MediaNama’s Take:
The Central Consumer Protection Authority’s (CCPA) final order against Zepto marks a shift in how India’s consumer protection regulator is enforcing dark pattern rules. Instead of treating practices like drip pricing and basket sneaking as isolated user interface violations, the CCPA grounds its findings in statutory pricing law. It holds that checkout-stage fees can push the final payable amount beyond the maximum retail price (MRP) permitted under the Legal Metrology (Packaged Commodities) Rules, 2011.
By framing interface-led pricing practices as MRP violations, the CCPA collapses the distinction between design manipulation and price illegality. This significantly raises compliance stakes for digital platforms, particularly in quick commerce, where pricing flows often rely on separating product prices from mandatory charges. The CCPA order also weakens the protective value of voluntary self-audit declarations, making clear that regulator-led scrutiny – and not platforms’ voluntary declarations – will determine compliance.
In essence, the CCPA order signals a more assertive enforcement posture, one that leaves less room for platforms to treat pricing design and consent mechanisms as discretionary product choices.
What’s the News
The CCPA has imposed a penalty of Rs. 7 lakh on Zepto Marketplace Pvt. Ltd. for deploying dark patterns such as drip pricing and basket sneaking. In its final order, the Authority held that Zepto’s checkout-stage pricing practices caused consumers to pay amounts higher than the MRP, in violation of the Legal Metrology (Packaged Commodities) Rules, 2011.
MediaNama had earlier reported on the penalty based on secondary reporting. The final order, now available, goes beyond the initial disclosures. Notably, it links interface-led pricing practices to statutory MRP violations, rejects Zepto’s pricing defences, and imposes enforceable obligations on upfront price disclosure, consent design, and public self-audit reporting.
Consequently, the CCPA has directed Zepto to discontinue the identified practices, disclose all charges upfront, conduct regular self-audits to identify dark patterns, and publish its audit declarations publicly.
How the Case Began
The CCPA initiated the case through a suo motu examination as part of its routine monitoring of e-commerce platforms for dark pattern practices. During this process, the consumer protection authority observed that Zepto displayed lower prices at the product selection stage, while introducing additional charges only after consumers proceeded to the cart and checkout pages.
In one instance cited in the order, Zepto listed an item at Rs. 170 but showed a final payable price of Rs. 177.4 after adding handling charges and a Zepto Pass membership fee. The CCPA noted that Zepto did not disclose these additional charges at the initial stage of selection, creating a misleading price signal.
The CCPA classified…
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