Rules and ethics
Part of Before you publish images, know the UK rules that apply to product photography
Product photography advertising rules in England: banned claims, sale images, cookies and green wording
A checklist for England ecommerce teams on product image claims: banned sale and badge practices, a sale price example, cookie consent and green wording.
What to take away
- The regulated part of a product image is the claim it carries, not the retouching. Check the words, badges and prices that sit on the picture.
- Falsely saying a product is available for a limited time is a banned practice.
- A badge claiming approval or endorsement by a body must be true. Do not use one the product has not earned.
- Cookies behind a personalised gallery need consent before they are set.
- Green wording needs evidence, and a leaf graphic does not supply it.
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 is the overall impression that the image and its caption create, not whether the file was retouched.
Teams can see how imaging, pricing and disclosure fit together in the UK rules and compliance guide.
Who enforces the rules
Keep every claim honest, because each check below has a named rule and a named enforcer.
The rules sit in the Digital Markets, Competition and Consumers Act 2024 (Schedule 20 lists the banned practices), the CAP Code and other Advertising Codes enforced by the ASA, the CMA Green Claims Code, the CMA guidance on unfair commercial practices, and regulation 6 of PECR, with the CMA and Trading Standards Services handling enforcement.
Check the sale and urgency claims
Falsely stating that a product will only be available for a limited time, or only on particular terms for a limited time, to elicit an immediate decision and deprive consumers of sufficient opportunity or time to make an informed choice is a banned practice.
That applies to a "sale ends tonight" overlay on a hero image. If the offer will run on, the overlay is false. Keep a dated note of when each offer starts and ends, and take the image down when the offer does.
Check badges and endorsements
A product shot with a certification badge, award laurel or "approved" stamp is claiming approval, endorsement or authorisation by a public or private body, which is banned when it has not been given.
Before a badge goes on an image, keep the certificate, the date and the scope. If the terms of an approval are no longer met, remove the badge. A studio's stock badge pack is not evidence of anything.
Worked example: a sale price overlay
The figures below are illustrative arithmetic, not a legal threshold. A lamp is shown at £60 against a crossed-out £90.
Amount
- £90Crossed-out price
- £60Sale price
- £30Saving in pounds
- 33%Saving as a share of the crossed-out price
The saving is £90 minus £60, which is £30, or about 33% of £90. A "save £30" overlay only holds up if the £90 price is real and the sale is real. Keep a price history for the lamp, so that you can show what it sold at before the sale, and record the dates.
Check the consent around the gallery
A gallery that remembers a shopper's size or colour preference stores information on the shopper's device, usually in a cookie. Tell people if you set cookies, and clearly explain what the cookies do and why. Valid consent is freely given, specific and informed.
You cannot set non-essential cookies on your website's homepage before the user has consented to them, and that applies to anyone who stores or gains access to information on a user's device (see the ICO cookies guidance on PECR). If your check covers analytics only, the gallery feature may sit outside the banner. Add it.
Check the green wording
"Eco-friendly", "carbon neutral" and "recyclable" need evidence, and a leaf graphic does not supply it.
A studio's own sustainability policy does not transfer to your product page. The claim belongs to the advertiser, so keep the evidence with the approval note.
Check the supplier terms
Your 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 clauses for both sides.
If you use generated imagery, apply the same checks. The AI product photography tools article lists what to verify first.
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. A disclosure policy can hold the wording rules, and the quality checklist can hold the sign-off step.
Plan for the cases that go wrong, such as a badge that lapses or an offer that is extended, in your risk scenarios.
Before you publish
- Every claim on the image has a named source and a date.
- Every limited-time claim matches the real offer dates.
- Every badge has a certificate that is still valid.
- Every crossed-out price has a price history behind it.
- Gallery cookies are covered by the consent banner.
- Every green claim has evidence on file.
This is general guidance only. Individual cases need a qualified adviser.
Common questions
Do the rules apply to organic social posts?
Yes. A promotional post carries the same claims as a paid advert, so check its words, badges and prices in the same way.
Can I shoot in a lifestyle setting that is not a customer's home?
Yes, provided the set 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.
