The most common deficiencies relate to contract terms concerning liability for errors and limitations of liability. As many as 37 out of 50 companies reviewed have terms that incorrectly limit the company's liability for incorrect price information. Traders have the right to change information on their website, but a price cannot be adjusted after a binding agreement has been entered into solely due to an incorrect price indication. Exceptions can only be made if the consumer realised or should have realised that the price was incorrect. It also occurs that companies disclaim responsibility for inaccuracies in product information or product images. This is contrary to the Consumer Purchase Act, where an item may be considered defective if it does not correspond to the information provided at the time of purchase.
General Disclaimers
Regarding limitations of liability, the review shows that 31 out of 50 companies have terms that are incompatible with the Consumer Purchase Act. Several actors use general disclaimers referring to force majeure, which is a concept that does not exist in the Consumer Purchase Act. Others apply routine disclaimers of liability for damages without taking into account that all statutory circumstances must be met for a company to avoid paying damages. Some also limit the right to damages to a specific amount, which is generally considered unreasonable.
Furthermore, problems are noted with terms regarding the binding time point at five companies, and four companies have reserved the right to change contract terms in binding agreements without specifying under what circumstances this may occur. Moreover, it appears that 33 of the reviewed companies still refer to the EU Commission's dispute resolution platform, despite it being discontinued in July 2025.
“My opinion is that many of the companies are not aware that they have made mistakes. It is therefore important to now review their contract terms to ensure that they do not conflict with consumer legislation,” says Maja Lindstrand, lawyer at the Consumer Agency.
The Consumer Agency has initiated targeted supervisory proceedings against the 46 companies. The companies have until the end of September to submit responses to the authority and explain how they intend to rectify the deficiencies.
Below are the 50 companies that were included in the Consumer Agency's review:
- AB Skruvat Reservdelar
- Adlibris AB
- Apotea Sverige AB
- Apotek Hjärtat AB
- Apoteket AB
- Arc E-commerce AB (Outl1)
- Babyland Online Nordic AB
- Bagaren och Kocken AB
- Bokus AB
- Boozt Fashion AB
- Bonti (Latens 1 AB)
- Byggmax AB
- Bythjul Norden AB
- CDON AB
- Clas Ohlson Aktiebolag
- Cocopanda Sweden AB
- Din VVS Butik (Triopart Int AB)
- Dressmann AB
- Elgiganten Aktiebolag
- Ellos AB
- Fyndiq AB
- Granngården AB
- H & M Hennes Mauritz Sverige AB
- Happy Homes Försäljning AB
- Jula Sverige AB
- JYSK AB
- Kappahl Sverige AB
- Kjell & Co Elektronik AB
- Komplett Services Sweden AB
- Kronans Apotek AB
- Lager 157 AB
- Mekonomen E-handel AB
- Mio AB
- Nakdcom One World AB
- Naturkompaniet AB
- Nelly NLY AB
- Original Brands Sweden AB (Kids Brand Store)
- Panduro Hobby AB (publ)
- Pen Store Sthlm AB
- Proffsmagasinet Svenska AB
- Rapunzel of Sweden AB
- Royal Design Group AB (Rum21)
- Rugvista AB
- Scandinavian Photo AB
- SmartaSaker i Stockholm AB
- Stadium Sverige AB
- Svenskt Tenn AB
- Tretti AB
- Webbhallen Sverige AB
- Willab Garden AB