European UnionA business used fake reviews to promote their product. Is this considered unfair?
Yes, using fake reviews to promote a product is considered unfair under EU law because it misleads consumers and distorts competition.
What the Law Says
The EU prohibits fake reviews as a clearly defined unfair commercial practice. The Unfair Commercial Practices Directive sets binding rules across all Member States to protect consumers from misleading and aggressive tactics.
Under the Unfair Commercial Practices Directive (UCPD), a commercial practice is unfair if it 'distorts or is likely to distort the average consumer's economic behaviour' — including by withholding material information or providing false information.
Fake reviews fall squarely within this definition because they create a false impression of independent consumer experience, directly influencing purchasing decisions.
Crucially, the Directive’s ‘blacklist’ in Annex I explicitly bans 'falsely representing oneself as a consumer' — which includes posting fake reviews while pretending to be an ordinary customer.
Statutory TextA commercial practice is unfair if it is contrary to the requirements of professional diligence and materially distorts or is likely to materially distort the economic behaviour with regard to the product of the average consumer.
— Directive 2005/29/EC, Art. 5(2)
Statutory TextFalsely representing oneself as a consumer
— Directive 2005/29/EC, Annex I, No. 11
What to Do
Stop publishing or commissioning fake reviews immediately.
Remove all existing fake reviews from your website and third-party platforms.
Cooperate fully with national enforcement authorities (e.g., national consumer protection agencies).
Implement internal compliance measures — e.g., clear review collection policies, staff training, and audit trails for published reviews.
Consider voluntary corrective statements to affected consumers where appropriate.
Sources
Not legal advice. This article is general information based on publicly available sources, written for educational purposes. Laws change and individual situations vary. Consult a licensed attorney in your jurisdiction before acting on anything you read here. Last reviewed: 2026-06-08.