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Price indication done right
The total price, inclusive of everything compulsory, must be visible where the offer is made. Most pricing complaints come from breaching that one rule.
Key points
- The price shown must be the total a consumer will pay, including unavoidable charges.
- Reference prices for discounts are now tightly regulated in many markets.
- Unit pricing is compulsory for goods sold by measure.
Price indication rules exist because comparison is impossible if the displayed price is not the price paid. The rules are detailed and enforcement is routine.
The total price rule
The price shown to a consumer must be the final price including taxes and all compulsory charges.
That means: taxes included, any unavoidable fee included, and any charge the consumer cannot avoid included. Charges that genuinely depend on a consumer choice, such as an optional delivery upgrade, may be shown separately and must be shown clearly before the order is placed.
A price that increases at the checkout because of a compulsory fee is not a price. It is the beginning of a negotiation the consumer did not agree to.
Reference prices and discounts
Rules on discount advertising have tightened substantially in Europe. The general requirement now is that a price reduction announced to consumers must state the prior price, defined as the lowest price applied during a defined period before the reduction, commonly 30 days.
That closes the practice of raising a price briefly before a sale to inflate the apparent saving.
| Practice | Position |
|---|---|
| Comparing against the lowest price of the last 30 days | compliant |
| Comparing against a manufacturer's recommended price | permitted with care, must be genuine and current |
| Comparing against a price never actually charged | prohibited |
| Continuous "sale" pricing | challengeable |
| Progressive discounts during a campaign | specific rules apply |
Unit pricing
Goods sold by weight, volume, length or area generally require a unit price alongside the selling price, so that comparison is possible.
The unit price must be as visible and legible as the selling price. It is a frequent finding in inspections.
Where the price must appear
Wherever the offer is made and wherever the product is presented in a way that invites purchase. That includes advertising, the shelf, the website listing page, and the product page.
Placing the total only at the final step of a checkout does not satisfy the requirement.
Business to business
Prices between businesses may generally be shown excluding tax, provided it is clearly marked. Mixed audiences require care: a website serving both consumers and businesses should show consumer-compliant pricing by default.
Additional charges to watch
Booking fees, service charges, payment surcharges where permitted, compulsory insurance, mandatory delivery, disposal levies, and deposit schemes. Each must be either included in the displayed price or disclosed prominently before the decision is made.
The practical audit
Once a year, place an order on your own site as a consumer and record the price at every step. Any increase between the advertised price and the final total is either compliant and clearly disclosed, or it is a problem.
Frequently asked questions
Must delivery costs be included?
They must be stated clearly where the offer is made. Where they are unavoidable and calculable, they generally form part of the total price.
Can you show a price without tax?
To consumers, generally no. Between businesses, generally yes, if clearly marked.
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