Rules and ethics
Part of Before you publish images, know the UK rules that apply to product photography
Before you publish product images, check the product photography advertising rules
A practical checklist for ecommerce teams in England on misleading imagery, price claims, cookie consent and green wording, with a worked example of a sale price.
What to take away
- The mistake most teams make is treating product photography as an art brief and the caption as an afterthought. The regulated part is the claim the image carries.
- Under the Consumer Protection from Unfair Trading Regulations 2008, marketing misleads if it deceives the average consumer and changes a buying decision.
- A price overlay is an advertisement. A crossed-out figure needs a genuine previous selling price.
- Cookies or similar storage behind a personalised gallery need consent under the Privacy and Electronic Communications Regulations.
Check the image against the claim
Start with the words attached to the picture. An "award winning" line needs a named award and a date. The test under the 2008 Regulations is the overall impression the image and its caption create, not whether the file was retouched.
Teams running a catalogue-wide process can see how the imaging, pricing and disclosure workstreams fit together in the UK rules and compliance guide for 2027.
Check the price and the comparison
A crossed-out price must reflect what the product genuinely sold at for a reasonable period. A brief promotional spike does not create a reference price you can reuse for months.
For example, a retailer shows a lamp at £60 against a crossed-out £90 and claims a £30 saving. If the lamp sold at £90 for three days, the saving is likely to mislead. A studio retainer of £400 a month would not reduce that exposure.
Check the import and origin claims
"Made in England" and "British made" are origin claims. They must be accurate and they affect customs treatment. Presenting imported goods as domestic creates a misleading action.
If you import goods and rely on a trade agreement to cut duty, the origin rules matter before the product reaches the studio. GOV.UK guidance on importing and exporting goods using preference agreements explains how to claim the preferential rate and what evidence to keep.
Check the consent around the gallery
A gallery that remembers a shopper's size or colour preference is using storage, usually cookies. Consent is normally required before that storage is set. The ICO's storage and access technologies guidance covers what counts as consent and how to record it.
If your banner only covers analytics, the gallery feature may sit outside it.
What the CAP code expects across the UK
The Committee of Advertising Practice code applies in England, Scotland, Wales and Northern Ireland. Ads must be legal, decent, honest and truthful, so an image must not exaggerate performance or hide a material condition. The Advertising Standards Authority can act on a single complaint.
How to record the decision
Keep a short approval note for each hero image: the claim, the evidence, the date and who signed it off. Update it when the claim changes.
Check the sustainability wording
"Eco-friendly", "carbon neutral" and "recyclable" need evidence, and a leaf graphic does not supply it. The Chartered Institute of Marketing's sustainable marketing hub collects guidance on environmental claims that stand up.
A studio's own sustainability policy does not transfer to your product page. The claim belongs to the advertiser.
Check the supplier terms
Your product photography contract should say who approves claims, who owns the retouched files and who carries liability if a claim is challenged. A retoucher who removes a safety label can create a misleading image. The commercial contracts guidance sets out the clauses that protect both sides.
This is general guidance only. Individual cases need a qualified adviser, and enforcement in Scotland, Wales and Northern Ireland can differ from England.
Common questions
Do the rules apply to organic social posts?
Yes. The CAP code covers paid and non-paid media, and consumer protection law applies to commercial practices generally. A promotional post is an ad even when no money changes hands.
Can I shoot in a lifestyle setting that is not a customer's home?
The set is fine provided it does not create a false impression of what the buyer receives. If it implies a size, feature or accessory that is not included, the image is likely to mislead.
Who is responsible if a studio produces a misleading image?
The advertiser owns the claim. The studio may carry contractual liability, but the brand owns the communication.
