Black Friday sales in the EU: the 30-day lowest price rule
In one sentence: whenever you announce a price reduction to EU consumers, you have to show the lowest price you charged in the 30 days before the reduction started, and any percentage you advertise has to be worked out from that price.
Black Friday is 27 November 2026. For a sale that starts that day, the 30 days go back to 28 October, so the prices your shop charged since then are the ones that count.
Where the rule comes from
Article 6a of the Price Indication Directive (98/6/EC), added by the Omnibus Directive (EU) 2019/2161, has applied since 28 May 2022. Any announcement of a price reduction must show the prior price, meaning the lowest price the trader applied during at least the 30 days before the reduction. The European Commission's guidance (2021/C 526/02) explains how to count, and the EU Court of Justice confirmed in case C-330/23 (September 2024) that a percentage discount has to be based on that prior price.
How the 30 days are counted
- From the start of the sale, not from today. If a sale runs for six weeks, the prior price stays the one from the 30 days before it began.
- Earlier promotions count. If you ran a sale three weeks ago, the price during that sale may be your lowest price, and then it is your prior price.
- Per sales channel. Your online shop has its own prior price, separate from a physical store.
- National options. EU countries may set different rules for goods on the market for less than 30 days, for goods that spoil quickly, and for reductions that grow step by step. Check the rules where you sell.
Mistakes that cause trouble on Black Friday
- Raising the price in early November so the "discount" looks bigger. The higher price is not the lowest price of the last 30 days, so it cannot be your reference.
- Using the recommended retail price or an old compare-at price as the struck-through price without also showing the real prior price, then advertising "40% off" calculated from it.
- Forgetting collection pages and banners. A sale badge on a collection page is also an announcement of a price reduction.
- No record of past prices. If a regulator or a competitor asks, you need to be able to show what you charged and when.
Quick checklist before the sale
- Do not raise prices on sale items in the weeks before the sale.
- Write down, or let software record, the price of each sale item since 28 October.
- Show the prior price next to every announced reduction, in plain words such as "Lowest price in the 30 days before the price reduction".
- Work out any percentage from that prior price.
Doing this on Shopify
Shopify keeps no price history, so the prior price has to come from somewhere else. Our Shopify app TuxPaw: EU Withdrawal & GPSR records every price change from the moment it is installed and shows "Lowest price in the 30 days before the price reduction" on the product page through a theme block, in all 24 EU languages. It only shows the line when it has the full 30 days of history for that product, and it flags in the admin when a struck-through price differs from the prior price. The free plan covers up to 25 products.
Because history only starts when the app is installed, install it at least 30 days before a sale you want it to cover.
Sources: Directive 98/6/EC, consolidated, Commission guidance 2021/C 526/02, Court of Justice, C-330/23.