Alex is Sprintlaw's co-founder and principal lawyer. Alex previously worked at a top-tier firm as a lawyer specialising in technology and media contracts, and founded a digital agency which he sold in 2015.
Customer refund requests are just part of doing business in New Zealand - whether you sell products online, run a retail shop, or provide services. Some requests will be totally fair and straightforward. Others might feel unreasonable, aggressive, or based on misunderstandings (especially if a customer simply changed their mind).
The tricky part is that refunds aren’t only about customer service. They’re also a legal compliance issue. If you handle refund requests the wrong way, you can end up with disputes, reputational damage, and (in some cases) regulator attention.
This guide breaks down how to deal with refund requests in a way that’s fair, practical, and aligned with key NZ consumer laws - without drowning you in legal jargon.
What Does NZ Law Actually Say About Refunds?
In New Zealand, the “refund rules” mostly come from two key laws:
- The Consumer Guarantees Act 1993 (CGA) - this sets minimum guarantees for goods and services supplied to consumers (for personal, domestic, or household use).
- The Fair Trading Act 1986 (FTA) - this focuses on misleading conduct, false representations, and unfair practices in trade (including how you advertise your refund policy).
These laws matter because they can override what your store policy says. So even if your website says “no refunds”, you may still need to provide an appropriate remedy in certain situations.
Refunds vs “Remedies” (Why The Difference Matters)
When customers make refund requests, they’re usually asking for their money back. Legally, though, the remedy might be one of the following (depending on the situation):
- a repair
- a replacement
- a refund
- compensation for loss (in some cases)
For goods and services covered by the CGA, the appropriate remedy depends on the circumstances - including whether the problem is considered minor or substantial, and whether it can be remedied within a reasonable time. Getting this classification right is one of the biggest “make or break” points in handling refund requests properly.
When Are You Required To Provide A Refund?
Under the CGA, a customer may be entitled to a refund (rather than only a repair or replacement) where:
- the issue with the goods or services is substantial (for example, it’s unsafe, very different from what was described, or can’t be fixed easily), or
- you can’t fix the issue within a reasonable time, or
- you refuse to fix the issue, or
- a repair fails and the issue continues.
Even if your business prefers repairs first (which is common), you still need a process that can escalate to a refund where the law requires it.
When Can You Say “No” To A Refund?
Not every refund request is legally required. Common situations where a refund might not be required include:
- Change of mind (for example, the customer decided they don’t like the colour or size) - unless you promised change-of-mind returns in your policy.
- Customer damage or misuse (for example, they broke it by using it contrary to instructions).
- They knew about the fault before buying and still purchased it anyway (this often comes up with “seconds” or clearly disclosed defects).
- Business-to-business sales (the CGA generally applies to consumers, not businesses, though the FTA still matters).
The key is to respond in a calm, consistent way, and to base your decision on facts - not frustration. (Easier said than done, we know.)
How To Assess Customer Refund Requests Step-By-Step
When you’re dealing with refund requests regularly, it helps to have a repeatable internal process. This reduces back-and-forth, keeps your team consistent, and makes your decisions easier to justify if the customer escalates the complaint.
Step 1: Confirm Who Bought It And When
Start by checking:
- proof of purchase (receipt, invoice, order confirmation email)
- purchase date (how long ago was it?)
- what exactly was purchased (SKU, model, service package, etc.)
Time matters because some products naturally wear out over time. The CGA doesn’t give a fixed refund window (like “30 days”), but it does look at what a consumer would reasonably expect for that type of goods or services.
Step 2: Clarify The Reason For The Refund Request
Ask simple, practical questions:
- What’s wrong with the item/service?
- When did the issue start?
- How has it been used?
- What outcome are they asking for: refund, replacement, repair, store credit?
In many cases, refund requests come down to communication issues - a customer expected one thing, received another, and doesn’t know what the law actually provides.
Step 3: Decide Whether The CGA Applies
As a starting point, the CGA generally applies when:
- you supplied goods or services in trade, and
- the customer purchased as a consumer (personal/domestic/household use).
If you sell business-to-business, it may be possible to contract out of the CGA in some cases - but only where the statutory requirements are met (including that it’s a supply in trade to another business, and the contracting-out term is in writing and fair and reasonable). This needs to be done carefully.
Step 4: Work Out Whether The Problem Is Minor Or Substantial
This is where many businesses get stuck. A practical way to think about it is:
- Minor issue: can be fixed within a reasonable time, and the product/service is still broadly usable for its purpose.
- Substantial issue: is unsafe, significantly different from description/sample, can’t be fixed easily, or is so serious a reasonable consumer wouldn’t have bought it if they knew.
If it’s minor, you can usually choose to repair, replace, or fix the service (as applicable). If it’s substantial, the customer can often reject the goods and ask for a refund (or replacement).
Step 5: Put The Outcome In Writing
Even if you resolve the refund request quickly, a short written confirmation helps prevent disputes later. Keep it simple:
- what was requested
- what you agreed to do
- timeframes (for repair, replacement, or refund processing)
- any return instructions or conditions (e.g. bring item in, include accessories)
This is also helpful internally if another staff member has to pick up the issue later.
Refund Policies: What You Can Set, And What You Can’t
A clear refund policy is one of the best tools for reducing stressful refund requests. But it needs to be written carefully - because the way you describe refunds can create obligations under the FTA, and you generally can’t contract out of key consumer rights in consumer sales.
If you don’t already have them, it’s worth putting proper Terms & Conditions in place that cover refunds, returns, and exchanges in a way that fits how your business actually operates.
What Your Refund Policy Should Cover
At a practical level, your policy should address:
- Change-of-mind returns: do you offer them? If yes, what are the conditions (time limit, original packaging, proof of purchase, exclusions)?
- Faulty goods: explain that customers have rights under NZ consumer law (and outline your process).
- Refund method: original payment method vs store credit (store credit generally shouldn’t replace a legal refund where a refund is required).
- Timeframes: how long processing takes once approved.
- Online orders: return shipping, who pays for shipping, and any special requirements.
For ecommerce businesses, it’s also common to set expectations through a clear Shipping Policy, because many refund requests start with delivery delays, missed delivery windows, or confusion about tracking.
“No Refunds” Signs: Be Careful
Blanket “no refunds” wording can be risky because it may mislead customers about their rights under the CGA. If a customer sees “no refunds” and thinks they have no rights for faulty goods, that can create Fair Trading Act issues.
If you want to limit change-of-mind returns, you can say something like “We don’t offer refunds for change of mind” - but you should avoid language that suggests customers can’t get a remedy for faulty goods.
Don’t Overpromise In Your Marketing
Another common trap is advertising “30-day money-back guarantee” or “hassle-free refunds” without having the systems (or exceptions) clearly defined.
Remember: if you promise something in advertising, on product pages, in DMs, or via customer support, you can end up having to honour it - even if your formal policy says something else. Consistency matters.
Handling Difficult Or High-Risk Refund Disputes
Most refund requests are resolved quickly. But some situations need extra care - especially when customers threaten complaints, social media posts, or chargebacks.
Chargebacks And Payment Disputes
A chargeback is when a customer disputes a card transaction through their bank/payment provider. While this isn’t “consumer law” in the same way as the CGA, your refund process can reduce chargeback risk by:
- providing clear written outcomes and timeframes
- keeping evidence (photos, assessment notes, customer emails)
- making it easy for customers to contact you first (before escalating)
If you run an online business, your terms should ideally deal with payment disputes and the process for resolving complaints before escalation.
If The Customer Is Abusive Or Unreasonable
You can still enforce respectful behaviour in your store or customer service channels. However, be careful not to refuse a valid remedy just because the customer is rude.
A practical approach is to:
- keep communications in writing where possible
- respond calmly, sticking to the facts and your process
- offer a path to resolution (inspection, assessment, repair/refund decision)
- set boundaries about abusive behaviour
Services: Refund Requests Can Be More Complex
Refund requests for services often involve disputes about quality, scope, or expectations. Under the CGA, services must be carried out with reasonable care and skill, be fit for purpose, and completed within a reasonable time (unless otherwise agreed).
If you regularly supply services, having a properly drafted Service Agreement can help set clear deliverables, timelines, exclusions, and limitations - which reduces “surprise” refund demands.
That said, contracts can’t take away core consumer rights in many consumer transactions, so it’s important to get the wording right for your specific customer base.
Prevention: How To Reduce Customer Refund Requests Without Breaking The Rules
The best way to handle refund requests is to stop avoidable ones from happening in the first place. Many refund requests come from unclear expectations rather than truly faulty products.
Make Product And Service Descriptions Accurate
The FTA prohibits misleading or deceptive conduct. So ensure your product pages, ads, and packaging accurately describe:
- size, dimensions, and materials
- compatibility and limitations
- what’s included (and what isn’t)
- expected performance and realistic outcomes
This is also where solid internal checks on marketing claims really pay off. A “too good to be true” claim might generate sales, but it can also generate refund requests (and complaints) later.
Use A Clear Returns/Refund Process (Not Just A Policy)
A policy is what you say you’ll do. A process is what your team actually does day-to-day.
Your internal process might include:
- a standard set of questions staff must ask
- required evidence (photos, order number, proof of purchase)
- inspection procedures
- approval thresholds (e.g. manager sign-off over $X)
- templated email responses (so everyone stays consistent)
If you want a practical overview of how refunds and returns fit into broader consumer compliance, the returns and refunds fundamentals are a good starting point.
Be Careful With Disclaimers
Disclaimers can help clarify expectations (especially around results, timelines, or third-party factors), but they don’t let you opt out of the CGA where it applies.
If you use disclaimers in marketing, websites, or service delivery, it’s worth ensuring they’re properly drafted and consistent with your other documents, including any Disclaimer wording you publish publicly.
Warranties And “Manufacturer Warranty” Confusion
Customers often think they must go to the manufacturer for warranty issues, or that a “warranty period” limits their rights. Under NZ consumer law, customers may have rights against the supplier (you) even beyond an express warranty, depending on what’s reasonable for that type of product.
This is why it’s important that your team understands how warranties and CGA remedies interact. If your products come with warranties against defects, having a clear policy can help you respond consistently - including a properly drafted Warranties Policy where relevant.
Key Takeaways
- Refund requests should be handled with both customer experience and NZ legal compliance in mind - the key laws are the Consumer Guarantees Act 1993 and the Fair Trading Act 1986.
- You may be required to provide a refund where a problem is substantial, can’t be fixed within a reasonable time, or you refuse (or fail) to remedy the issue.
- Change-of-mind refunds usually aren’t legally required, but if you offer them in your policy or advertising, you should honour what you promised.
- A strong refund policy helps, but it can’t override core consumer rights - and “no refunds” wording can create problems if it misleads customers about CGA remedies.
- Having the right legal documents in place (like Terms & Conditions and a Service Agreement) can reduce refund disputes by setting expectations clearly from day one.
- Clear product descriptions, consistent internal processes, and well-drafted disclaimers can prevent avoidable refund requests and protect your business as you grow.
Note: This article is general information only and doesn’t take into account your specific situation. It isn’t legal advice.
If you’d like help setting up your refund policy, Terms & Conditions, or a customer-facing process that’s compliant with NZ consumer law, you can reach us at 0800 002 184 or team@sprintlaw.co.nz for a free, no-obligations chat.







