Are all online traders required to provide a link to an ODR platform under regulation 19A of SI 2015/1392?

The alternative dispute resolution for Consumer disputes (competent authorities) Regulations 2015, SI 2015/542 (the Consumer ADR Regulations) came into force in 2015, inserting regulation 19A from Alternative Dispute Resolution for Consumer Disputes (Amendment) Regulations 2015, SI 2015/1392.

SI 2015/542, reg 19A provides that:

'[(1) Where under an enactment, rules of a trade association, or term of a contract, an online trader is obliged to use an alternative dispute resolution procedure provided by an ADR entity or EU listed body, the trader must—

(a) provide a link to the ODR platform in any offer made to a consumer by email; and

(b) inform consumers of—

(i) the existence of the ODR platform; and

(ii) the possibility of using the ODR platform for resolving disputes.

(2) The information in (1)(b) must also be included in the general terms and conditions of online sales contracts and online service contracts of the trader, where such general terms and conditions exist.

(3) An online trader must on its