Challenge ANPC fines & measures (consumer protection)

For traders and service providers who received an ANPC contravention report (fine, warning, confiscation, temporary suspension of activity, or corrective measures). We review the report, the appeal deadline (typically 15 days from service under Government Ordinance no. 2/2001), the evidence and the real operational impact of the measures, then we build a court challenge and a compliance plan that fits your business model.

The information is general and does not replace legal advice. The facts, documents and timeline matter.

When you may need this

You received an ANPC fine for incomplete consumer information (price, characteristics, warranties, delivery/returns).
The inspection alleges labelling or presentation issues (in-store or online).
The report accuses you of unfair commercial practices (misleading information or material omissions).
ANPC imposed temporary suspension of activity or a ban on selling certain products or services.
You were given corrective measures with short deadlines (update labels, price displays, terms & conditions, website notices).
The inspection started from a consumer complaint and you need a consistent defence narrative and evidence file.
The case creates reputational pressure and operational disruption (closures, signage, customer messaging).
You want to prevent repeat sanctions through documented procedures and compliance checks.

What we do, in practice

We review the ANPC report and all related documents (annexes, photos, samples, seizure or sealing minutes, measure orders).
We confirm the deadline and the competent court for the complaint under Government Ordinance no. 2/2001.
We analyse the legal basis cited (for example Government Ordinance no. 21/1992 and Law no. 363/2007) and whether it matches the facts described.
We check how the facts were established: competence, mandatory elements, evidence, proportionality and individualisation of the sanction.
We build the evidence package: product labels, technical sheets, store photos, website snapshots, terms & conditions, return/warranty policies, internal procedures and customer communications.
We draft and file the contravention complaint and the related requests, including on complementary sanctions and measures (such as temporary suspension), depending on the case file.
We propose a compliance plan (labelling, pricing, website disclosures, complaint handling) designed to reduce future risk.

Documents and information useful for the first review

Document	Why it matters	Notes
ANPC contravention report + annexes	Sets the allegations, legal basis, sanctions and measures	We verify mandatory elements and service
Inspection photos and samples	Shows what was found (labels, pricing, information)	We preserve full context (place, date, time, complete page)
Product labels, packaging, technical sheets	Key for labelling and consumer information compliance	We check the rules applicable to the specific product category
Terms & conditions, returns and warranty policies	Relevant for unfair practices or missing information claims	Version in force at inspection date is crucial
Pricing evidence (shelf, checkout, online)	Supports pricing transparency and consistency	We check coherence across channels
Correspondence with ANPC / complaint handling file	Can clarify chronology and your position	We align messaging to avoid inconsistencies

Risks and common mistakes

Missing the 15-day deadline for the complaint (see Government Ordinance no. 2/2001).
Challenging without fixing the evidence context (incomplete photos, missing full website snapshots).
Ignoring immediate-effect measures (for example temporary suspension) or the related display obligations where applicable.
Updating the website quickly without preserving proof of the prior version (important for chronology and defence).
Mixing up national rules (for example Government Ordinance no. 21/1992) with product-specific EU rules (for example labelling regulations).
Sending incomplete responses to the authority that later create contradictions.

FAQ

What is the deadline to challenge an ANPC contravention report?

As a rule, 15 days from service, under Government Ordinance no. 2/2001, Article 31.

Can a temporary suspension measure be challenged?

Often yes, but it depends on how it was imposed (within the report or through related acts) and on the cited legal basis. In practice, temporary suspension may also come with a display obligation regulated by ANPC Order no. 760/2019.

If I corrected the issues, does it still make sense to challenge?

It can, especially regarding legality and proportionality; the strategy depends on the evidence at the inspection date and on the alleged conduct.

What does “unfair commercial practice” mean in legal terms?

At EU level the framework is Directive 2005/29/EC, and in Romania it is implemented mainly through Law no. 363/2007.

Where is the complaint filed?

Typically, the competent court is the local court (judecătoria), under the rules in Government Ordinance no. 2/2001.

What should I preserve from my website after an inspection?

Full page snapshots (product page, checkout, terms, returns, warranties), date-stamped if possible, plus any marketing messages shown to consumers at the time.