According to the Air Transport Users' Council, Ryanair passengers can avoid paying the checked-in luggage charges by taking more baggage onto the aircraft with them.
The budget airline recently announced it is to increase baggage charges, meaning passengers could pay up to £100 for two checked-in suitcases.
James Fremantle, industry affairs manager for the council, said: "They are quite generous about how much you can take onto the aircraft and they do it to cut costs. By cutting costs, they can give cheaper fares and that is good for consumers."
However, Mr Fremantle said Ryanair could lose some customers if it is not more sympathetic to their needs: "It is all about choice and there are airlines that passengers can go with and get a free baggage allowance."
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