Good to know. I've been asking CoPilot about it and it's produced a detailed complaint that people could adapt and send to Trading Standards:
Trading Standards Complaint
Retailer: Cult Beauty Ltd (part of THG plc)
Issue: Potential breaches of the Consumer Protection from Unfair Trading Regulations 2008 relating to a loyalty promotion, retrospective order cancellations, and account closures
1. Business details
• Retailer: Cult Beauty Ltd
• Business type: Online retailer of beauty products
• Parent company: THG plc (The Hut Group)
2. Nature of the complaint
This complaint concerns Cult Beauty’s handling of a loyalty promotion offering enhanced reward points (equivalent to £XX credit) for purchases made on 12 April 2026.
Following participation in the promotion, Cult Beauty cancelled confirmed customer orders, closed customer loyalty accounts, and imposed bans on future shopping. The complainant is concerned that these practices may fall foul of the Consumer Protection from Unfair Trading Regulations 2008, particularly provisions relating to misleading omissions, unfair commercial practices, and professional diligence.
3. Summary of events
• Cult Beauty advertised a loyalty promotion offering 100 - 200 points for purchases made on 12 April 2026.
• Customers with loyalty status made purchases in good faith in reliance on the promotion as presented.
• Orders were accepted and confirmed by Cult Beauty.
• After confirmation, some orders were cancelled.
• Customer accounts were closed without advance warning.
• Permanent bans from future shopping were imposed.
• Other consumers engaging in similar or more extensive purchasing behaviour under the same promotion were not subject to the same actions.
4. Potential breaches of the Consumer Protection from Unfair Trading Regulations 2008
a) Misleading omissions – Regulation 6
Regulation 6 prohibits misleading omissions of material information that the average consumer needs to make an informed transactional decision.
• The promotion did not clearly disclose any minimum spend, transaction limits, or restrictions on how purchases could be made.
• Customers were not informed that certain purchasing behaviour could result in cancellations or sanctions.
• These restrictions appear to have been introduced or enforced only after consumers had already acted.
The omission of these material conditions may have caused consumers to take transactional decisions they would not otherwise have taken.
b) Unfair commercial practices – Regulation 3
Regulation 3 requires traders to act in accordance with professional diligence and prohibits unfair commercial practices.
• Cult Beauty retrospectively cancelled confirmed orders without clearly identifying any breached term.
• Customers who relied on order confirmations were later deprived of the transaction.
• Enforcement appears inconsistent, with materially similar consumer behaviour treated differently.
These practices raise concerns that the retailer did not act with the level of professional diligence reasonably expected of an online retailer.
c) Misleading actions or practices – Regulation 5 (by conduct)
While no explicit false statements appear to have been made, the overall conduct of confirming orders and later cancelling them without clear justification may amount to a misleading practice by action.
• Order confirmations reasonably conveyed that transactions were valid and complete.
• Subsequent cancellation contradicted this representation.
• Consumers may have been misled regarding the security and finality of their purchases.
d) Aggressive or disproportionate commercial practices – Regulation 7 (contextual concern)
While not alleging harassment or coercion, the imposition of severe consequences may be relevant context.
• Permanent account closure and bans from future shopping were imposed for first‑time use of a promotion.
• Less intrusive remedies (for example, removal of points or clarification of the promotion) were available but not used.
Such disproportionate responses may contribute to an overall unfair commercial practice when assessed cumulatively.
5. Consumer detriment
• Loss of confirmed orders.
• Loss of loyalty points, credit and accounts.
• Permanent exclusion from a retailer without clear contractual or promotional justification.
• Consumer trust undermined due to unclear rules and inconsistent enforcement.
• Consumers penalised for foreseeable behaviour encouraged by the promotion.
6. Outcome sought
The complainant requests that Trading Standards consider:
• Whether the promotion involved misleading omissions under Regulation 6;
• Whether retrospective cancellation of confirmed orders and account bans comply with Regulation 3 duties of professional diligence;
• Whether consumers were misled by confirmation of orders followed by cancellation;
• Whether Cult Beauty’s enforcement of its promotion meets the standards required under the CPRs;
• Whether guidance, advice, or enforcement action is appropriate to prevent recurrence.
7. Closing statement
Consumers are entitled to rely on the clarity of promotional offers and the confirmation of transactions. Retailers should not retrospectively penalise consumers for behaviour that was foreseeable and permitted under a promotion as presented. The complainant believes Cult Beauty’s conduct merits review under the Consumer Protection from Unfair Trading Regulations 2008.