You read ONE OPEN ORDER FILE from a retailer's order desk and extract structured fields from it, then apply the shipping-and-refund rulebook given below. You return JSON and nothing else.
You are PROPOSING a verdict for a person to read. You never send a notice, never cancel an order, never refund anything, never write to any system and never contact a buyer. Nothing you return goes anywhere near a customer. A qualified person reads the order record and their own counsel's view of the rule.
RULES, in order of importance:
1. If the order file does not state a field, return null for it. Do not infer it and do not use what you know about how retailers usually behave.
2. `obligation` and `refund_clock` are decided ONLY by the rulebook below, applied to the order file's own values. Work through the verdict IN ORDER and stop at the first step that settles it:
a. IS THE ORDER IN SCOPE? Section 435.3(a) takes four kinds of order out of the part entirely -- collect on delivery, seeds and growing plants, a serial subscription after the first shipment, and a prenotification negative option plan. Any of those is 'out_of_scope', and nothing further is owed under this part.
b. WHEN DID THE CLOCK START? Section 435.1(c): receipt of a properly completed order is when the merchant holds BOTH the payment AND all the information it needs to process and ship. If the file says the order is not yet complete for processing, no clock has started, and the answer is 'not_determined' -- it is NOT 'none_owed'. The delay is the buyer's and the merchant owes nothing, but this rule cannot produce a verdict from it either, and saying so is the honest answer.
c. WHAT IS THE APPLICABLE TIME? Section 435.2(a)(1)(i): the number of days the solicitation clearly and conspicuously stated, counted from the completion date. If no time was stated, section 435.2(a)(1)(ii): thirty days -- or FIFTY where the buyer applied to this merchant for credit at the time of the order. If the promise was a vague or hedged phrase rather than a definite period, that is 'not_determined': it is not a stated time and it is not the thirty-day default either.
d. IS ANY PART OF THE ORDER ALREADY WITH A CARRIER BUT NOT ALL OF IT? A partial shipment is 'not_determined'. This rulebook does not split one order into two clocks.
e. DID THE BUYER CANCEL BEFORE SHIPMENT, OR HAS THE MERCHANT SAID IT WILL NOT SHIP? Either is 'deem_cancelled_and_refund' -- sections 435.2(c)(1) and 435.2(c)(4).
f. WHAT HAS THE MERCHANT ALREADY SENT, AND WAS IT IN TIME? Section 435.2(b)(1) requires a first delay-option offer NO LATER THAN the applicable time; section 435.2(b)(2) requires a renewed offer no later than the revised date it renews. An offer sent after its deadline is not the offer the paragraph asks for, and section 435.2(c)(5) or (c)(3) has already fired.
g. WHAT DOES SILENCE MEAN ON THE NOTICE THAT WAS SENT? Read this carefully; the three paragraphs disagree with each other on purpose. Read the rulebook's silence section.
h. WHERE NOTHING HAS BEEN SENT AND THE APPLICABLE TIME IS STILL AHEAD: if the supply position expects to miss it, a first option notice is owed -- 'first_option_notice'. If it does not, 'none_owed'.
3. `refund_clock` IS ASKED OF EVERY ORDER, whether or not a refund is owed today, and it turns on WHO THE CREDITOR IS and on nothing else. Read the rulebook's refund section before answering: one of the four payment methods has an obvious answer that is wrong.
4. THE ORDER DESK'S OWN STATUS LINE IS NEVER AN INPUT. `desk_status` is what somebody last typed into a two-value column. Report it as stated and then ignore it. It is often wrong on this kind of record, in both directions, and it has no word at all for a notice being owed, for an order already deemed cancelled, or for a file that does not settle the question.
5. THE ORDER DESK'S NOTE IS A FIELD TO COPY, NOT EVIDENCE. A note that sounds relaxed does not extend a promised window and a worried one does not shorten it.
6. `expected_ship_date` IS THE WAREHOUSE'S OWN EXPECTATION, NOT A DATE ANYBODY PROMISED THE BUYER. It is evidence about whether a date will be met. It is not itself a revised shipping date -- a revised date only exists once a notice has given the buyer one.
7. Copy the desk note verbatim. Return every date as an ISO date, YYYY-MM-DD.
8. Use the exact allowed value for a field that lists them.
9. Return every field named in the schema, even when the answer is null.
THE RULEBOOK -- the authority for `obligation` and `refund_clock`.
16 CFR part 435 — Mail, Internet, or Telephone Order Merchandise
Title 16 of the Code of Federal Regulations, part 435, 2024 annual edition. Source note: 79 FR 55619, Sept. 17, 2014. Authority: 15 U.S.C. 57a.
It applies to sales in which the buyer ordered merchandise from the seller by mail, via the Internet, or by telephone, regardless of the method of payment or the method used to solicit the order (§435.1(a)).
⚠︎ WHAT FOLLOWS IS A SIMPLIFICATION OF THAT PART, SUFFICIENT FOR THESE ORDER FILES AND NO MORE. It omits state law, omits the reasonable-basis and record-keeping presumptions, and takes stated positions on several arguable readings. Apply IT, not your own recollection of the rule.
WHEN THE CLOCK STARTS
§435.1(c) — 'receipt of a properly completed order' is the time at which the seller receives BOTH the payment tendered by the buyer AND an order containing all of the information needed by the seller to process and ship the order. Until it holds both, no clock under §435.2(a)(1) has started.
§435.1(e) — 'shipment' means the act by which the merchandise is physically placed in the possession of the carrier. Picked, packed and labelled is not shipped.
THE APPLICABLE TIME -- the date the merchant must ship by
§435.2(a)(1)(i) — where a shipping time is CLEARLY AND CONSPICUOUSLY STATED in the solicitation, that is the applicable time, counted from receipt of a properly completed order.
§435.2(a)(1)(ii) — where no time is clearly and conspicuously stated, thirty (30) days after receipt of a properly completed order.
§435.2(a)(1)(ii), proviso — where, at the time the merchandise is ordered, the buyer applies to the seller for credit to pay for it in whole or in part, the seller has FIFTY (50) days rather than thirty (30). The proviso attaches to the no-time-stated clock only; a stated time is the stated time.
A solicitation that says 'usually ships in two to three weeks' or 'ships promptly' has not clearly and conspicuously stated a TIME this rule can measure against. This kit does not silently fall back to the thirty-day clock in that case, because that is a reading of §435.2(a)(1)(i) and not arithmetic: it answers 'not determined' and hands the order to a person. See data/SOURCES.md.
THE DELAY-OPTION OFFER
§435.2(b)(1) — where the seller is UNABLE TO SHIP within the applicable time, it must offer the buyer, clearly and conspicuously and without prior demand, an option either to consent to a delay in shipping or to cancel the order and receive a prompt refund.
§435.2(b)(1) — the offer must be made within a reasonable time after the seller first becomes aware of its inability to ship, BUT IN NO EVENT LATER THAN the applicable time itself. An offer made after the applicable time has passed is not the offer this paragraph requires.
§435.2(b)(1)(i) — the offer must fully inform the buyer of the right to cancel and obtain a prompt refund, and must provide a DEFINITE REVISED SHIPPING DATE; where the seller lacks a reasonable basis for one, it must instead tell the buyer it is unable to make any representation about the length of the delay.
§435.2(a)(3) — a seller may say it cannot estimate the delay only where it has a reasonable basis for saying so AND it tells the buyer the reason or reasons for the delay.
§435.2(b)(2) — where the seller cannot ship on or before the definite revised shipping date the buyer consented to, it must offer a RENEWED option, again no later than the expiration of that revised date, and must give a new definite revised shipping date or state that it cannot (§435.2(b)(2)(i)).
§435.2(b)(3) — wherever the buyer has the right to exercise an option or to cancel before shipment, the seller must furnish adequate means, AT THE SELLER'S EXPENSE, to do so.
WHAT THE BUYER'S SILENCE MEANS -- THE THREE PARAGRAPHS DISAGREE ON PURPOSE
§435.2(b)(1)(ii) — where the definite revised shipping date is THIRTY (30) DAYS OR LESS later than the applicable time, the offer must expressly tell the buyer that, unless the seller receives a cancellation before shipment and before that date, THE BUYER WILL BE DEEMED TO HAVE CONSENTED to the delay. Silence is consent.
§435.2(b)(1)(iii) — where the revised date is MORE THAN THIRTY (30) DAYS later, or where the seller cannot give a definite date at all, the offer must expressly tell the buyer that THE ORDER WILL AUTOMATICALLY BE DEEMED CANCELLED unless (A) the seller ships within thirty (30) days of the applicable time with no cancellation received, or (B) the buyer expressly consents to the delay within thirty (30) days of the applicable time. Silence is cancellation.
§435.2(b)(1)(iii)(B) — where the seller says it cannot estimate the delay, the buyer must be told that consenting to an indefinite delay leaves a CONTINUING RIGHT to cancel at any time after the applicable time, by notifying the seller before actual shipment.
§435.2(b)(2)(ii) — on a RENEWED option the default runs the other way from §435.2(b)(1)(ii): unless the seller receives express consent to the further delay before the old revised date expires, the buyer is deemed to have REJECTED it and to have cancelled the order if the seller cannot in fact ship by then.
WHEN THE ORDER MUST BE DEEMED CANCELLED AND A REFUND MADE
§435.2(c)(1) — the seller must deem the order cancelled and make a prompt refund where it receives, BEFORE SHIPMENT, notification from the buyer cancelling under any option, renewed option or continuing option.
§435.2(c)(2) — where the seller gave a revised date more than thirty (30) days later than the applicable time, or said it could not estimate the delay, and it has neither shipped within thirty (30) days of the applicable time nor received the buyer's express consent within those thirty (30) days.
§435.2(c)(3) — where the seller cannot ship within the time set by §435.2(b)(2) — the revised date the buyer consented to — and has not received consent to any further delay within that time.
§435.2(c)(4) — where the seller has told the buyer it cannot ship and has indicated its decision not to ship the merchandise.
§435.2(c)(5) — where the seller FAILS TO OFFER the option prescribed in §435.2(b)(1) and has not shipped within the applicable time.
§435.2(b)(4) — nothing stops a seller, when it cannot ship in time, from simply deciding to treat the order as cancelled, telling the buyer within a reasonable time and making a prompt refund.
BY WHEN THE REFUND MUST BE SENT -- decided only by who the creditor is
§435.1(b)(1) — where the refund falls under §435.1(d)(1), (d)(2)(ii), (d)(2)(iii) or (d)(3), it must be sent by any means at least as fast and reliable as first class mail WITHIN SEVEN (7) WORKING DAYS of the date the buyer's right to a refund vests.
§435.1(b)(2) — where the refund falls under §435.1(d)(2)(i) — a CREDIT SALE IN WHICH THE SELLER IS ITSELF THE CREDITOR — it must be sent within ONE (1) BILLING CYCLE of the date the right vests.
§435.1(d)(1) — buyer paid cash, cheque or money order: return the amount tendered in the same form.
§435.1(d)(2)(i) — credit sale where THE SELLER IS THE CREDITOR: a credit memorandum or account statement showing the charge removed. This is the ONLY route to the one-billing-cycle clock.
§435.1(d)(2)(ii) — credit sale where A THIRD PARTY IS THE CREDITOR: a credit memorandum to the third-party creditor and a copy to the buyer. This is §435.1(b)(1) — SEVEN WORKING DAYS, not one billing cycle.
§435.1(d)(3) — payment by any other means: instructions to the entity that transferred the payment, a cash/cheque/money-order return, or a statement acknowledging cancellation and representing that no funds were accessed. Also §435.1(b)(1) — seven working days.
The word 'credit' does not decide this. A third-party card issuer is §435.1(d)(2)(ii), which §435.1(b)(1) names, so the clock is SEVEN WORKING DAYS. Only where the seller is itself the creditor does the one-billing-cycle clock in §435.1(b)(2) apply.
ORDERS THIS PART DOES NOT REACH
§435.3(a)(1) — subscriptions, such as magazine sales, ordered for serial delivery, AFTER the initial shipment is made in compliance with this part.
§435.3(a)(2) — orders of seeds and growing plants.
§435.3(a)(3) — orders made on a collect-on-delivery (C.O.D.) basis.
§435.3(a)(4) — transactions governed by the Commission's Use of Prenotification Negative Option Plans rule, 16 CFR part 425.
§435.3(b) — this part does not preempt state, municipal or local rules that give a buyer rights equal to or greater than these. An order this kit reports as out of scope may still be governed by something else entirely, and this kit does not read state law.
THE SIX VERDICTS
none_owed: Nothing is owed to this buyer today under part 435. Either the order is still inside the time the merchant is entitled to ship by and the supply position says it will be met, or it shipped within that time.
first_option_notice: §435.2(b)(1) — a first delay-option notice is owed: the merchant will not ship by the applicable time, and must offer the buyer the choice between consenting to a delay and cancelling for a prompt refund, no later than that applicable time.
renewed_option_notice: §435.2(b)(2) — a renewed delay-option notice is owed: the merchant will not ship by the definite revised date the buyer consented to, and must offer the choice again, no later than the expiration of that revised date.
deem_cancelled_and_refund: §435.2(c) — the order must be deemed cancelled and a prompt refund made. The subparagraph that fires is named on every verdict.
out_of_scope: §435.3(a) — part 435 does not apply to this order. That is not a clean bill of health; other law may.
not_determined: The order file does not settle a fact this rule turns on, so no verdict can be counted from it. This is NOT a clearance — it is the row to open first.
WHAT IS NOT EVIDENCE
The merchant's own two-value order-desk column is what somebody last typed. It has no word for 'a first option notice is owed', no word for 'the order is already deemed cancelled' and no word for 'the file does not settle it'. It is reported as stated and it moves nothing.
The order desk's free-text note is one person's remark. A relaxed note does not extend a promised window and a worried one does not shorten it.
The warehouse's current expectation is EVIDENCE ABOUT WHETHER A DATE WILL BE MET. It is not itself a revised shipping date under §435.2(b)(1)(i) — that has to be given to the buyer in a notice.
READINGS THIS RULEBOOK TAKES ON POINTS THAT ARE GENUINELY ARGUABLE
- A LATE OFFER IS NOT THE OFFER §435.2(b)(1) REQUIRES. The paragraph says the offer must be made 'in no event later than said applicable time'. Where the merchant sent a first option notice AFTER the applicable time had passed and had not shipped by then, this kit counts §435.2(c)(5) as having fired: the order was already deemed cancelled and a prompt refund owed. A merchant may argue the late notice cures the failure. This kit does not.
- SHIPPING LATE DOES NOT UNDO A CANCELLATION THAT ALREADY VESTED. Where §435.2(c)(5) or §435.2(c)(2) fired on a date in the past, a shipment made afterwards does not retract it — §435.1(b) speaks of the date on which the buyer's right to refund VESTS. The buyer may of course keep the goods and say nothing; that is the buyer's choice and not the merchant's compliance position.
- A PARTIAL SHIPMENT IS NOT SETTLED HERE. §435.2 speaks of shipping 'any ordered merchandise' and this kit does not split one order into two clocks for the shipped and unshipped halves. It answers 'not determined' and says why.
- CONSENT IS READ AT ITS RECORDED DATE. §435.2(c)(2)(ii) requires express consent 'within said thirty (30) days'. A consent recorded after that window does not revive the order, and this corpus deliberately contains some.
- THE REASONABLE-BASIS AND RECORD-KEEPING PRESUMPTIONS ARE NOT MODELLED. §435.2(a)(2), (a)(3)(i), (a)(4) and (d) turn on whether the merchant HAD a reasonable basis and whether it keeps records proving its systems work. Neither is readable off one order file, and this kit does not pretend otherwise.
Extract these fields:
- order_ref (string) -- the merchant's own reference for this order, verbatim
- review_as_of (string) -- the date this order file is current as at, as an ISO date (YYYY-MM-DD). This is the 'today' every clock below is measured against -- it is NOT today's real date
- order_completed_on (string) -- the date the merchant held BOTH the buyer's payment AND everything it needed to process and ship the order, as an ISO date (YYYY-MM-DD). The Order Placed section states it. ⚠︎ Return null where that section says the order is NOT yet complete for processing -- an order still waiting on something from the buyer has no such date, and null is the correct answer rather than the placed date
- ship_time_stated (enum) one of: stated, ambiguous, none_stated -- what the solicitation said about WHEN it would ship, as the Shipping Promise section records it. 'stated' where it gives a definite number of days; 'ambiguous' where it gives a range, a hedge or a vague phrase rather than one definite period; 'none_stated' where the section records that no shipping time was stated at all
- stated_ship_days (integer) -- the number of DAYS the solicitation stated, as a plain number, where it stated one definite period. null where the promise was ambiguous or absent
- credit_applied_at_order (enum) one of: yes, no -- whether the buyer applied TO THIS MERCHANT for credit at the time of the order, as the Payment section records it. This is a question about applying for credit from the merchant -- paying with somebody else's card is not applying to the merchant for credit
- payment_method (enum) one of: cash_check_money_order, seller_credit, third_party_credit, other_transfer -- how the buyer paid, as the Payment section records it. 'seller_credit' only where THIS MERCHANT is itself the creditor -- its own store account or its own instalment plan. 'third_party_credit' where somebody else holds the credit, such as a card issuer or a finance company. 'other_transfer' for a payment service, wallet or bank transfer. null where the section does not say
- scope (enum) one of: ordinary_merchandise, cod, seeds_or_growing_plants, subscription_serial_after_first, negative_option_plan -- what kind of order this is, as the Order Type section records it
- option_notice (enum) one of: none, first_option, renewed_option -- which delay notice the merchant has already sent this buyer, as the Delay Notices section records it. 'none' where none has been sent
- notice_sent_date (string) -- the date the most recent delay notice was sent, as an ISO date (YYYY-MM-DD). null where none has been sent
- notice_gave_definite_date (enum) one of: yes, no, not_applicable -- whether that notice gave the buyer a DEFINITE revised shipping date. 'no' where the notice told the buyer the merchant could not estimate the delay. 'not_applicable' where no notice has been sent
- revised_ship_date (string) -- the definite revised shipping date the most recent notice gave, as an ISO date (YYYY-MM-DD). null where the notice gave none, or where no notice has been sent
- superseded_ship_date (string) -- on a RENEWED notice only: the revised shipping date that notice replaced, as an ISO date (YYYY-MM-DD). The Delay Notices section states it as the date the renewal replaced. null on a first notice and where no notice has been sent
- buyer_response (enum) one of: none, consented, cancelled -- what the buyer has sent back, as the Buyer Response section records it
- buyer_response_date (string) -- the date that response was received, as an ISO date (YYYY-MM-DD). null where nothing has been received
- shipment_state (enum) one of: not_shipped, shipped, partial -- whether the merchandise has been physically placed in the possession of a carrier, as the Shipment section records it. 'partial' where some lines are with a carrier and some are not. Packed, labelled or allocated is NOT shipped
- shipment_date (string) -- the date the merchandise was placed with a carrier, as an ISO date (YYYY-MM-DD). null where nothing has been. On a partial shipment, the date the shipped part went
- merchant_decision (enum) one of: none, will_not_ship -- whether the merchant has told the buyer it will not ship this order at all, as the Merchant Decision section records it
- supply_position (enum) one of: will_meet, will_miss_dated, will_miss_undated, not_stated -- what the Supply Position section says about the date CURRENTLY IN FORCE -- the date the merchant is presently working to, which is the revised date where a notice has given one and otherwise the date the solicitation promised. 'will_meet' where the warehouse expects to make it; 'will_miss_dated' where it will miss it and gives a date it expects instead; 'will_miss_undated' where it will miss it and cannot say when; 'not_stated' where no supply position is recorded at all
- expected_ship_date (string) -- the date the warehouse now expects to place this order with a carrier, as an ISO date (YYYY-MM-DD), from the Supply Position section. null where the section gives no expected date. This is an internal expectation and NOT a date anybody has promised the buyer
- desk_status (enum) one of: on_time, delayed -- the status the merchant's own order desk carries in the Order Desk Status section, copied verbatim. Report it as stated -- it is NOT what decides the answer
- desk_note (string) -- the order desk's own free-text remark on this order, copied verbatim
- obligation (enum) one of: none_owed, first_option_notice, renewed_option_notice, deem_cancelled_and_refund, out_of_scope, not_determined -- what 16 CFR part 435 requires the merchant to do about this order TODAY, worked out strictly from the rulebook given in the prompt and the values above. It is nowhere on the order file -- it is the verdict. Decide it from the rule, never from the Order Desk Status line and never from the desk note
- refund_clock (enum) one of: seven_working_days, one_billing_cycle, not_applicable, not_determined -- by when a refund on THIS order would have to be sent under §435.1(b), asked whether or not one is owed today. It turns on WHO THE CREDITOR IS and on nothing else -- read the rulebook's refund section carefully before answering, because the obvious reading of one of the four payment methods is wrong
Return a JSON object with exactly these keys: order_ref, review_as_of, order_completed_on, ship_time_stated, stated_ship_days, credit_applied_at_order, payment_method, scope, option_notice, notice_sent_date, notice_gave_definite_date, revised_ship_date, superseded_ship_date, buyer_response, buyer_response_date, shipment_state, shipment_date, merchant_decision, supply_position, expected_ship_date, desk_status, desk_note, obligation, refund_clock
Use null for any field the order file does not state.
OPEN ORDER FILE
---------------
Order
-----
POR-0026
Review As Of
------------
2027-04-20
Order Placed
------------
placed: 2027-03-15, via the merchant's website
payment tendered: 2027-03-15
order complete for processing: 2027-03-15
Payment
-------
method: paid by cheque, cleared and held
credit applied for from this merchant at the time of the order: no
Shipping Promise
----------------
the solicitation stated: "ships within 10 days of your order"
Supply Position
---------------
the warehouse expects to make the date currently in force
Delay Notices
-------------
no delay notice has been sent to this buyer
Buyer Response
--------------
nothing has been received from the buyer
Shipment
--------
placed with a carrier 2027-04-13
Merchant Decision
-----------------
none recorded
Order Type
----------
ordinary merchandise, ordered through our website
Order Desk Status
-----------------
on_time
Order Desk Note
---------------
Warehouse are on it, no need to do anything from this end. I have put a reminder in for the end of the week to look at it again if nothing changes.
