The guidance covers invitations to purchase, enquiry-led marketing and the consumer protection requirements outlined in the Digital Markets, Competition and Consumers Act.
The guidance has been developed in response to conversations across the industry about how the rules should be interpreted in real-life travel marketing, particularly across social media, email, websites, shop windows, printed assets and enquiry-led sales activity.
Under the CMA’s guidance, where a trader provides consumers with information about a product and its price, this will normally constitute an invitation to purchase. In those circumstances, businesses need to ensure that pricing information is clear, timely and not misleading, and that any mandatory fees, taxes, charges or other unavoidable payments are reflected appropriately.
To help members apply this in practice, Advantage has created a toolkit breaking down the key principles into practical tests, examples and checklists that can be applied to day-to-day activity.
– The enquiry vs purchase framework: Helping members assess whether a communication is designed to prompt an enquiry, or whether it includes enough product and pricing information to be treated as an invitation to purchase
– Channel-specific examples: Providing practical examples across common marketing formats, including social media posts, CRM quotes, window cards, digital magazines, websites and email promotions
– Pricing transparency checklists: Helping members review pricing, calls to action, availability, mandatory charges and “from” price claims before marketing activity goes live; and
– Supplier and trader information: Outlining practical considerations around tour operator details, Atol-related information and trader identity information where relevant, recognising that the requirements can vary depending on the content, channel and customer journey.
David Forder, Advantage's Marketing Director, said: “There is still a lot of grey area for the industry to work through, so our aim has been to take a complex subject and turn it into something members can actually use."
