TOTO Prime Service — Dealer Compliance Script Card
A5 · Double-sided · Print, laminate, and issue to each authorised dealer before they are permitted to sell Prime Service.
Front · Approved Scripts
A5 · FRONT
Prime Service
Dealer Script Card
✓ Approved Scripts
Use these phrases — or close equivalents — when presenting Prime Service to customers.·Present clearly, without pressure.
Your role is to inform, not pressure. Customers already have rights under Australian Consumer Law.
Prime Service is an optional paid upgrade — present it as added certainty and convenience.
1
When explaining what Prime Service adds
"Your TOTO comes with a 3-year manufacturer warranty. Prime Service is an optional paid plan that bridges the Year 3 labour gap and extends full coverage — parts and labour — to 6 years. It's completely your choice."
✓ Correctly describes what the plan adds. Frames it as optional. Does not imply ACL rights are insufficient.
2
When a customer asks about their existing rights
"Under Australian Consumer Law you already have rights to a repair, replacement or refund for a major failure — those rights exist regardless of any paid plan. Prime Service sits on top of that with fixed 6-year coverage and priority response."
✓ Proactively discloses ACL rights before mentioning Prime Service. This disclosure is required by law.
3
When closing or handling hesitation
"There's no rush — you can add it at any time while the manufacturer warranty is still active. And if you purchase today, there's a 30-day cooling-off period for a full refund if you change your mind."
✓ No pressure. Discloses cooling-off period. Truthful about the purchase window.
Back · Forbidden Phrases
A5 · BACK
Prime Service
Dealer Script Card
✕ Never Say This
These phrases breach Australian Consumer Law or TOTO dealer rules.·Violations may result in de-authorisation and ACCC referral.
Saying any of the following — even casually — may mislead customers about their legal rights and
expose B&H and your store to ACCC enforcement, consumer complaints, and class action liability.
1
Implying ACL rights are weak or uncertain
"Without Prime Service, after 3 years you're on your own." / "The warranty runs out — you won't be covered."
⚠ Risk: Misleads customers about ACL rights, which continue beyond 3 years. Mirrors Harvey Norman class action conduct (2025 consolidated).
✓ Say instead: "The manufacturer warranty is 3 years. ACL rights continue beyond that — Prime Service makes coverage explicit and adds Year 3 labour."
2
Suggesting purchase is required, expected, or urgent
"Everyone takes Prime Service." / "I'd strongly recommend it — repairs are expensive." / "You need to decide today."
⚠ Risk: Pressure tactics and fear-based selling may constitute misleading conduct (ACL s18) or unconscionable conduct (ACL s20–22).
✓ Say instead: "It's completely optional. Here's what it covers — you can also add it any time while the warranty is active."
3
Calling it insurance or a legal requirement
"Prime Service is like insurance for your toilet." / "You need this to be fully covered." / "Without it, any repair bill is yours."
⚠ Risk: "Insurance" framing triggers ASIC licensing requirements. "Need" implies ACL is inadequate. Unverified cost claims may be misleading.
✓ Say instead: "Prime Service is a service plan — not insurance. It gives you certain, fixed 6-year coverage with labour included from Year 3."
4
Guaranteeing service times or an identical replacement
"We guarantee someone on site within 48 hours." / "If it can't be fixed you get the exact same model, brand new."
⚠ Risk: Response times are target service standards, not guarantees; replacements are an equivalent or superior model and may differ in colour, finish or appearance. Overstating either is misleading conduct (ACL s18/s29).
✓ Say instead: "We aim to make first contact within 48 hours for Advanced and Concierge, 72 hours otherwise — timing can vary with technician availability and location. If a product can't be repaired, it's replaced with an equivalent or better model; colour or finish may differ."