What a money-back guarantee has to refund

The short answer

The Federal Trade Commission publishes Guides for the Advertising of Warranties and Guarantees. One section of them addresses satisfaction guarantees and similar representations, and it sets a single standard.

A seller or manufacturer should use the terms Satisfaction Guarantee, Money Back Guarantee, Free Trial Offer, or similar representations in advertising only if the seller or manufacturer refunds the full purchase price of the advertised product at the purchaser's request.

Two things in that sentence do the work. The amount is the full purchase price, not a partial credit and not store credit. And the trigger is the purchaser's request, not the seller's agreement that the request is reasonable.

The guides then permit conditions, on one condition of their own. An advertisement that mentions a satisfaction guarantee or a similar representation should disclose, with such clarity and prominence as will be noticed and understood by prospective purchasers, any material limitations or conditions that apply.

The conditions have to travel with the phrase

The guides illustrate the disclosure requirement with two examples, and both put the condition inside the same sentence as the promise.

One is an advertisement mentioning a satisfaction guarantee conditioned on return of the unused portion within thirty days, phrased as a guarantee of satisfaction followed by the instruction to return the unused portion within thirty days for a full refund. The other is a money-back guarantee conditioned on return of the product in its original packaging, phrased as the guarantee followed by the instruction to return the item in its original package.

The structural point is the placement. In both examples the limitation is not on a separate page, not in a policy document, and not below a fold. It is attached to the claim it limits.

That is a specific answer to a common pattern, where a headline promises money back and a terms page later narrows the promise to an unopened container, a short window, a restocking deduction, or a first order only. The guides do not forbid any of those conditions. They ask that a reader see them at the same time as the promise.

What counts as a similar representation

The guides name three phrases and then extend to similar representations, which is deliberately open-ended.

Satisfaction Guarantee, Money Back Guarantee and Free Trial Offer are the named ones. Free Trial Offer sitting in that list is the detail most often missed, because a free trial is usually thought of as a subscription mechanic rather than a guarantee. Under these guides it is a representation held to the full-purchase-price standard.

The open-ended extension means the test is not whether a particular wording appears. It is whether the representation conveys the same thing to a prospective purchaser. Risk free, love it or your money back, and try it and see all point at the same promise.

None of this decides whether a specific offer is or is not one of these representations. That depends on the words used and what a reader would take from them, which is a question about a particular page.

The pointer an advertisement is supposed to carry

A separate section of the guides deals with advertisements that mention a warranty or guarantee rather than describing one in full, and it asks for a pointer to the complete terms.

Where an advertisement mentions a warranty or guarantee offered on the advertised product, it should disclose, with such clarity and prominence as will be noticed and understood by prospective purchasers, that prior to sale, at the place where the product is sold, prospective purchasers can see the written warranty or guarantee for complete details of the coverage.

The guides supply worked examples of wording sufficient to convey that, and the pattern in all of them is the same: a short claim, then an instruction naming where the full document can be read before buying.

There is a distinct version for remote selling. Where an advertisement in a catalogue, or in any other solicitation for mail order or telephone order sales, mentions a warranty or guarantee offered on the advertised product, it should disclose, with the same clarity and prominence, that prospective purchasers can obtain complete details of the written warranty or guarantee free from the seller upon specific written request, or from the catalogue or other solicitation, whichever applies.

The examples given for that version include an instruction to write for a free copy at a named address, and a statement that the limited warranty can be read in the catalogue itself.

The common element across both is that the reader is told where to find the full text and that obtaining it costs nothing. An advertisement mentioning a guarantee and giving no route to the terms is not the shape these guides describe.

This section is the one carrying the narrower scope limit, so what it reaches depends on the Magnuson-Moss definitions discussed below. The pointer it describes is still a reasonable thing to look for in any offer that mentions a guarantee.

The lifetime problem, and the performance rule

A separate section handles duration claims. If an advertisement uses lifetime, life, or similar representations to describe the duration of a warranty or guarantee, the advertisement should disclose, with such clarity and prominence as will be noticed and understood by prospective purchasers, the life to which the representation refers.

The guides' own examples make the ambiguity concrete: a lifetime guarantee on an automobile muffler measured by the life of the car it is installed in, versus a lifetime guarantee on a battery measured by how long the original purchaser owns the car. The same word describes two different periods.

The final section is one sentence and it is about conduct rather than wording. A seller or manufacturer should advertise that a product is warranted or guaranteed only if the seller or manufacturer promptly and fully performs its obligations under the warranty or guarantee.

That closes a gap the disclosure rules leave open. A perfectly disclosed guarantee that is not honoured is addressed by this section rather than by the ones about what the advertisement says.

Where the guides stop, and what else is running

The guides set out their own scope in their first section, and it is not uniform across the part. The disclosure section on warranty advertising applies only to advertisements for written warranties on consumer products, as written warranty and consumer product are defined in the Magnuson-Moss Warranty Act, and that are covered by the pre-sale availability rule. The other sections of the guides apply to the advertising of any warranty or guarantee.

Whether a given preparation sold in this market falls inside those statutory definitions is a question about that product, and this article does not answer it in either direction.

The guides also say what they are not. They do not purport to anticipate all possible unfair or deceptive acts or practices in the advertising of warranties or guarantees, and they should not be interpreted to limit the Commission's authority to proceed under section 5 of the Federal Trade Commission Act. The guides state that the Commission may bring an action under section 5 against an advertiser who misrepresents the product or service offered, who misrepresents the terms or conditions of the warranty offered, or who employs other deceptive or unfair means.

Separately, a guarantee is only one of several routes by which money comes back. A shipping rule, a card network dispute process and a seller's own refund policy all run on different clocks and need different paperwork, and none of them starts by itself.

What a reader can check before paying

The guides suggest a short list of questions, each of which is answerable from a seller's own published pages.

What amount does the guarantee return, and is it described as the full purchase price or as something less. What triggers it, a request or an assessment. What conditions apply, and are they printed beside the promise or somewhere else. If a duration word like lifetime is used, whose life or what life does it refer to.

Then one question the guides do not answer, because no document can: whether the guarantee is honoured in practice. The performance section addresses that as an obligation, not as a fact a reader can verify in advance.

A guarantee published without its conditions is not evidence of bad faith. It is evidence that the conditions are somewhere else, and finding them is work the reader has to do before rather than after.

Sources

Each document below is named as it names itself, with the date printed on that document rather than the day it was read.

1. Title 16 Code of Federal Regulations Part 239, Guides for the Advertising of Warranties and Guarantees, read in full — the scope and Magnuson-Moss limiting sentence at 239.1, the pre-sale availability disclosure at 239.2 with both example blocks and its two footnotes, the satisfaction and money back guarantee standard at 239.3, the lifetime duration rule at 239.4, and the performance obligation at 239.5; Source note 50 FR 18470, May 1, 1985, as amended at 50 FR 20899, May 21, 1985 — Electronic Code of Federal Regulations, Office of the Federal Register, September 2026