Faulty Goods Calls: The Consumer Rights Act Remedies Ladder
In short
Dilr Voice is an enterprise voice AI platform from DILR.AI that answers inbound calls and hands over to a person with full context. This guide maps the Consumer Rights Act 2015 remedies onto a retailer's faulty goods phone journey, and shows which steps an agent records and which decisions stay with a person.
DE
Dilr.ai EngineeringEngineering team
Published Oct 18, 2026Read 22 min
A customer rings to say the washing machine they bought three weeks ago has stopped draining. In that one call they may already have exercised a legal right, and the retailer's phone journey decides whether anyone notices. The Consumer Rights Act 2015 gives a consumer who buys faulty goods a ladder of remedies, each tier with its own conditions, and the trader who sold the goods carries the duty to honour it. The phone line is one of the first places those claims land, and a call that walks the ladder out of order creates problems later.
The volume is real. In its February 2026 campaign data, Citizens Advice reported that its Consumer Service received 17,744 complaints about clothing and footwear in 2025, up from 14,620 in 2024, a rise of 21%. Faulty goods topped that list with 3,222 complaints, 18% of the total. Those figures cover clothing and footwear only, not electricals or home goods, but they show the shape of the problem: in clothing and footwear, a high-volume retail sector, faulty goods were the single largest complaint issue. Staffing is under pressure at the same time. The BRC, citing ONS figures, reported 2.76 million retail jobs in March 2026 and raised concerns that rising employment costs are reducing entry-level and flexible job opportunities, a pressure our guide to where AI pays in UK retail sets out in more detail.
This guide is written for the Head of Customer Service at a UK retailer selling electricals and home goods. It holds one altitude: the fault-remedy sequence under sections 19 to 24 of the Act, and how a phone journey, human or voice AI agent, should walk it. It deliberately cedes three neighbouring topics. Returns eligibility triage for unwanted goods belongs to our guide to retail order status and returns calls. Cancellation rights for distance and off-premises sales belong to our post on cooling-off rights for voice sales. Lost or damaged parcels and the passing of risk belong to our courier and parcel delivery guide. It also covers business-to-consumer contracts for goods only: digital content and services sit in different chapters of the Act.
This guide is shipped by the team behind Dilr Voice, a multi-agent voice AI platform with inbound front desk handling and warm transfer to a human with full context. Or see DATS, our five-stage consulting system for placing AI inside existing operations.
What does the Consumer Rights Act require when a customer reports a fault?
The Consumer Rights Act 2015 treats every consumer contract for goods as including terms that goods are satisfactory in quality, fit for a purpose made known to the trader, and as described. Where goods breach those terms, section 19 gives three tiers of remedy, each with its own conditions: the short-term right to reject, repair or replacement, and a price reduction or the final right to reject. The trader, the retailer, owes them.
Section 9 sets out what satisfactory quality means. A reasonable person's standard applies, taking account of the description, the price and the other circumstances, and the statute lists aspects of quality that include fitness for the usual purposes, appearance and finish, freedom from minor defects, safety and durability. Durability matters most on a fault line, because the question a customer is really asking on day 200 is whether the goods should have lasted longer than they did.
Section 19 then sets the ladder. Where goods fail the quality, fitness or description terms, the remedies are the short-term right to reject, the right to repair or replacement, and the right to a price reduction or the final right to reject. The tiers are not a free menu. Each opens under conditions written into the following sections, and where goods fail because of the trader's installation or a requirement stated in the contract, section 19(4) leaves out the short-term right altogether. A call that offers the wrong tier first can leave the retailer refusing something the customer was entitled to, or conceding something they were not yet owed.
Two points about who the duty binds are worth fixing before any journey design. First, the trader is the business that sold the goods to the consumer, not the manufacturer and not a technology supplier. Second, the rights apply between a trader and a consumer, which section 2(3) defines as an individual acting for purposes wholly or mainly outside their trade, business, craft or profession. A company buying the same washing machine for its office is not a consumer, which is one reason the first question in the call matters so much. Our broader guide to UK and EU voice AI compliance covers the data protection side of recording these calls; this post stays with the consumer law.
When does the 30-day short-term right to reject start and stop?
The short-term right to reject under the Consumer Rights Act 2015 lasts until the end of 30 days, counted from the first day after three things have all happened: ownership has passed to the consumer, the goods have been delivered, and, where the trader agreed to install them, the trader has told the consumer that is done. The clock does not start at the till, and it pauses while an agreed repair or replacement is under way.
Section 22(3) is precise about the start, and the precision changes call scripts. For a fridge freezer bought online on the first of the month, delivered on the fifth and installed by the retailer's own team, who confirm the installation to the customer on the ninth, the count begins on the tenth. A call handler who counts from the order date will tell some customers their right has expired when it has not. A script that asks only "when did you buy it?" collects the wrong date. The question set has to capture the delivery date, and for installed goods, the date the customer was told the installation was done.
Three further rules in section 22 shape the journey:
Perishable goods. Under section 22(4), goods that can reasonably be expected to perish sooner carry a shorter limit, ending when they could be expected to perish.
Agreements to cut it short do not bind. Section 22(2) says an agreement under which the short-term right would be lost before the time limit passes is not binding on the consumer. A returns policy cannot shorten it.
The pause during repair or replacement. Under sections 22(6) to 22(8), if the consumer requests or agrees to a repair or replacement, the 30-day period stops running for the waiting period, from the day of the request to the day the consumer receives the goods back. If the repaired or replacement goods still do not conform, the limit becomes 7 days after the waiting period ends or, if later, the original limit extended by the waiting period.
The pause is easy to miss. A customer who agreed to a repair on day 20 and received the machine back on day 34 has not lost the short-term right to reject on day 31. The waiting period runs from the day of the request to the day the goods come back, both included, and the clock stood still for all of it. If the repaired machine still does not work, section 22(7) gives the customer at least 7 more days. A journey that records only the purchase date and today's date cannot compute this, so the record has to hold the delivery date, the installation date, and the start and end of every waiting period. Our guide to setting caller expectations covers how to say "let me check the dates" without promising an outcome.
How is the right actually exercised on a call?
Under the Consumer Rights Act 2015, a customer exercises the right to reject by telling the trader they are rejecting the goods and treating the contract as at an end. Section 20 asks only for an indication clear enough to be understood. That means a phone call can be the moment the right is exercised, and a retailer's call record may be the only evidence of when it happened.
"The indication may be something the consumer says or does, but it must be clear enough to be understood by the trader."
Consumer Rights Act 2015, section 20(6)
The practical consequence is that a phone line is a legal channel, not just a service channel. When a customer says, in terms clear enough to understand, "I am rejecting this, I want my money back", the right may have been exercised at that moment, and section 22(1) only removes the short-term right if the time limit passes without the consumer exercising it. The call record therefore needs to capture what was said and when. Whether the goods actually failed to conform is a separate question, decided later. The record of the rejection and the decision on conformity should never be collapsed into one step, and neither should trigger an automatic refund on its own.
How should a call handle the repair or replacement stage?
Under section 23 of the Consumer Rights Act 2015, once a consumer requires repair or replacement, the retailer must carry it out within a reasonable time and without significant inconvenience, and must bear the necessary costs, including labour, materials and postage. The consumer chooses which of the two, unless the chosen remedy is impossible or disproportionate compared with the other.
The cost rule in section 23(2) is an easy line for a call handler to cross by accident. A script that asks the customer to pay for courier collection of a faulty item for repair, or to cover a call-out charge for an engineer, is likely asking for necessary costs the statute places on the trader. The same applies to postage for a part. Any offer made on the call should be framed as cost-free to the consumer, because it is.
The choice between repair and replacement belongs to the consumer, with one limit. Under sections 23(3) and 23(4), the consumer cannot require a remedy that is impossible, or that is disproportionate compared with the other. A remedy is disproportionate if it imposes unreasonable costs on the trader compared with the alternative, taking account of the value the goods would have if they conformed, how significant the fault is, and whether the other remedy could be carried out without significant inconvenience to the consumer.
That test is a judgement. It weighs costs the call handler usually cannot see, such as the spare parts price, engineer availability and the replacement stock position, against the seriousness of the fault. A voice agent or a front-line handler should not decide it. The right design is to capture the customer's preference, capture the fault description, and route the proportionality question to someone with the cost data. If the retailer proposes the other remedy instead, the reason should be recorded. For help mapping who holds decisions like this, see our DATS consulting services.
Two more rules govern the waiting stage:
Reasonable time is contextual. Section 23(5) says reasonable time and significant inconvenience are judged against the nature of the goods and the purpose they were bought for. A broken fridge in a family home is a different case from a broken decorative lamp.
The consumer must give the trader a chance. Under sections 23(6) and 23(7), a consumer who requires or agrees to a repair cannot switch to replacement, or exercise the short-term right to reject, without first giving the trader a reasonable time to repair, unless that delay would cause significant inconvenience. The same applies the other way round for replacement.
The second rule protects the retailer, but only if the journey records the agreement. When a customer agrees on the phone to a repair, the call record is the evidence that the waiting period began, which is also the evidence that the 30-day clock paused. The same record does two jobs, so capture it with a date. When a case needs a person, a warm transfer that carries the full context means the customer does not have to repeat the fault history.
The Consumer Rights Act remedies ladder for goodsEach tier opens under the conditions in sections 22 to 24 of the Consumer Rights Act 2015; at the third tier the consumer chooses a price reduction or final rejection, not both.
When can a customer ask for a price reduction or final rejection?
Under section 24 of the Consumer Rights Act 2015, a consumer may choose either a price reduction or the final right to reject, not both, in three situations only: one repair or one replacement has been carried out and the goods still do not conform; neither repair nor replacement can be required because both are impossible or disproportionate; or the trader failed to repair or replace within a reasonable time without significant inconvenience.
The trigger in section 24(5)(a) is a single failed repair or a single failed replacement. It is not three repairs, and it is not "we will try again". Section 24(6) defines a repair or replacement as having happened once the consumer has requested or agreed to it, for one fault or more than one, and the trader has delivered or made the goods available in response. For goods repaired at the customer's home, section 24(7) says they are made available when the trader indicates the repairs are finished.
This is a point where a phone journey can easily go wrong. A handler who offers a second repair when the customer is entitled to choose final rejection is not breaching anything by offering, but the customer may say no, and the call record should show that the choice was put fairly. If you want a second view on where your own script stands, book a scoping call. A journey that only ever offers a further repair, without telling the customer the higher tier is open, risks steering them away from a remedy the statute gives them.
The money side has its own rules:
Price reduction under section 24(1) is a reduction by an appropriate amount, with a refund of anything paid above the reduced price. Section 24(2) allows it to be the full price where appropriate.
Final rejection brings a refund, but under section 24(8) the trader may deduct for the use the consumer has had of the goods since delivery.
No deduction in the first 6 months. Section 24(10) bars any deduction for use if the final right to reject is exercised in the first 6 months, unless the goods are a motor vehicle or a description specified by order. Section 24(11) counts those 6 months from the first day after transfer, delivery and any notified installation, the same start events as the 30-day period.
Refund mechanics. For final rejection, the refund rules in section 20 apply directly; for a price reduction, section 24(3) applies the same rules. Either way the refund must be made without undue delay and in any event within 14 days beginning with the day the trader agrees the consumer is entitled to it, by the same means of payment unless the consumer agrees otherwise, and with no fee.
Note where the 14 days begin. They run from the day the trader agrees the consumer is entitled, which may or may not happen on the call, and the duty to refund without undue delay applies throughout. A voice agent that has no authority to agree entitlement should not quote a refund date at all; it should tell the customer when they will hear back.
How does the six-month presumption change the call?
The Consumer Rights Act 2015 presumes that goods which fail to conform within six months of delivery did not conform on the day they were delivered. That shifts the evidence question onto the retailer for repair, replacement, price reduction and final rejection. The presumption does not apply to the short-term right to reject, and the retailer can rebut it.
Section 19(14) states the rule, and its scope is narrower than a casual reading suggests. It applies only for the purposes of subsections 19(3)(b), 19(3)(c) and 19(4), which cover the repair or replacement tier, the price reduction or final rejection tier, and the two-tier case in section 19(4). It counts six months beginning with the day the goods were delivered. That is a different start point from the six months in section 24(10), which begins the day after transfer, delivery and installation notice. The two periods often overlap in practice, but they are separate rules with separate purposes, and a script should never call either one "the six-month rule" as though there were only one.
Section 19(15) gives the two ways the presumption falls away: it is established that the goods did conform on delivery, or applying it is incompatible with the nature of the goods or with how they fail to conform. A sofa cushion slashed by a pet, or a phone screen cracked by a drop, are the kind of case the second limb is aimed at, in our reading, because the way the goods failed points away from a defect present on delivery.
For call design, the presumption changes the default posture rather than the outcome. Inside the window, a front-line journey should not ask the customer to prove the fault existed at delivery, because the statute does not require it. It should collect a clear fault description, the delivery date and, where relevant, a model and serial number, and then route any rebuttal argument to a person through a warm handover with context. A rebuttal is an assessment of evidence, and it is the retailer's to make. Outside six months, the customer needs to show the lack of conformity, and the journey's job is to explain that plainly without discouraging a legitimate claim. Customers in vulnerable circumstances may need more help with that step; our guide to vulnerable customer detection covers the signals worth watching for.
Which steps can a voice agent handle and which stay with a person?
A voice agent on a retailer's fault line can handle the structured parts of the Consumer Rights Act journey: capturing the order reference and dates, recording the fault description and the customer's stated remedy, and logging a rejection in the customer's own words. Decisions that weigh evidence or cost, such as conformity, proportionality, rebuttal of the presumption and the amount of any reduction, should stay with a person.
The split follows the statute's own structure. Some steps are facts to capture, which an agent can be set up to collect in a structured way. Others are judgements the Act leaves to the trader, which need someone who can see the cost data and the product history. The table sets out how we would draw the line for an electricals and home goods retailer. It is our design view, not a legal requirement.
Step in the journey
Statutory hook
Voice agent
Person
Confirm consumer purchase and order
s.2(3), s.19
Capture details
Edge cases, business buyers
Capture delivery and installation dates
s.22(3), s.24(11)
Capture
None needed
Record fault description
s.9, s.19
Capture in customer's words
None needed
Log a stated rejection with timestamp
s.20(5), s.20(6)
Capture verbatim
Review later
Record waiting periods for repair or replacement
s.22(6) to (8)
Capture start and end
None needed
Decide whether goods conform
s.19, s.9
No
Decide
Decide whether a remedy is disproportionate
s.23(3), s.23(4)
No
Decide
Rebut the six-month presumption
s.19(15)
No
Decide
Set a price reduction or use deduction
s.24(1), s.24(8)
No
Decide
Handler time is the cost at stake. The ContactBabel UK Contact Centre Decision Makers' Guide 2024, a cross-sector survey, put the mean cost of a live inbound call at 5.58 pounds, with a mean speed to answer of 116 seconds and a first-call resolution rate of 78%. Those are averages across sectors, not retail fault lines, but they give a sense of what each live call costs. The capture steps in the top half of the table are repetitive and date-sensitive, which is exactly the work that suffers when a queue is long. The judgement steps are where a skilled person adds value.
On the product side, Dilr Voice supports this kind of split: it chains specialised agents in a single call, runs an inbound front desk with business-hours and after-hours routing, and hands over to a human through a warm transfer with full context. Its RAG knowledge bases let the agent answer from the retailer's own policy documents during the call, and post-call automation can write the case to the CRM without code. Our pillar guide to enterprise AI voice agents covers the architecture in more depth.
The same diagnostic logic underpins our AI operating model consulting, which settles who owns each decision once an agent is answering the phone.
What should the call record capture for each remedy decision?
A retailer's call record for a faulty goods contact should capture the facts that decide which Consumer Rights Act tier is open: purchase, delivery and installation dates, the fault in the customer's words, any stated rejection with its timestamp, the remedy the customer asked for, any agreed repair or replacement with its start and end dates, and the reason for any decision a person made.
The record matters because each statutory clock turns on a date the phone call usually captures first. The 30-day period depends on delivery and installation dates. The pause depends on when a repair was agreed and when the goods came back. The final rejection trigger depends on whether one repair or replacement has already happened. If the record is thin, the retailer cannot compute the customer's entitlement, and the customer, or later a court, may compute it for them.
The fields we would treat as the minimum:
Order and consumer status: order reference, and confirmation the buyer is a consumer.
Dates: delivery date, installation confirmation date where relevant, and the date of the call.
Fault: a description in the customer's own words, and the model and serial number.
Stated remedy: what the customer asked for, recorded verbatim where they used rejection language.
Agreements: any agreed repair or replacement, with the start and end dates of the waiting period.
Returns: the collection arrangement, at the trader's cost under section 20(8) and section 23(2).
Decisions: who decided conformity, proportionality or rebuttal, when, and why.
Refund trigger: the date entitlement was agreed, which starts the 14 days under section 20(15).
That is eight fields, and the first six are capture work. Dilr Voice keeps full audit trails on every call, which means the words and timestamp of a stated rejection can be retrieved later. Our AI voice ROI framework shows how to put a cost on the handler time those capture steps currently take.
One more check sits alongside the call record. Section 31 makes a contract term not binding on the consumer to the extent that it would exclude or restrict the trader's liability under the conformity provisions, including quality, fitness and description, or make a remedy subject to a restrictive or onerous condition. Section 31 is about contract terms, so in our view the first place to look is the retailer's written terms and returns policy. A call script that recites a policy condition the statute makes non-binding repeats the same problem in spoken form, so the policy and the script should be reviewed together.
Top five clothing and footwear complaint issues, 2025Complaints to the Citizens Advice Consumer Service about clothing and footwear in 2025, out of 17,744 in total; faulty goods were the largest single issue at 18%. Source: Citizens Advice, press release 23 February 2026
Citizens Advice also reported that 82% of the clothing and footwear complaints, 14,487 of them, related to online orders, against 14% bought in store. That figure describes where the goods were bought, not which contact channel customers used, so read it as a sign of how much of the complaint load attaches to online sales. Our retail industry guide sets out where AI pays across the rest of the retail contact mix.
What is the best voice AI for faulty goods calls in 2026?
The best voice AI for faulty goods calls in 2026 is the one that captures statutory dates and rejection language accurately, answers from the retailer's own policy, keeps an audit trail of every call, and hands judgement cases to a person with full context. No platform is best for every retailer, and the right choice depends on the existing contact centre stack.
Buyers can compare three kinds of option. Contact centre suites such as Genesys and Five9 are established platforms, and adding automation inside an existing platform can be simpler than adding a new layer. Conversational AI vendors such as PolyAI offer voice agents for customer service. Developer platforms such as Vapi and Retell AI give engineering teams building blocks to assemble their own agent. Our comparison of AI voice agents for 2026 sets out how we think about the trade-offs.
The criteria that matter for a fault line are specific:
Date capture. Can the agent reliably collect delivery and installation dates and log waiting periods, not just a purchase date?
Verbatim logging. Does it record rejection language in the customer's own words with a timestamp?
Grounded answers. Does it answer policy questions from the retailer's own documents rather than from general knowledge?
Handover. Does it pass the case to a person with the fault history attached, so the customer does not repeat it?
Audit. Can the retailer retrieve the record of any call months later, when a final rejection or a dispute arrives?
There is one scenario where a new agent is the wrong answer. If the retailer's fault-line problem is a broken policy, such as a returns policy that conflicts with section 22(2) or charges collection costs, an agent will only deliver the wrong answer faster. Fix the policy first, then automate. Where the contact centre platform already supports the capture steps, configuring it may beat buying anything new.
Frequently asked questions
Can a retailer's returns policy shorten the 30-day right to reject?
No. Under section 22(2) of the Consumer Rights Act 2015, an agreement under which the consumer would lose the short-term right to reject before the 30-day time limit passes is not binding on the consumer. A retailer's returns policy can offer longer or more generous terms, but it cannot cut the statutory period short, and a phone script should never suggest that it does.
The trader and the consumer can agree to extend the period under section 22(1), and some retailers offer longer goodwill windows. Keep the statutory right and the goodwill policy clearly separated in the script.
Does a customer saying they want their money back on a call count as rejection?
Under section 20 of the Consumer Rights Act 2015, a consumer exercises the right to reject by indicating to the trader that they are rejecting the goods and treating the contract as at an end, in words or actions clear enough to be understood. A customer saying clearly on a call that they are rejecting faulty goods may therefore have exercised the right at that moment.
Whether a refund is owed still depends on whether the goods failed to conform and whether the time limit had passed. That is why the record should log the words and the timestamp, and leave the conformity decision to a person.
Who pays for returning or collecting faulty goods?
Under the Consumer Rights Act 2015, the retailer pays in most cases. When goods are rejected, section 20(8) puts the reasonable costs of returning them on the trader, except where the consumer returns them in person to the place they took possession. For a repair or replacement, section 23(2) requires the trader to bear the necessary costs, including labour, materials and postage.
A call that asks the customer to book and pay for a courier for a faulty item they are rejecting, or sending for repair, is likely asking for a cost the statute places on the retailer. Offer collection, and log the arrangement in the case.
30-min scoping call · No deck · Confidential. We will look at which parts of your faulty goods journey suit an agent, and which should stay with your team.
Written by the Dilr.ai engineering team, practitioners who ship enterprise AI in production. Follow us on LinkedIn for shipping notes, or subscribe via the RSS feed.
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Questions this article answers
What does the Consumer Rights Act require when a customer reports a fault?
The Consumer Rights Act 2015 treats every consumer contract for goods as including terms that goods are satisfactory in quality, fit for a purpose made known to the trader, and as described. Where goods breach those terms, section 19 gives three tiers of remedy, each with its own conditions: the short-term right to reject, repair or replacement, and a price reduction or the final right to reject. The trader, the retailer, owes them.
When does the 30-day short-term right to reject start and stop?
The short-term right to reject under the Consumer Rights Act 2015 lasts until the end of 30 days, counted from the first day after three things have all happened: ownership has passed to the consumer, the goods have been delivered, and, where the trader agreed to install them, the trader has told the consumer that is done. The clock does not start at the till, and it pauses while an agreed repair or replacement is under way.
How is the right actually exercised on a call?
Under the Consumer Rights Act 2015, a customer exercises the right to reject by telling the trader they are rejecting the goods and treating the contract as at an end. Section 20 asks only for an indication clear enough to be understood. That means a phone call can be the moment the right is exercised, and a retailer's call record may be the only evidence of when it happened.
How should a call handle the repair or replacement stage?
Under section 23 of the Consumer Rights Act 2015, once a consumer requires repair or replacement, the retailer must carry it out within a reasonable time and without significant inconvenience, and must bear the necessary costs, including labour, materials and postage. The consumer chooses which of the two, unless the chosen remedy is impossible or disproportionate compared with the other.
When can a customer ask for a price reduction or final rejection?
Under section 24 of the Consumer Rights Act 2015, a consumer may choose either a price reduction or the final right to reject, not both, in three situations only: one repair or one replacement has been carried out and the goods still do not conform; neither repair nor replacement can be required because both are impossible or disproportionate; or the trader failed to repair or replace within a reasonable time without significant inconvenience.
How does the six-month presumption change the call?
The Consumer Rights Act 2015 presumes that goods which fail to conform within six months of delivery did not conform on the day they were delivered. That shifts the evidence question onto the retailer for repair, replacement, price reduction and final rejection. The presumption does not apply to the short-term right to reject, and the retailer can rebut it.
Which steps can a voice agent handle and which stay with a person?
A voice agent on a retailer's fault line can handle the structured parts of the Consumer Rights Act journey: capturing the order reference and dates, recording the fault description and the customer's stated remedy, and logging a rejection in the customer's own words. Decisions that weigh evidence or cost, such as conformity, proportionality, rebuttal of the presumption and the amount of any reduction, should stay with a person.
What should the call record capture for each remedy decision?
A retailer's call record for a faulty goods contact should capture the facts that decide which Consumer Rights Act tier is open: purchase, delivery and installation dates, the fault in the customer's words, any stated rejection with its timestamp, the remedy the customer asked for, any agreed repair or replacement with its start and end dates, and the reason for any decision a person made.
DE
Dilr.ai Engineering
Engineering team
Dilr Voice
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