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The EU Omnibus price-reduction rule: the 30-day lowest price, explained for online stores

When an online store in the EU announces a price reduction, it must show the lowest price it charged for that product in at least the 30 days before the reduction, and any percentage must be calculated from that price. We checked an AI research report against Article 6a of Directive 98/6/EC, the European Commission's guidance and the 2024 Aldi Süd judgment, and kept only what a merchant needs.

Published 2026-10-11

The short answer

Under Article 6a of Directive 98/6/EC, added by the Omnibus Directive (EU) 2019/2161, any announcement of a price reduction must indicate the prior price: the lowest price the trader applied during a period of at least 30 days before the reduction. The rule has applied across the EU since 28 May 2022.

In September 2024 the Court of Justice of the EU confirmed in case C-330/23, Aldi Süd, that the prior price is not just a figure to display. A percentage reduction, or a promotional claim stressing an advantageous price, must be calculated from that lowest 30-day price.

What counts as a price reduction announcement

The European Commission's guidance on Article 6a, published in the Official Journal on 29 December 2021 as notice 2021/C 526/02, lists the forms an announcement can take: a percentage such as 20% off, a fixed amount off, a new price shown next to a crossed-out former price, and other techniques that tell the consumer the price is lower, including presenting the current price as a starting price with a higher price to come.

Wording that only creates the impression of a reduction is also covered. The guidance names sales prices, special offers and Black Friday offers as subject to Article 6a, so the prior price has to be shown for the goods concerned.

Some promotions are outside Article 6a but still subject to the Unfair Commercial Practices Directive: general claims such as best or lowest prices, comparisons with other traders' prices or the manufacturer's recommended retail price, and tied offers such as buy one, get two, or 30% off when buying three. Ordinary price changes that are not announced as reductions are not covered either.

How to calculate the prior price

1. Look back at least 30 days. The trader must find the lowest price it charged for the product during at least the 30 days before the reduction starts. The guidance is explicit that this lowest price includes any earlier reduced price in that window. Ignoring a promotion that ended a week ago breaks the rule.

2. Base the percentage on that price. The guidance gives an example: if the announcement is 50% off and the lowest price in the previous 30 days was 100, the seller must present 100 as the prior price, even if the last selling price was 160. The Aldi Süd case shows the trap in practice. A brochure showed bananas at 1.29 euro with 1.69 crossed out and a 23% reduction, while the small print said the lowest price in the last 30 days was 1.29. The Court held that the reduction must be calculated from the lowest 30-day price.

3. Keep it for the campaign. The prior price is set at the start of each reduction and can stay the same for the whole campaign, even one longer than 30 days. Article 6a does not require the store to say how long the prior price was applied.

4. Treat each sales channel separately. If a trader sells at different prices in different shops or online channels, the prior price for each channel is the lowest price applied in that channel.

A store may also show other reference prices, such as its regular price outside promotions, provided they are clearly explained and do not distract from the prior price. A store may use a longer look-back than 30 days if the price it shows is the lowest in that longer period.

Where the prior price must appear

For a general announcement such as 20% off everything today, the guidance says the prior price does not have to be on the banner. It must be shown for each product at the point of sale, which online means the price section of the product in the shop interface.

If the store has not raised the price and has not run another promotion in the past 30 days, the current displayed price is already the prior price and nothing needs to change on the product page. If either has happened, the store must adjust the displayed prior price for the affected products.

The Price Indication Directive also requires prices to be unambiguous, easily identifiable and clearly legible. A prior price that the shopper cannot easily find does not meet that standard.

Codes, loyalty programmes, marketplaces and services

Discount codes. A code offered to potentially all visitors, such as 20% off today with a published code, is treated as an announcement and needs the prior price. A reduction for loyalty members only is also covered when the programme is used by many or most customers.

Genuinely personal reductions are outside Article 6a: a voucher received after a purchase for the next order, a reduction for a customer's birthday or for signing up to a loyalty scheme, and loyalty programmes that give a continuous discount over a long period. These remain subject to the Unfair Commercial Practices Directive.

Marketplaces. Article 6a applies to the seller who contracts with the consumer, including sellers on online marketplaces. The marketplace itself is not responsible unless it is the seller. Traders outside the EU that direct sales to EU consumers are covered.

Services and digital content. At EU level the Price Indication Directive applies to goods only. The guidance states that Article 6a does not apply to services, including digital services, or to digital content. National laws can differ.

Where national rules differ: perishables, new products, progressive reductions

Article 6a lets each Member State set its own rules in three situations: goods that deteriorate or expire rapidly, products on the market for less than 30 days, and reductions that are progressively increased during one campaign. A store selling across borders needs the rule of each country it sells into.

The guidance limits these options. Perishable goods means items such as fresh food, not seasonal clothing that only expires commercially. The new-products option allows a shorter period, not a complete exemption. A product returning after being out of stock is not a new arrival. Successive campaigns such as Black Friday followed by Cyber Monday do not count as one progressive reduction: the earlier promotional price becomes the prior price for the next one.

Romania, as one checked example, set its rule in Article 4^1 of Government Decision 947/2000, inserted by Government Decision 686/2022. The prior price is the lowest price in the same sales area in the last 30 days. For products that deteriorate or expire rapidly the period is 10 days. For products on sale for less than 30 days it is the lowest price in that shorter period, and the seller must state that period clearly. In a progressively increased reduction within the same campaign, the prior price is the price before the first reduction.

Method

We started from an AI deep-research report written as a product specification for a price-history app. We removed the product, pricing and app-store material and kept the legal claims a merchant needs. On 11 October 2026 we checked them against the text of Directive (EU) 2019/2161, the Commission's guidance notice in the Official Journal, the Court of Justice press release on case C-330/23 and the consolidated Romanian decision on the official Romanian legislation portal.

We did not verify the report's descriptions of German, French, Polish, Italian, Spanish and Dutch national law, or its accounts of national fines, so this article does not repeat them.

Where the report was wrong

It understated the services exclusion. The report said the Price Indication Directive is centred on goods rather than services. The Commission guidance is firmer: Article 6a does not apply to services or digital content at EU level.

It presented an inference as a ruling. The report attributed to the Court of Justice a ban on placing the prior price in an accordion, a tooltip or a remote footnote. The Aldi Süd ruling is about how the reduction is calculated. The legibility requirement comes from the directive's general rule, and how it applies to a particular design is a matter for national authorities.

It overstated where the prior price must appear. The report said official guidance treats ads, search results and product listings as places where the prior price is required. For general announcements, the Commission guidance requires the prior price at the point of sale, not on the banner itself. Some national authorities may go further; we did not verify those claims.

It described a national rule in a way the guidance says is not allowed. The report described one country's rule as a full exemption for products sold for the first time. The Commission says the new-products option allows a shorter period, not an exemption. Either the national rule goes beyond the option or the report described it loosely. We did not check the national text.

Limitations

This is a reading of EU law and one national rule, not legal advice. The Commission guidance is not binding; only the directive and the Court's judgments are. The guidance reflects case law up to October 2021, and the Aldi Süd judgment came later.

We read the Court's press release, not the full judgment text. We checked one national transposition. Stores selling into several Member States should confirm each country's choices on perishables, new products and progressive reductions.

Sources

1. Directive (EU) 2019/2161 (Omnibus Directive), Article 2 inserting Article 6a into Directive 98/6/EC
2. Commission Notice 2021/C 526/02: Guidance on the interpretation and application of Article 6a of Directive 98/6/EC
3. Court of Justice of the EU, press release 152/24, judgment in case C-330/23 Aldi Süd (26 September 2024)
4. Romanian Government Decision 947/2000, Article 4^1 (consolidated, official legislation portal)

Questions and answers

What is the 30-day lowest price rule in the EU?

The 30-day lowest price rule is Article 6a of Directive 98/6/EC, added by the Omnibus Directive (EU) 2019/2161 and applicable since 28 May 2022. When a trader announces a price reduction, it must show the prior price, which is the lowest price it applied in at least the 30 days before the reduction. The rule aims to stop traders raising a price briefly to advertise a fake discount.

Must the discount percentage be calculated from the 30-day lowest price?

Yes. In case C-330/23, Aldi Süd, decided on 26 September 2024, the Court of Justice of the EU held that a price reduction announced as a percentage, or as a promotional claim stressing an advantageous price, must be calculated from the lowest price applied in at least the 30 days before the reduction. Showing that lowest price only for information, while calculating the discount from a higher price, is not enough.

Do previous sale prices count when calculating the Omnibus prior price?

Previous sale prices count when calculating the Omnibus prior price. The European Commission's guidance says the lowest price in the 30-day window includes any earlier reduced price in that period. For successive campaigns such as Black Friday followed by Cyber Monday, the earlier promotional price becomes the prior price for the next campaign, unless the reduction is one uninterrupted progressive campaign in a country that allows that option.

Does the Omnibus price rule apply to discount codes?

The Omnibus price rule applies to discount codes that are available to potentially all consumers, such as a published code for 20% off today, and to member-only reductions when the programme is used by many or most customers. According to the European Commission's guidance, genuinely personal reductions, such as a voucher for the next purchase or a birthday discount, and long-running loyalty discounts are outside Article 6a.

Does the Omnibus 30-day price rule apply to services and digital products?

At EU level the Omnibus 30-day price rule does not apply to services or digital content. The European Commission's guidance states that the Price Indication Directive, including Article 6a, covers goods only. Misleading price reductions on services and digital content remain subject to the Unfair Commercial Practices Directive, and some national laws may extend the 30-day rule further, so stores should check each country they sell into.

What is the Romanian rule for the lowest price before a reduction?

Romania applies the rule through Article 4^1 of Government Decision 947/2000. The prior price is the lowest price in the same sales area in the last 30 days before the reduction. For products that deteriorate or expire rapidly the period is 10 days. For products on sale for less than 30 days it is the lowest price in that period, which must be stated. In a progressively increased reduction, the prior price is the price before the first reduction.

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