Short answer: Reply in writing quickly, keep every record, and check whether the complaint is about an unfair practice or goods that were defective on delivery. Consumers usually go to CASE first, then to the Small Claims Tribunals (up to S$20,000, or S$30,000 by consent) within 2 years. Persistent offenders face CCS injunctions.
When a customer threatens to file a CPFTA claim, the first question is what that means and how much is at stake. This guide explains a CPFTA claim in Singapore from the supplier’s side: what the Consumer Protection (Fair Trading) Act 2003 (CPFTA) actually lets a consumer do, the lemon law rules on defective goods, the routes a complaint can take, the time and money limits, and the practical steps and records that protect your business.
Key facts at a glance
- A consumer may sue a supplier for an unfair practice under section 6 CPFTA, but only for claims up to the prescribed limit of S$30,000 (section 6(6)); the consumer can abandon any excess.
- The Small Claims Tribunals (SCT) hear CPFTA unfair practice claims up to S$20,000, or S$30,000 if both parties sign a Memorandum of Consent, and lawyers cannot represent parties there.
- A section 6 action must start within 2 years of the last material event or of the consumer first knowing of the unfair practice, whichever is later (section 12(1)).
- Under the lemon law (Part 3, sections 13 to 18), goods that turn out not to conform within 6 months of delivery are presumed to have been defective at delivery (section 14(3)).
- CASE handles local consumer complaints first; persistent offenders are referred to the Competition and Consumer Commission of Singapore (CCS), which can ask the District Court or High Court for declarations and injunctions (section 9).
- Obstructing a CCS investigation, or giving it false information, can lead to a fine of up to S$10,000, up to one year’s imprisonment, or both.
Raffles Corporate Services works with a panel of experienced Singapore law firms who offer cost-effective and efficient legal service and advice. This article is general information only and is not legal advice.
What is a CPFTA claim, and does the Act apply to my business?
A CPFTA claim is a civil claim by an individual consumer against a business that has engaged in an unfair practice, or that sold goods which did not conform to the contract. If your business supplies goods or services to individuals in Singapore, the Act applies to you.
Under section 2, a consumer is an individual acting otherwise than exclusively in the course of business, so a company buying office supplies is not one. A supplier is anyone who, in the course of business, provides, makes, promotes or is paid for goods or services, including its employees and agents. Part 2 applies where either party is resident in Singapore, or the offer or acceptance is made in or sent from Singapore (section 3).
Section 4 defines an unfair practice as doing or saying anything (or failing to) that might reasonably deceive or mislead a consumer, making a false claim, or taking advantage of a consumer who cannot protect their own interests. The Second Schedule lists examples, such as claiming qualities or benefits goods do not have, selling used goods as new, advertising a discount that does not exist, charging substantially more than an estimate without the consumer’s prior express agreement, and using harsh or excessively one-sided terms.
Under section 5, an unfair practice can happen before, during or after the sale, a single act is enough, and what your staff or agents say in the course of their work is treated as what your business said.
What is the legal basis, and how does the lemon law work?
The consumer’s main rights come from section 6 (unfair practices) and Part 3 (the lemon law for non-conforming goods). Court procedure outside the tribunal is governed by the Rules of Court 2021.
| Provision | What it does | Why it matters to you |
|---|---|---|
| CPFTA s 6 | Consumer may sue for an unfair practice; claims capped at S$30,000 | Your maximum exposure in a CPFTA unfair practice action |
| CPFTA s 7(7) and (8) | No relief for goods or services intended for business use; mixed use can be apportioned | A useful point if the buyer was really buying for a business |
| CPFTA s 7(10) and (11) | Court must consider whether the consumer tried to minimise loss and to resolve the dispute with you first | A written offer to resolve helps you later |
| CPFTA ss 13 to 18 | Lemon law: repair, replace, price reduction or rescission | Applies to defective goods, not services |
| Rules of Court 2021, O 5 r 1 | Duty to consider amicable resolution; offer to settle before suing | Applies to both sides in court proceedings |
| Rules of Court 2021, O 6 r 1 | Proceedings start by originating claim where facts are disputed | How a larger claim would be started in court |
The lemon law applies where the buyer deals as consumer, the goods did not conform to the contract at delivery, and the contract was made on or after 1 September 2012 (section 14(1)). Goods do not conform if they breach an express term or the implied terms of the Sale of Goods Act 1979, such as satisfactory quality and fitness for purpose.
- Presumption: if the defect shows up within 6 months of delivery, the law presumes it existed at delivery, unless you prove otherwise or the presumption does not fit the nature of the goods (section 14(3) and (4)). After 6 months, the consumer must prove the defect existed at delivery.
- Repair or replace first: the consumer may require repair or replacement, which you must do within a reasonable time, without significant inconvenience, and at your own cost, including labour, materials and postage (section 15(2)). The Act does not set a fixed number of days; what is reasonable depends on the goods and why they were bought (section 15(5)).
- Proportionality: you can resist a remedy that is impossible or disproportionate compared with the alternatives (section 15(3) and (4)).
- Price reduction or rescission: only if repair and replacement are not available, or you failed to repair or replace within a reasonable time (section 16(2)). If the contract is rescinded, the refund may be reduced for the use the consumer has had of the goods (section 16(3)).
The lemon law covers goods only; complaints about services are framed as unfair practices or breach of contract.
Which routes can a CPFTA claim in Singapore take?
A complaint usually moves through up to four stages: CASE negotiation or mediation, a claim in the Small Claims Tribunals, a civil action in court, and, for repeat offenders, CCS enforcement.
| Route | Who starts it | Limits and time | Possible outcome for the business |
|---|---|---|---|
| Consumers Association of Singapore (CASE) | Consumer | No court filing; CASE is the first point of contact for local consumers | Negotiated or mediated settlement; a Voluntary Compliance Agreement (VCA) for errant retailers |
| Small Claims Tribunals (State Courts) | Consumer (or the business, for its own claims) | Up to S$20,000, or S$30,000 with a Memorandum of Consent; file within 2 years of the event | Order to pay, refund, repair or do something; most cases conclude within 4 months of filing |
| Civil court action | Consumer, through a lawyer or in person | Section 6 claims capped at S$30,000; larger disputes are usually run as contract or misrepresentation claims | Damages, restitution, specific performance, contract variation, plus costs |
| CCS enforcement | CCS | Generally within 2 years of the last material event (section 12(3)) | Declaration, injunction, publicity and notification orders |
CASE is not a court. It helps consumers obtain redress through negotiation or mediation, and errant retailers may sign a VCA in which they agree in writing to stop the practice and, in some cases, compensate affected consumers. If you then fail to pay compensation promised in a VCA, the consumer can recover it as a civil debt (section 8(6)), within one year of the failure (section 12(2)).
For the SCT itself, including filing, consultations, hearings and enforcement, see our existing guides on how a Small Claims Tribunal claim runs for a company and enforcing an unpaid Small Claims Tribunal order. The official eligibility rules are on the Singapore Courts’ small claims eligibility page.
CCS (the Competition and Consumer Commission of Singapore, which used the abbreviation CCCS until 2025) does not act for individual consumers. According to its overview of the CPFTA, it takes on persistent errant retailers referred to it. It can investigate and require documents (sections 19 and 20), and apply to the District Court or High Court for a declaration and injunction (section 9). Accompanying orders can require you to publicise the injunction, tell new customers about it in writing before they sign, and print a statement on every invoice, for up to 5 years. Breaching an injunction can be punished as contempt of court.
What should your business do when a customer threatens a claim?
Treat the threat as the start of a dispute file. A prompt, written, documented response puts you in a better position if the matter reaches CASE or the tribunal.
- Acknowledge in writing within a day or two. Confirm you have received the complaint and when you will respond in full.
- Identify what the complaint is really about. Is it a defect in goods (lemon law), something said or advertised (unfair practice), a pricing issue, or a cancellation or refund policy dispute?
- Check the dates. When was the sale, when were the goods delivered, and when did the problem appear? A defect within 6 months of delivery is presumed to have existed at delivery.
- Freeze and collect the evidence. Save the order, invoice, terms accepted, chat and email history, advertisements and web pages as they stood at the time of sale, delivery records, and any repair reports.
- Offer an appropriate remedy where the complaint has merit. For defective goods, offer repair or replacement at your cost within a stated, reasonable time. Put any offer in writing and keep it open for a reasonable period.
- Respond in full in writing. Set out the facts, the remedy offered or the reasons for declining, and invite the customer to resolve the matter through CASE if they disagree.
- If CASE contacts you, engage. Reply by its deadline, attend mediation, and record any settlement in a short written agreement with clear payment or repair terms.
- If you receive a Notice of Consultation from the SCT, diarise the date immediately. Both parties must attend, and if you do not, the tribunal may make an order against you. Someone from the company attends with a Letter of Authorisation on the company’s letterhead, which the Courts ask to see at every session; lawyers cannot represent parties in the SCT.
- If a lawyer’s letter or court papers arrive, or CCS writes to you, stop corresponding informally and speak to a lawyer before replying.
Which records and documents should you keep?
Keep a record of each consumer sale, what was said about the product, and every step of the complaint.
| Document | Why it matters |
|---|---|
| Invoice, receipt and order confirmation | Proves what was sold, at what price, and the date |
| Terms and conditions accepted by the customer, with the version date | Shows refund, cancellation and warranty terms in force at the time |
| Advertisements, product pages, brochures and price displays at the time of sale | Answers allegations of misleading claims or false discounts |
| Delivery note or courier proof of delivery | Starts the 6-month lemon law presumption period |
| Inspection, repair and replacement reports | Shows the defect was dealt with within a reasonable time |
| Complaint log, emails, chat messages and call notes | Shows you tried to resolve the dispute, which a court must consider under section 7(10) |
Record refunds, credit notes and replacement costs properly in your accounts; our guide to reconciling marketplace fees, refunds and revenue covers the accounting side for online sellers.
How long does it take and what does it cost?
If a claim goes to the SCT, official filing fees are modest and most cases conclude within 4 months of filing. Court proceedings take longer and cost more.
| Stage | Typical timing | Cost drivers |
|---|---|---|
| Internal complaint handling | Days to a few weeks | Staff time; repair or replacement cost; goodwill gesture |
| CASE negotiation or mediation | Weeks, depending on both parties | Management time; settlement amount |
| SCT claim | Most cases conclude within 4 months of filing | Filing fee for a claim or counterclaim by a company: S$50 up to S$5,000; S$100 above S$5,000 up to S$10,000; 3% of the amount above S$10,000 up to S$30,000 (individuals pay S$10, S$20 or 1%) |
| Civil court action | Months to over a year | Lawyers’ fees, court fees, adverse costs if you lose; time spent on evidence and witnesses |
| CCS investigation and injunction | Varies with the investigation | Legal fees, compliance programme, publicity and notification orders for up to 5 years |
SCT fees: Singapore Courts’ filing and service page. Other costs depend on the facts.
What does the company secretary prepare, and what does the solicitor do?
Your corporate service provider keeps the company’s records and authorisations in order; a Singapore Advocate and Solicitor gives legal advice and conducts any court proceedings. In the SCT, the company is represented by its own authorised person, because lawyers cannot appear there.
- The company secretary or corporate service provider can prepare the Letter of Authorisation for the company’s representative, obtain the ACRA business profile (the Courts ask a filing business for one obtained within 1 month of filing), keep registered details current so notices reach you, and keep the accounting records for refunds and settlements.
- A solicitor advises on liability, replies to lawyers’ letters, and conducts any civil action or CCS proceedings. Court proceedings under the Rules of Court 2021 are conducted by a Singapore Advocate and Solicitor.
Raffles Corporate Services does not give legal advice or appear in court. Where a dispute needs a lawyer, we refer clients to our panel of Singapore law firms. If you are setting up a consumer-facing business, our guide to setting up an online business, including consumer protection compliance covers the groundwork, and our corporate secretarial team can keep your statutory records in order.
What are the common mistakes businesses make?
These errors turn a manageable complaint into a claim:
- Relying on a “no refund, no exchange” sign. A shop policy does not remove a consumer’s lemon law rights for goods that were defective on delivery.
- Insisting the defect is the customer’s fault within the first 6 months without evidence. The burden is on you to show the goods conformed at delivery.
- Promising a repair and then taking too long. Unreasonable delay opens the door to a price reduction or rescission (section 16(2)).
- Ignoring CASE or an SCT notice. Missing the consultation can lead to an order made in your absence.
- Assuming the matter is closed. A section 6 claim can be brought up to 2 years from when the consumer learned of the unfair practice.
Frequently asked questions
Can a customer claim more than S$30,000 under the CPFTA?
Not under section 6. The prescribed limit for a CPFTA unfair practice action is S$30,000, and a consumer with a larger claim may abandon the excess to stay within it.
Does the lemon law mean I must give a refund?
Not at first. The consumer may require repair or replacement, and only if those are impossible, disproportionate, or not done within a reasonable time can the consumer ask for a price reduction or rescind the contract. A refund on rescission may be reduced for the use the consumer has had.
Can my company send a lawyer to the Small Claims Tribunals?
No. Lawyers are not allowed to represent parties in SCT proceedings. The company sends its own representative who knows the facts, with a Letter of Authorisation on company letterhead and the documents organised in order.
Is CASE a court?
CASE is a consumer association, not a court. Taking part in its negotiation or mediation is usually sensible: in a later section 6 action, the court must consider whether the consumer made a reasonable effort to resolve the dispute with you first, and a business that engaged in good faith is better placed.
Can a director be personally affected?
CCS can seek an injunction against any person who knowingly abets, aids, permits or procures a supplier’s unfair practice (section 10), which can include individuals running the business.
Need help with this?
Raffles Corporate Services can handle the ACRA filings, compliance documentation and records for you, and where court proceedings or legal advice are needed, we work with a panel of experienced Singapore law firms who offer cost-effective and efficient legal service and advice.
Email: [email protected]
Call, SMS or WhatsApp: +65 8501 7133
Last reviewed: 20 October 2026. The Editorial Team, Raffles Corporate Services.