The 30-Day Lowest Price Rule: How to Show Discounts and Crossed-Out Prices Correctly

Since 28 May 2022, every price reduction announced to consumers in the EU has to be measured against one specific price: the lowest price the seller charged in at least the 30 days before the reduction. The rule comes from Article 6a of the Price Indication Directive, added by the Omnibus Directive (EU) 2019/2161. In Germany it is § 11 of the Price Indication Ordinance (PAngV).

It sounds simple, yet in the EU's check of Black Friday 2025 sales, 30% of 314 online traders still got it wrong. Here is how it works, with an example, and how it affects your Black Friday preparation.

A worked example

A jacket normally costs €99. Three weeks before Black Friday it was on sale for one week at €59. On Black Friday you sell it for €49.

• Wrong: was €99, now €49, '−50%'. The reference price is not the lowest price of the last 30 days.
• Also wrong after the Aldi Süd ruling: was €99, now €49, '−50%', with 'lowest price in the last 30 days: €59' in small print. The percentage must be calculated from €59.
• Right: €49, '−17%', with 'lowest price in the last 30 days: €59' as the reference price.

The Court of Justice of the EU decided this in the Aldi Süd case (C-330/23, 26 September 2024): a reduction announced as a percentage, or as a statement such as 'price highlight', must be determined on the basis of the 30-day lowest price. The German court that referred the case applied the ruling against the retailer in October 2024.

What counts as a price reduction

• Covered: crossed-out former prices, 'was/now', percentage badges, '−€20', 'reduced', 'price highlight' or 'sale price' claims about your own earlier price, in your shop, newsletters, banners and ads.
• Not covered by the 30-day rule: general price comparisons that do not claim a reduction of your own price, such as a clearly labelled RRP comparison (see below), and individual discounts given to one customer.
• Still covered by the rules on misleading practices: everything. Even where the 30-day rule does not apply, a price comparison must not mislead.

The exceptions

Progressive reductions. If you lower a price in steps without interruption (for example −10%, then −20%, then −30% during one sale), the prior price can stay the lowest price before the first step. If you return to the normal price in between, the count starts again.

Perishable goods. Germany exempts goods that spoil quickly or are close to their best-before date, if the price is cut for that reason and the shopper is told so. 'Special offer' alone does not qualify.

Individual reductions. A personal code sent to one customer is not an announced price reduction. Once the code is published for everyone, the rule applies again.

Crossed-out RRPs: allowed, with conditions

A comparison with the manufacturer's recommended retail price (RRP, in German UVP) is not a reduction of your own price, so in the prevailing view the 30-day rule does not apply to it. But German courts set three conditions:

1. It must be labelled as an RRP, for example 'RRP' or 'manufacturer's recommended price'. 'List price', 'regular price' or a bare crossed-out figure are risky.
2. It must be current. An RRP the manufacturer has withdrawn cannot be used without saying so.
3. It must be realistic. An appeal court (OLG Stuttgart) held that an RRP only serves as a fair comparison if the market actually charges it; an RRP that exists only to make discounts look bigger is misleading.

The EU check found that 6 in 10 shops comparing prices did not clearly explain the reference price. Label it.

Common mistakes

• Raising the price shortly before the sale, so the 'reduction' starts from a price that was never the 30-day lowest.
• Percentage badges calculated from the normal price while the 30-day price is shown separately.
• Reductions only fixed on the product page, while newsletters, banners and ads still show the old percentage.
• Marketplace listings left out: the same rule applies to your Amazon, eBay or OTTO offers.
• 'Up to −70%' banners where hardly any product reaches 70% from its 30-day price.

Checking your shop before Black Friday

Export the price history of every product you plan to discount, note the lowest price of the 30 days before the start date, and base every percentage on it. Then check every place the discount appears, not only the product page. Our Black Friday checklist covers countdowns and the checkout as well.