This is a situation where the typical consumer has asymmetric resources and time pressure (they’re paying quickly at a retail checkout), and hence have limited

This is a situation where the typical consumer has asymmetric resources and time pressure (they’re paying quickly at a retail checkout), and hence have limited opportunity to hunt around CVS’s website to figure out whether CVS is doing the plain-language reasonable thing or has cobbled together some alternative arrangement. Obviously IANAL but I think in these situations firms should clearly disclose to consumers at the time of donation what’s happening. “The plans were clearly displayed in the locked basement of the local planning office” shouldn’t be a viable alternative. More generally: this is a case where government regulation is very helpful. There is a clear public interest in consumers’ ability to trust that retailers are being honest and forthright about “we donate to charity on your behalf” claims. I know many people who refuse to donate to these schemes because they don’t trust the retailer, which seems harmful all around. ETA: I read your first link carefully and I don’t even think it discloses anything. It says there is a $10m commitment and later says customers will be invited to donate. It doesn’t make clear that one will be counted towards the other.