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Expert Answer • 2 min read

What are the requirements for 'comparison pricing' in discounts?

As an e-commerce manager, I'm struggling to understand the legal and ethical requirements for displaying comparison prices during discount campaigns. I want to ensure my pricing strategies are transparent, compliant with regulations, and build customer trust. What are the specific guidelines for showing original prices, calculating discount percentages, and avoiding misleading marketing practices when presenting comparative pricing?
Muhammed Tüfekyapan

Muhammed Tüfekyapan

Founder & CEO

2 min

TL;DR - Quick Answer

Comparison pricing requirements vary by jurisdiction, but generally require that the 'was' price be a genuine price charged for a meaningful period before the discount. In the EU (Omnibus Directive), it must be the lowest price in the preceding 30 days. In the US, FTC guidelines prohibit inflated reference prices.

Complete Expert Analysis

Requirements for Comparison Pricing in Discounts

Comparison pricing - showing a "was" price alongside a discounted "now" price - is one of the most regulated aspects of retail promotion. Getting it wrong can result in regulatory enforcement, customer complaints, and reputational damage.

Jurisdiction Requirements

JurisdictionReference Price RequirementKey Rule
EU (Omnibus Directive)Must show lowest price in preceding 30 daysCannot use the highest price as the "was" reference
UK (CCPR)Reference price must be genuine and recentCMA enforces against fake reference prices
US (FTC Guides)Former price must have been charged in ordinary course of businessMust have been charged for a substantial period
Australia (ACCC)Reference price must be genuine; "was" must have applied for a reasonable periodTypically 28+ days at reference price

What Makes a Valid Reference Price

  • Valid: Price at which the product was genuinely sold to customers in normal trading for 28+ days before discount period
  • Valid: MSRP when it reflects actual market pricing and wasn't artificially inflated
  • Invalid: A price charged for only 1-2 days before switching to "sale" price permanently
  • Invalid: A price that was never actually charged - shown only to create a higher "was" baseline
  • Invalid (EU): The highest price in the last 30 days rather than the lowest

Documentation Required

  • Pricing history showing when the reference price was in effect
  • Sales data confirming the product was sold at the reference price during that period
  • For EU campaigns: documentation of lowest price in preceding 30 days per product
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Muhammed Tüfekyapan

Muhammed Tüfekyapan

Founder & CEO of Growth Suite

With over a decade of experience in e-commerce optimization, Muhammed founded Growth Suite to help Shopify merchants maximize their conversion rates through intelligent behavior tracking and personalized offers. His expertise in growth strategies and conversion optimization has helped thousands of online stores increase their revenue.

E-commerce Expert Shopify Partner Growth Strategist

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