The Revised Specified Commercial Transactions Act (hereinafter referred to as the “Revised Specified Commercial Transactions Act”) will come into effect on June 1, 2022. This article explains the details of the Revised Specified Commercial Transactions Act and how to set it up with Stripe. For basic details and requirements of the Revised Specified Commercial Transactions Act, please see here .
Note:
This guide was created based on the guidelines and materials published by the Consumer Affairs Agency. It was created with the utmost attention to detail, but accuracy cannot be guaranteed. Please be sure to refer to the relevant materials and guidelines.
Guidelines for display at the application stage of mail order sales regarding the amendments to the Specified Commercial Transactions Act and the Deposit Act in 2021
Background information
In response to an increase in transaction problems with subscription purchases, the revised Specified Commercial Transactions Act now requires businesses to display certain transaction information when placing an order online. It also prohibits representations or other representations that may mislead consumers (Article 12-6 of the Specified Commercial Transactions Act). It also allows consumers to revoke decisions made due to misunderstandings of statements or other representations that violate the Act (Article 15-4 of the Specified Commercial Transactions Act). In
light of these provisions, the Consumer Affairs Agency has published the “Guidelines for Representations at the Application Stage of Mail Order Sales” (hereinafter the “Guidelines”) to clarify interpretations and provide specific examples. The
revised Specified Commercial Transactions Act and the Guidelines require businesses to display all necessary information about matters that are likely to confuse consumers so that they can be confirmed at a glance. This will prevent consumers from being charged for something they thought was a trial, or from being unable to cancel a contract because of complicated requirements when they are told they can cancel at any time. To comply with this, businesses must provide customers with certain contract information on the final confirmation page of online orders.
Final confirmation page
As a general rule, the “final confirmation page” should display the following information:
① Quantity ② Sales price / consideration ③ Time and method of payment ④ Time of delivery / supply ⑤ Details regarding application deadlines (if applicable) ⑥ Information regarding withdrawal and cancellation
The guidelines define a final page in online sales as the page where a consumer clicks an order or other button to complete an offer and enter into a contract. Note that although the guidelines indicate that pages with “Confirm Order” or similar titles are considered final pages, any page that fulfills this definition’s function is treated as a final page, regardless of title.
Information that needs to be displayed
① Quantity
The guidelines state that businesses should display details such as quantity, number of times, and contract period in a format that is easy for consumers to check based on the type of product/service sold. In addition
, for subscriptions, the quantity of the product delivered in each installment must be displayed along with the number of deliveries so that consumers can see the total amount delivered. If the fact that it is a subscription is written in small or hard-to-read letters away from the phrase “first order free” or “free trial”, it is likely to be considered a violation of the revised Specified Commercial Transactions Act. It is
also recommended that businesses indicate whether the subscription is unlimited, and if so, provide details such as the amount provided over a certain period (e.g., annually) as a guide. This also applies to contracts with automatic renewal.
In addition, when selling the same product with different contents, the display must be made so that consumers can clearly distinguish between them. For example, if Product A is sold in packs of 5, 3, 2 or different sizes (e.g. large/800mL, medium/500mL, small/300mL, etc.), the quantity/size etc. must be stated in the product description along with the product name.
② Sales price/value
When a customer buys multiple products, businesses should display the total price in addition to the prices of the individual products. Any additional delivery charges should also be displayed. For
subscriptions, businesses should clearly show the total price the customer will pay in addition to the amount for each instalment. For example, for a 6-month subscription with monthly instalments, the confirmation page should display the total amount for the 6 months, in addition to the monthly instalments, including delivery. For subscriptions with a special price for the first instalment, businesses should display the price of the first instalment and the prices of any subsequent instalments. For
free trials that automatically convert to a paid subscription, businesses should clearly display up front when the conversion will occur and the amount to be paid. For unlimited contracts, we recommend displaying approximate totals for a set period (such as one year).
③ Timing and method of payment
Businesses must display the applicable payment methods and the associated payment due date.
If there are multiple payment methods used and the information cannot be displayed dynamically, the payment due date must be displayed for each supported payment method.
④ Delivery time/provision time
You must indicate when the product will be shipped, delivered, or when the service will commence, and
if it is a subscription, the period for which each delivery is provided must be indicated.
⑤ Application period
If the offer is for a limited time, the duration of the offer must be displayed on the final confirmation page. To avoid violations, you can include more information next to the product name or include a link to more information, but the duration cannot be vague (such as “for a limited time only”).
- Expressions likely to maintain compliance: Specially selected three-tiered New Year’s meal [Application period ends December 27th]
- Expressions that are likely to violate the law: Specially selected three-tiered New Year’s meal [On sale now!]
This does not apply to offers that have limited quantities, special payment terms, or special bonuses/after-sales services/ancillary benefits, or other terms that do not terminate the purchase when the offer expires. Other examples include:
- An offer that does not affect whether or not a consumer can purchase a product
- Limited time discount
- Limited time point redemption campaign
- Limited time free shipping campaign
- Applications that are not subject to a specific period
- Limited quantity available
⑥ Information regarding order withdrawal and cancellation
Businesses must display the manner, conditions and effects of withdrawal or termination of a contract/order.
Specific examples include cancellation fee terms, cancellation procedures and cancellation deadlines. Clear links to a separate page or window may be included for consumers to review these details. However, if there is a limited time frame for cancellation, if the cancellation process requires steps that consumers would not expect (such as submitting additional personal information), or if the business does not provide an easy way for consumers to request cancellation, these details must be clearly stated on the final confirmation page. Additionally, if cancellation requests are made
over the phone, it may be considered a misrepresentation if consumers are unable to reach a representative or if the representative does not respond to the request.
Set the information to be displayed on the final confirmation page with Stripe Checkout / Payment Links
In the next section, we’ll show you how to display the six main display categories on your Stripe Checkout confirmation page.
① Quantity
The Stripe Checkout page will show you the product quantity, the amount due, allow you to change the quantity, and, in the case of regular billing with a trial period, will show you details about the trial period and any future cycles.
② Sales price
Checkout lets you display prices, including shipping and tax, in three different ways:
1. Include shipping and sales tax in the product price
The easiest way to do this is to include shipping and tax in your price when you create your product. Just mention that in your description. Click here to learn how to create a product .
2. Set the tax rate and shipping fee
You set the shipping and tax rates when you create your products , and then associate them with amounts when you create your Checkout URL, allowing you to display shipping and tax separately on the final Checkout confirmation page.
3. Use Stripe Tax
If you use Payment Links or need to account for reduced or foreign VAT rates, we recommend using Stripe Tax instead of tax rates , which can be set on a per-product basis using Stripe Tax.
③ Timing and method of payment
・ Payment method
Checkout or Payment Links allows you to select your payment method on the final confirmation page.
– Timing of payment
Deferred payment methods are currently not supported in Japan. For single orders, transactions should usually be processed instantly.
④ Delivery time/provision time
If your product requires shipping, you can set the Shipping cost and display the estimated delivery date on the final confirmation page.
⑤ Application period
Checkout doesn’t have the ability to display an offer expiration date or sale period. One way to display this information is by including it directly in the product name. If you offer a time-limited offer, include the intended end date and time in the product name or description.
⑥ Information regarding order withdrawal and cancellation
・Setting a return policy
Returns and refunds can be set up in your Stripe dashboard under Settings > Checkout and Payment Links . You can include your policies regarding refunds, exchanges, and returns by enabling Refund and Return Policy.
