“No Refund, No Exchange” in Singapore: What the Lemon Law Lets Sellers Say About Refunds and Warranties

Last updated 23 October 2026 — by Adrian Tan, SDM. Marketing guidance, not legal advice. Section numbers are to the Consumer Protection (Fair Trading) Act 2003 as shown on Singapore Statutes Online on 23 October 2026; in the current revised edition the “lemon law” sits in sections 13 to 18, which older articles cite as sections 12A to 12F. Where we interpret how a rule applies to marketing copy, we say so.

“NO REFUND, NO EXCHANGE.” It is printed on receipts, stuck beside cash registers and pinned to the top of thousands of Shopee and Instagram shops. It is also, as a statement of a consumer’s rights, wrong for any item that turns out to be defective.

Singapore’s lemon law has applied to consumer purchases since 1 September 2012. It gives buyers the right to have defective goods repaired or replaced, and if that fails, a price reduction or refund. The government’s own guidance says a retailer cannot contract out of those obligations by “simply displaying a notice” that it does not give refunds. And misdescribing a buyer’s rights is itself listed as an unfair practice under the Consumer Protection (Fair Trading) Act 2003 (CPFTA).

None of that means a shop must accept every return. The law draws a clear line between change of mind, which you can refuse, and defective or not-as-described goods, which you cannot. This guide is for e-commerce sellers, retailers and the marketers who write their returns pages, product listings, checkout copy and ads. It explains the lemon law, the wording that gets sellers into trouble, what the platforms require, and works through five rewrites.

The short version

• You may refuse change-of-mind returns. We found no Singapore law that requires them. Offering them is goodwill, and you can set the conditions.
• You may not refuse remedies for defects. If goods do not conform to the contract at delivery, the buyer can require repair or replacement, then a price reduction or refund.
• Defects within six months are presumed to have existed at delivery. The seller has to prove otherwise.
• The retailer is liable, not just the manufacturer. A manufacturer warranty is an extra right on top.
• Do not describe rights the buyer does not lose. “No refund under any circumstances” and “warranty void if opened” can mislead buyers about their rights, which is an unfair practice.

How the lemon law works

Who and what it covers

Part 3 of the CPFTA (sections 13 to 18) applies where the buyer is “dealing as consumer”, a test borrowed from the Unfair Contract Terms Act, and the goods did not conform to the contract when delivered. If there is a dispute about whether the buyer was a consumer, the seller has to prove they were not. “Non-conforming” means a breach of an express term of the contract, or of the terms the Sale of Goods Act implies about description, satisfactory quality, fitness for purpose and sale by sample.

The Ministry of Trade and Industry’s lemon-law FAQ, published when the law came in, clarifies several points sellers often get wrong:

• Online purchases of physical goods are covered. Services and virtual goods are not.
• Second-hand goods are covered, judged against their age and price.
• Sale and discounted items are covered, except for defects disclosed before purchase.
• Perishables get the presumption only up to their shelf life.
• Rented or leased goods and real property are excluded.

The six-month presumption

If a defect shows up within six months of delivery, it is presumed to have existed at delivery (section 14). The seller can rebut that by proving the goods conformed, or by showing the presumption is incompatible with the nature of the goods or the defect: a phone screen cracked by a fall is not a manufacturing defect. After six months, the buyer can still claim, but has to prove the defect was there at delivery. The presumption does not restart when goods are replaced.

The two-step remedy ladder

Step one (section 15): the consumer can require repair or replacement. The seller must do it within a reasonable time and without significant inconvenience, and must bear the necessary costs, including labour, materials and postage. The consumer cannot insist on a remedy that is impossible or disproportionate.

Step two (section 16): if repair or replacement is impossible or disproportionate, or the seller fails to do it within a reasonable time, the consumer can ask for a price reduction or to rescind the contract for a refund. A refund can be reduced to reflect the use the consumer has had of the goods. The MTI FAQ adds that refunds should go back by the original payment method; store credit only if the consumer agrees.

A court can order a specific remedy, and the Small Claims Tribunals have the same powers (section 18). The tribunals hear claims up to $20,000, or $30,000 if both sides sign a memorandum of consent, and a claim has to be filed within two years of the cause of action.

Why “no refund, no exchange” is a problem

There are three separate legal reasons a blanket no-refund notice causes trouble when goods turn out to be defective.

First, the implied terms cannot be excluded against a consumer. Section 6(2) of the Unfair Contract Terms Act says liability for breach of the Sale of Goods Act’s implied terms about description, quality, fitness and sample “cannot be excluded or restricted by reference to any contract term” when dealing with a consumer. Those implied terms are what make goods “non-conforming” under the lemon law.

Second, the government’s position is explicit. The MTI FAQ says a retailer cannot contract out of its lemon-law obligations, giving the example of a notice saying “we do not give refunds under any circumstances”. Its advice for genuinely known defects is to write them on the invoice or packaging, which removes them from the claim.

Third, misdescribing a buyer’s rights is an unfair practice. Section 4 of the CPFTA makes it an unfair practice to say anything that might reasonably mislead a consumer, and paragraph 11 of the Second Schedule specifically lists representing that a transaction involves or does not involve rights or remedies where that is deceptive or misleading. Paragraph 23 adds omitting a material fact or hiding it in small print. A consumer who is misled can sue, and the Competition and Consumer Commission of Singapore (which now uses the short form CCS) can act against a business that persists.

A point of legal nuance for the careful reader: the CPFTA’s own general ban on contracting out (section 35) is stated not to apply to the lemon-law Part. The protection comes instead from the Unfair Contract Terms Act and from section 4. The practical result for your copy is the same: a no-refund notice does not remove the buyer’s rights for defective goods, and saying it does is the risk.

What the complaint data says

The Consumers Association of Singapore (CASE) received 13,786 complaints in 2025, down 3.2% from 2024. E-commerce complaints fell 22.7% to 3,588. The industries that matter most for warranty and refund copy sit near the top of the list.

In electrical and electronics, 41.9% of complaints were about defective or non-conforming goods; for motorcars, 29.7%. In a written reply to Parliament on 8 April 2026, the trade ministry said CASE receives roughly 156 to 176 complaints a year specifically about defective non-vehicle goods under the lemon law, and that more than two-thirds are resolved in the consumer’s favour. The most common sticking points were disputes over defect versus wear and tear or misuse, disagreement over the return policy (refund versus repair or replacement), and partial refunds the consumer considered too low. Each of those is, at root, a copywriting problem: a returns page that set out the rules accurately would head off many of them.

Warranties: what you can and cannot say

A warranty is a promise you choose to make. You can set its length, scope and exclusions. What you cannot do is use warranty wording to suggest the buyer has fewer rights than the law gives them.

The clearest regulatory signal is from the motor trade. On 22 July 2024 the Commission reminded car dealers to remove “warranty restrictions” that misled consumers about their rights, saying such conduct may be an unfair practice. Its acceptable alternative was a term that lets the dealer reject claims where third-party work actually caused the damage. That is a useful model for any product category: tie the exclusion to cause, not to a blanket trigger.

Two related claims also need care. Paragraph 18 of the Second Schedule lists misrepresenting the availability of repair facilities or spare parts, so “island-wide service centres” and “parts available for 10 years” must be true. And any extended warranty you sell, whether yours or a third party’s, should state clearly who provides it and what it adds beyond the buyer’s statutory rights. We found no Singapore-specific guidance on extended warranties, so the general rules in section 4 are the test.

What the marketplaces require

Platform policies sit on top of the law, and most sellers meet them first.

• Shopee Singapore lets buyers request a return or refund within 15 days of delivery, for Mall and non-Mall items, according to its help centre when we checked.
• Lazada Singapore uses different windows for different programmes (LazMall, Marketplace, cross-border and grocery). Check the current figures for your programme in Lazada’s seller centre rather than copying them from a third-party article; we could not verify them from a primary source.

A platform window is a process rule for using the platform’s dispute system. It is not the end of the buyer’s legal rights, which continue beyond it under the lemon law. Your returns page should not present the platform window as the only time a buyer can complain about a defect.

Five worked examples

1. A phone-accessories shop on Shopee

The shop banner reads “NO REFUND NO EXCHANGE — CHECK BEFORE BUYING”. Replace it with: “No change-of-mind returns. Faulty or not as described? Raise it through Shopee within 15 days of delivery for the fastest fix. Your rights under Singapore’s lemon law still apply after that.” The shop keeps the policy it wanted and loses the misleading statement.

2. A furniture retailer with a 30-day return policy

The returns page says “30-day returns” and, in the FAQ, “defects must be reported within 30 days”. Keep the 30-day goodwill window for change of mind. Change the FAQ: “If an item develops a fault within six months, we presume it was there at delivery and will repair or replace it at our cost, including collection and delivery. If we can’t, we’ll offer a partial or full refund.” That reflects the cost rule in section 15 and the order of remedies in sections 15 and 16. Furniture was the seventh-largest source of CASE complaints in 2025, so this is worth getting right.

3. An electronics shop’s warranty card

“Warranty void if opened or sticker removed.” Rewrite: “Warranty claims may be declined where damage was caused by unauthorised opening, repair or modification. This warranty is in addition to your statutory rights.” Add a line on the product page: “Bought from us? Contact us first about any fault; we handle it even where a manufacturer warranty also applies.”

4. A fashion brand’s exchange policy

“Exchanges within 14 days for unworn items with tags. Store credit only. No refunds.” That is lawful as a change-of-mind policy if you add one sentence: “Faulty items will be repaired, replaced or refunded to your original payment method.” For end-of-season sales, list any known flaws in the listing itself; the Sale of Goods Act excludes defects pointed out before the contract.

5. A second-hand camera seller on Carousell

“Sold as is, no returns.” Second-hand goods are covered, judged against their age and price. “As is” protects you for the wear and defects you actually disclosed, not for faults you did not mention. Better: “Used, 3 years old. Known issues: minor scratches on the body, small dust spot in the viewfinder (photographed). No change-of-mind returns.”

A returns-page checklist

1. Separate change-of-mind returns from faulty or not-as-described goods, with a heading for each.
2. State your goodwill window and conditions for change of mind clearly.
3. For faulty goods, describe repair or replacement first, then partial or full refund, at your cost.
4. Say refunds for faulty goods go to the original payment method.
5. Remove “no refund under any circumstances”, “warranty void if opened” and any time limit that reads as the end of legal rights.
6. List known defects on the product page or invoice, including for sale and second-hand items.
7. Check repair, spare-parts and service-centre claims are true.
8. Make the policy easy to find from every product page and the checkout.

A clear, fair returns page is also a conversion asset: return-policy uncertainty is a common reason buyers hesitate at checkout, which our guide to e-commerce conversion rate optimisation covers. For the other consumer-law traps on product pages, see our guides to the Trade Descriptions Act and product claims, dark patterns in Singapore and the legal requirements for business websites. If you sell vouchers or packages rather than goods, the rules are different; see gift voucher and loyalty points marketing and prepaid package marketing. For marketplace strategy generally, start with digital marketing for e-commerce in Singapore.

Where this leaves you

You can run a strict returns policy in Singapore. You can refuse change of mind, require tags and packaging, offer store credit for exchanges and exclude damage caused by misuse. What you cannot do is tell buyers they have no remedy for goods that were defective when they arrived. Rewrite the notices that say otherwise, put the lemon-law ladder in plain words on your returns page, and most of the disputes CASE sees never start.

If you want an online store whose product pages, returns policy and checkout are built to convert and to stand up to scrutiny, our web design and e-commerce team in Singapore can help, and you can see how we work in our client case studies. For the bigger picture, start with our complete guide to web design in Singapore.

Frequently asked questions

Is “no refund, no exchange” legal in Singapore?

You may refuse change-of-mind returns, but a notice cannot remove a consumer’s rights for defective or non-conforming goods. The government’s lemon-law guidance says retailers cannot contract out by displaying a no-refund notice, and misdescribing a buyer’s rights is an unfair practice under the CPFTA.

Do I have to accept change-of-mind returns?

We found no Singapore law that requires change-of-mind returns. The lemon law is triggered only by goods that did not conform to the contract at delivery. Change-of-mind returns are goodwill, so you can set the window and conditions, as long as your policy does not misstate defect rights.

How long does the lemon law last?

Defects that appear within six months of delivery are presumed to have existed at delivery unless the seller proves otherwise. After six months the buyer can still claim but must prove the defect was there at delivery. Small Claims Tribunal claims must be filed within two years.

Does the lemon law apply to online and second-hand purchases?

Yes for physical goods bought online, according to the trade ministry’s lemon-law FAQ. Second-hand goods are covered and judged against their age and price. Sale items are covered except for defects disclosed before purchase. Services, virtual goods and rented goods are not covered.

Can I say “warranty void if opened”?

A blanket trigger like that risks misleading buyers about their rights. Tie exclusions to the cause of the fault instead, for example declining claims where damage was caused by unauthorised opening or repair, which mirrors the approach the Commission accepted for car dealers in 2024.

Who is responsible for a defect: the retailer or the manufacturer?

The retailer that sold the goods is liable under the lemon law. A manufacturer warranty, where one exists, is an additional right for the buyer, not a substitute for the seller’s obligations.