Warranty and returns in Nigeria: what you owe the customer

Warranty and returns in Nigeria under the FCCPA 2018: the three month rule, who pays, what a no refund sign cannot do, and whether the factory can be made to pay.

The sign says:

NO REFUND AFTER PAYMENT.

You see it in shops all over Nigeria.

But that sign does not remove a customer's legal rights when the goods are:

defective

unsafe

not what was advertised

or:

not fit for the purpose you sold them for.

For an importer, this matters because the Nigerian customer bought the product from you.

If the Chinese factory produced a bad batch, you may have a claim against the factory later.

But the Nigerian customer's first complaint is still coming to your shop, warehouse, website or WhatsApp.

What does Nigerian law require? #

Nigeria's main consumer-protection law is the Federal Competition and Consumer Protection Act 2018 — FCCPA.

Section 131 says consumers have the right to goods that are:

• reasonably suitable for their normal purpose
• of good quality
• in good working order
• free from defects
• reasonably durable
• compliant with applicable regulatory standards.

If the customer specifically tells you:

“I need this inverter to run a 1.5HP air conditioner.”

and you sell it while presenting yourself as knowledgeable about the product, the law also expects the goods to be reasonably suitable for that stated purpose.

That is why product descriptions matter.

Do not promise what the product cannot do just to close the sale.

There is an implied warranty even if you never printed one #

This is one of the most important points for Nigerian sellers.

Section 132 creates an implied warranty of quality.

You do not escape it by saying:

“No warranty.”

or:

“China product, use at your own risk.”

For goods that fail the Section 131 quality requirements, the consumer may return them within three months after delivery, without penalty and at the supplier's risk and expense.

The Act then requires the supplier to repair, replace or refund the defective goods.

That three-month rule is about defective or non-compliant goods.

It is not a general three-month change-of-mind return policy.

When can a customer demand a refund? #

There are several different situations.

The product is defective #

Example:

You sell a blender.

The motor fails during normal use shortly after purchase.

That is a quality/warranty issue.

The product does not match the description #

You advertise:

256GB phone

and deliver:

128GB phone.

The customer did not get what you sold.

The product does not match the sample #

You show a buyer a thick, high-quality fabric sample.

The delivered rolls are visibly thinner and poorer.

Section 121 requires goods bought from a description or sample to materially correspond with what the customer was shown.

The customer told you the intended purpose #

The buyer says:

“I need this machine for 500kg production per day.”

You recommend a model knowing the requirement.

It turns out the machine cannot handle it.

That can become a fitness-for-purpose issue.

What about a customer who simply changes their mind? #

That is different.

A customer buying a perfectly good item and returning the next morning because:

“I don't like the colour again.”

does not automatically have the same protection as someone returning defective goods.

Your store's change-of-mind policy can therefore matter.

You can decide, subject to applicable law and how the sale was made, whether you offer:

exchange only

store credit

or:

voluntary refund

for ordinary change-of-mind cases.

But you cannot use that policy to cancel statutory rights over defective, misdescribed or unsuitable products.

So can you have a “No Refund” policy? #

You can have a returns policy.

What you should not have is a policy that effectively says:

“Whatever happens after payment is your problem.”

FCCPC's own consumer guidance says contract terms attempting to exclude liability for defective performance or waive implied obligations can be prohibited and void.

The Commission has also publicly welcomed court decisions striking down blanket no-refund practices where businesses failed to deliver what consumers paid for.

A better sign is:

Returns and warranty subject to our policy and your statutory consumer rights under Nigerian law.

Then explain the policy properly.

Write a return policy customers can understand #

Keep it simple.

Your policy should answer:

How long do I have to report a problem?

What proof of purchase do I need?

What happens if the product is defective?

Who pays return delivery?

What happens if I simply changed my mind?

Are hygiene-sensitive or personalised products treated differently where legally permitted?

How long does inspection take?

Do not hide the important part inside twelve paragraphs of tiny text.

FCCPC guidance expects business terms to be clear and understandable.

Online sellers have the same problem #

Selling through:

Instagram

WhatsApp

Jumia

or your own website

does not make the product less your responsibility.

In fact, online descriptions can make disputes easier to prove.

If your Instagram post says:

“Original leather.”

and the product is synthetic, the customer has a screenshot.

If you say:

“Battery lasts 12 hours.”

and your supplier's own specification says six, the advertisement is now part of the problem.

Do not allow your social-media person to promise specifications the factory never gave you.

The August 2026 labelling directive matters to importers #

On 19 August 2026, FCCPC directed manufacturers, importers, distributors and retailers to review their inventory and withdraw consumer goods with non-compliant labelling.

The Commission specifically mentioned missing or misleading information such as:

• production date
• expiry or best-before date
• batch number
• manufacturer details
• ingredients
• allergens
• country of origin
• illegible or altered labels
• misleading product claims.

This is not something to fix after the container reaches Lagos.

Specify the label while the product is still at the Chinese factory.

Put the right information on the packaging in China #

Before approving mass production, check:

Product name

Manufacturer

Country of origin

Model

Batch/lot number where applicable

Production and expiry dates where applicable

Ingredients where applicable

Warnings

Instructions

Importer/distributor information where required

NAFDAC/SON information where applicable

Printing the right carton in China is cheap.

Opening 5,000 boxes in Lagos to add stickers is not.

Keep batch numbers #

This is one habit worth building from the first shipment.

Suppose customers begin complaining that a charger is overheating.

You need to know:

Which shipment?

Which supplier?

Which production batch?

How many units are affected?

If you imported 30,000 pieces over six months and kept no batch records, every unit becomes suspicious.

Good records let you isolate the problem.

SONCAP protects you before the goods leave China #

For SON-regulated imports, the conformity process should happen before shipment.

SON describes SONCAP as a pre-shipment verification programme for regulated imported products.

The current process includes:

Product Certificate

Certificate of Conformity

and:

SONCAP Certificate.

The Product Certificate supports Form M processing, while the SONCAP Certificate is required for clearance of SONCAP-regulated goods.

This is different from MANCAP.

SONCAP and MANCAP are not the same thing #

Remember:

SONCAP → imported regulated products

MANCAP → locally manufactured products

Do not allow somebody to sell you a MANCAP story for a container being manufactured in China.

Use which certificate does my product need? before ordering.

What does SONCAP cost? #

SON's currently published standard certification fees include:

PC1: US$500

PC2: US$1,000

PC3: US$2,000

SONCAP Certificate: US$350.

SON's current guidance also says a consignment that leaves the exporting country without the required SONCAP process can face a default charge of:

20% of CIF

or:

₦2 million

whichever is higher.

That should be enough reason to handle compliance before loading.

Certification does not remove your after-sales responsibility #

SONCAP means the product has gone through the applicable conformity route.

It does not mean:

“Nothing can ever go wrong.”

Factories have bad batches.

Products are damaged in transit.

Warehouses flood.

Batteries degrade.

Components fail.

That is why you still need:

inspection + batch tracking + returns process + supplier agreement.

NAFDAC goods need even more control #

If you import products regulated by NAFDAC, such as certain:

• foods
• cosmetics
• drugs
• supplements
• medical devices

the registration and labelling rules become product-specific.

NAFDAC maintains separate guidelines for imported food, cosmetics, drugs, medical devices, supplements and other regulated categories.

Do not assume a process you used for cosmetics applies unchanged to food.

Check the category before manufacturing the label.

For some registration categories, NAFDAC's published process allows up to 120 working days from acceptance of a complete submission, with the clock stopping when compliance queries are outstanding.

That is why NAFDAC registration is something you plan before a commercial shipment.

Not after it arrives.

What happens when regulators find bad stock already in Nigeria? #

The risk is bigger than one unhappy customer.

FCCPC can investigate consumer complaints.

SON can enforce standards against substandard regulated products.

NAFDAC can act against unregistered, counterfeit, expired or otherwise non-compliant regulated goods.

FCCPC now also gives consumers an online complaint portal where they can submit complaints and attach invoices, agreements and correspondence.

So your WhatsApp conversation with the customer may eventually become part of a formal complaint.

Handle genuine complaints properly before they grow.

Can you make the Chinese supplier pay for a bad batch? #

Possibly.

But only if you built that protection before the problem happened.

The Nigerian customer bought from you.

You then need a separate route to recover your loss from China.

That starts with your supplier contract.

Do not rely only on the proforma invoice #

For a serious customised or high-value order, your purchase agreement should state:

• product specification
• approved sample
• quality standard
• inspection requirements
• defect tolerance
• warranty
• replacement obligations
• cost of recalls/returns where negotiated
• responsibility for non-conforming goods
• dispute-resolution mechanism
• governing law
• payment terms

If all your agreement says is:

“5,000 pcs — US$20,000”

you have left the difficult parts for the argument later.

Inspect before paying the balance #

The cheapest warranty claim is the one you never have to make.

If inspection discovers:

500 faulty units

while the goods are still sitting in the Chinese factory and you still owe 70%, you have leverage.

If customers discover those 500 units after the container reaches Nigeria and the supplier has already received 100%, you have a complaint.

Those are very different positions.

Use quality inspection in China before releasing the balance.

Nigeria is not currently a CISG contracting state #

Be careful with international-contract templates saying:

“This transaction is governed automatically by the CISG because China is a member.”

China is a CISG contracting state.

Nigeria is not listed as one.

So do not assume the CISG automatically governs every Nigeria–China purchase simply because the factory is Chinese.

Have the governing law and dispute mechanism written deliberately into important contracts.

Arbitration can give you a clearer cross-border route #

Both Nigeria and China are parties to the 1958 New York Convention on recognition and enforcement of foreign arbitral awards.

China acceded in 1987.

Nigeria acceded in 1970.

That makes arbitration worth considering in larger cross-border purchase contracts because arbitral awards have an established international enforcement framework.

Possible institutions include:

CIETAC

ICC

or another institution agreed with legal advice.

This does not mean arbitration is cheap.

It means the dispute mechanism is agreed before anybody is angry.

For a small order, the best protection is still:

supplier verification + sample + inspection + controlled payment.

Your China warranty should match your Nigerian warranty risk #

Suppose you offer Nigerian customers:

12-month replacement warranty.

But your Chinese supplier gives you:

30 days after shipment.

You have created an eleven-month gap where every failure is entirely your cost.

That may still be a business decision.

But know the number.

Negotiate supplier warranty terms that make sense for what you promise locally.

Price returns into the product #

Returns are a cost.

If you sell 1,000 units and historically:

30 come back

then your business has a 3% returns problem.

Do not treat every return as an unexpected insult.

Cost it.

Your price should be able to carry:

• defective units
• replacements
• return delivery
• technician checks
• packaging damage
• warranty administration

Our how to sell imported goods in Nigeria puts returns beside the other selling costs.

A simple returns process #

Do not improvise every time a customer complains.

Use one process.

1. Ask for proof of purchase #

Invoice, order number or payment record.

2. Identify the product #

Model, serial number or batch where available.

3. Ask what happened #

Do not start by accusing the customer.

4. Inspect #

Confirm whether the issue is:

product defect

wrong item

shipping damage

misuse

or:

change of mind.

5. Apply the correct remedy #

Repair, replacement, refund or your lawful voluntary policy depending on the circumstances.

6. Record the failure #

If three customers report the same problem from the same batch, investigate the batch.

Do not wait for customer number 100.

The importer checklist #

Before you start selling:

PRODUCT

✓ Specification documented?

✓ Nigerian compliance checked?

✓ Labels correct?

CHINA

✓ Supplier verified?

✓ Approved sample retained?

✓ Inspection completed?

✓ Warranty agreed?

NIGERIA

✓ Return policy written?

✓ Staff understand it?

✓ Batch records kept?

✓ Complaint process exists?

MONEY

✓ Expected return rate inside your pricing?

✓ Return-delivery cost accounted for?

If the answer is no, fix it before you scale.

The short answer #

A Nigerian seller can have a returns policy.

But:

“NO REFUND UNDER ANY CONDITION”

is not a magic shield against consumer law.

Defective goods carry statutory consumer protections.

Goods should match their description and sample.

Regulated products must meet the relevant standards.

And the importer cannot simply point at China when something goes wrong.

Your protection starts before shipment:

correct specification → correct certificate → correct label → inspection → batch record → written supplier warranty → clear Nigerian returns policy.

Handle that properly and returns become a business cost you can control.

Ignore it and one bad batch can become:

refunds + regulator attention + damaged reputation + stock you cannot sell.

Start with which certificate does my product need?.

Then use quality inspection in China before the goods leave the factory.

And price your expected returns into how to sell imported goods in Nigeria.

First published 23 Sep 2026. Last checked 23 Sep 2026 by The ChinaBridge desk. Something here out of date? Tell us in the comments and we will fix it.