processed. C. conso L. 111-7-2 The references “C. conso” in this guide are to the French Consumer Code.

An online review is the expression of a consumer's opinion on their consumer experience, whether qualitative or quantitative: a rating on its own counts. The author does not need to have bought the product. Sponsorships, recommendations and expert reviews are not online reviews within the meaning of the text. C. conso D. 111-9

Using a third-party review service does not exempt you from the information requirement. The European Commission states that the obligation also applies to a trader that showcases on its site reviews provided by a specialised tool. Guidance 2021/C 526/01, § 4.2.4

The information to display next to the reviews

It must appear clearly and visibly. C. conso D. 111-10

The law adds that the date of the review and any updates to it are displayed. C. conso L. 111-7-2 You will sometimes find these rules cited under the numbers D. 111-16 to D. 111-19: the consolidated edition of the Code consulted places them at Articles D. 111-9 to D. 111-12, as worded by décret (decree) No. 2024-753 of 7 July 2024.

The review policy

The specific section often takes the form of a “Charte des avis” (review policy) page, linked from the review block. If you check reviews, it also states: C. conso D. 111-11

• The main features of the checks carried out when collecting, moderating or publishing reviews (for example: invitation sent after delivery, unique link tied to the order number, human review).
• Whether the author of the review can be contacted, where applicable.
• Whether or not a review can be modified, and how.
• The reasons for refusing publication: abusive language, personal data, review unrelated to the product, etc.

The processing of personal data linked to the checks must comply with the French Data Protection Act (loi Informatique et libertés). C. conso D. 111-11 The Commission adds that the information covers how average ratings are calculated, and that it must be accessible from the interface where the reviews are read, through a clearly visible link if necessary. Guidance 2021/C 526/01, § 4.2.4

Rejected reviews and negative reviews

When you refuse to publish a review, you tell its author why, by any appropriate means. C. conso L. 111-7-2 · D. 111-12 The law also requires a free function that allows those responsible for the products concerned to report, with reasons, a doubt about the authenticity of a review. C. conso L. 111-7-2

Altering consumer reviews in order to promote products is a practice deemed misleading. C. conso L. 121-4, 28° The European directive from which this rule derives gives the example of publishing only positive reviews and deleting negative ones. Dir. (EU) 2019/2161, recital 49 Other EU countries transpose the same directive with their own wording. The Commission also cites pre-filled templates of positive reviews, reminders sent to get a negative review withdrawn, and aggregated ratings based on undisclosed criteria. Deleting a fake negative review remains possible. Guidance 2021/C 526/01, § 4.2.4

“Verified reviews”: what the claim implies

Stating that reviews come from consumers who have actually used or bought the product, without having taken the necessary steps to check this, is a practice deemed misleading. So is publishing fake reviews or having them published. C. conso L. 121-4, 27° and 28° And as soon as you give access to reviews, the way you ensure that they come from real customers is material information. C. conso L. 121-3

The Commission cites as reasonable steps asking for an order or booking number, prior registration, e-mail verification, clear rules prohibiting undisclosed sponsored comments, detection tools and complaint handling. The steps expected of a large platform are more demanding than those expected of a small site. It also mentions the ISO 20488:2018 standard on online reviews. Guidance 2021/C 526/01, § 4.2.4

Penalties

A breach of the information obligations in Article L. 111-7-2 is liable to an administrative fine of up to €75,000 for an individual and €375,000 for a legal entity. C. conso L. 131-4

Fake reviews and reviews presented as verified without verification fall under the offence (délit) of misleading commercial practice: two years' imprisonment and a €300,000 fine, or up to 10% of average annual turnover, increased to five years and €750,000 if the offence is committed through an online service. C. conso L. 132-2 For a company, the maximum fine is multiplied by five under the French Criminal Code (Code pénal). C. conso L. 132-3 · C. pén. 131-38

Common mistakes

• A “verified reviews” badge on reviews that anyone can post.
• A single date, the publication date, without the date of purchase or experience.
• A forced “most relevant” sort order with no chronological option and no explanation of the criteria.
• No review policy, or a policy that says nothing about rewards and time limits.
• Negative reviews rejected without a reason given to their author.

Your action list

1. List every place where reviews or ratings appear: product pages, home page, widgets, structured data.
2. Decide whether you check reviews, and document the procedure you actually follow.
3. Add next to the reviews the statement on checks, the publication date, the date of experience and a chronological sort order.
4. Publish a review policy: rewards, time limits, checks, modification, reasons for refusal.
5. Check that your review service lets you inform an author of a refusal and report a doubtful review.
6. Remove any “verified” label that does not correspond to an actual verification.
7. For a marketplace, imported reviews or a paid tester programme, have your set-up validated by a lawyer.

Find the other obligations for online shops in all our guides.