Every price reduction a store in the EU announces to consumers has to be shown together with the lowest price from the 30 days before it. This is not the regular price, the recommended retail price or the price from July, but the lowest price from the last 30 days, and the store has to be able to show where that figure comes from.
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What the rule actually requires
Every announcement of a price reduction has to state the prior price, and the prior price is the lowest price the store applied during at least the 30 days before the reduction. Many stores get this definition wrong, because the intuitive reading is the regular price, while the law means the lowest one.
Take a product that costs 100, is reduced to 80 for a weekend in early November and then goes back to 100. In late November it cannot be advertised as reduced from 100. The reference price is 80, so a Black Friday price of 70 is a discount of 12.5%, not 30%. In 2024 the Court of Justice of the EU confirmed in the Aldi Süd case (C-330/23) that the percentage and the crossed-out price have to refer to that lowest price.
The rule applies to every announcement of a reduction: on the product page, in the category listing, on a banner, in a newsletter and in advertising. The channel does not change the obligation, and neither does the size of the store. The rule comes from an EU directive, so it applies in every member state, in Poland since 1 January 2023. Some details, such as exceptions for new or perishable products, differ between countries, so check the rules in the countries where you sell.
Why the rule matters most in November
The 30-day window before Black Friday covers the promotions a store ran in late October and early November, and that is when many stores test their seasonal prices.
A short discount in that period lowers the reference price for Black Friday, which is the opposite of what the store wanted. Testing prices before the season therefore has a cost: a smaller discount you can announce on the most important day of the year.
There is a second reason. The obligation requires data the store may not have. The price history has to exist before the promotion starts, and a store that begins recording prices in late November has no data for the period the rule refers to.
What this means for how you plan the promotion
Plan the pre-season prices with Black Friday in mind. If a product is going into the Black Friday offer, keeping it at the regular price for the 30 days before the sale protects the reference price.
Record the price history automatically instead of keeping a spreadsheet. To show the lowest price, you need to know every price the product has had, including scheduled sales that started and ended without anybody watching.
Show the lowest price wherever the reduction is announced, not on a separate page. The obligation applies to the announcement itself, so a note that appears only in the cart does not cover a category page advertising 30% off. You can read more about compliance in our article on the new legal requirement for every online store in the EU.
The thirty-day history has to be recorded before the promotion, which is the part a spreadsheet cannot do. WP Desk Omnibus tracks every change to regular and sale prices from the moment it is activated, including scheduled sales, and shows the lowest figure on the product page, in listings and in the cart.
Summary
A store selling to consumers in the EU has to show the prior price with every announced reduction, and the prior price is the lowest price applied during at least the 30 days before the reduction, not the regular price. A product at 100, reduced to 80 for a weekend in early November and then restored, has a reference price of 80, so a Black Friday price of 70 is a 12.5% discount, not 30%. The CJEU confirmed in case C-330/23 that the percentage and the crossed-out price refer to that lowest price. The rule covers the product page, listings, banners, newsletters and advertising, applies in all EU countries (in Poland since 1 January 2023) and has country-specific exceptions. It matters most before Black Friday, because discounts from the previous 30 days lower the reference price. Keep products planned for Black Friday at the regular price for 30 days before the sale, record the price history automatically and show the lowest price wherever the reduction appears.
Frequently asked questions
These three questions come up before every seasonal promotion.
Does the rule apply to a brand new product?
Yes, but with an exception that depends on the country. In Poland, for a product sold for less than 30 days, you show the lowest price from the day you started selling it. In other EU countries the rules may differ.
What about progressive discounts in one campaign?
It depends on the member state. Some countries allow the price from before the first reduction to stay as the reference when the discount grows in stages during one campaign. Check the rules in each country where you sell.
Do variations each need their own lowest price?
Yes, if the variations have different prices, because the reduction is announced for each of them. A single figure for all variations understates the lowest price for some and overstates it for others.
