Lowest Price of the Last 30 Days: Getting the Omnibus Directive Right

1. What is the 30 day rule and what does it cover?

When you advertise a discount in your online shop, for example with a crossed out old price, a sale banner, or a percentage such as minus 20 percent, a special disclosure duty applies. You must state, alongside the new reduced price, the lowest price you charged for that product in the 30 days immediately before the price reduction. This obligation comes from Section 11 of the German Preisangabenverordnung, or PAngV, the price labeling regulation, and is commonly known as the 30 day rule or reference price rule. Legally, it is a market conduct rule intended to make the comparison between the old and the new price genuinely understandable for shoppers.

The reasoning behind the rule is simple: before the reform, traders could artificially raise a price shortly before a big advertised sale, then suggest an especially large discount even though the real benefit to the customer was small. Such misleading prices were meant to trick shoppers into buying something that was not actually as good a deal as it looked. The 30 day rule closes this loophole because the actual lowest price of the recent past has to be made visible, so customers can see the real discount at a glance. For you as a shop owner, this mainly means one thing: your price history becomes a fixed part of every discount campaign, not just a footnote for bookkeeping.

In very practical terms: if you currently offer a product for 79 euros and you sold it for 65 euros at some point in the last 30 days, you cannot advertise a discount using 79 euros as the starting price. The reference must be the lower price of 65 euros, even though your current regular price is higher. This example shows why a careful price history matters so much: without one, you cannot reliably prove the correct reference price if it is ever challenged.

2. Since when does the rule apply?

The rule goes back to the European Omnibus Directive, formally Directive (EU) 2019/2161, through which the EU modernized several consumer protection rules. Germany implemented this requirement through a reform of the Preisangabenverordnung. The new Section 11 PAngV with the 30 day rule has been in force since 28 May 2022. Since then, the obligation applies directly and without any further transition period to every discount campaign you advertise to consumers, regardless of whether your shop has existed for years or only just launched. Anyone who opened a shop after that date is bound by the rule from day one, just like an established business, there is no grandfathering or transitional relief for older shops. Even though several years have now passed since the rule took effect, competition associations and competitors continue to check reference price displays regularly, especially around major sale periods such as winter and summer clearance sales.

There was no special transition arrangement, unlike some other legal changes. This means that from the effective date, every discount campaign, even one that had already been planned for a while, had to meet the new requirements. For today, several years after the rule took effect, what matters most is that it has become a firmly established part of case law and warning letter practice, no longer treated as a recent novelty.

3. Who is affected, including small shops?

The 30 day rule generally applies to any trader who sells goods to consumers and advertises a price reduction while doing so, whether online, in a physical store, or through both channels at once. The size of the business does not matter: even a small one person shop running a sale twice a year must follow the rule as soon as a reduced price is shown next to the old price. Purely business to business transactions, meaning B2B sales without any consumer involved, are not covered by this specific rule.

Many small shop owners wrongly assume this requirement is only something large retail chains with their own legal department need to worry about. That assumption is wrong. As soon as you advertise with a reduced price, whether it is a winter sale, a discount week, or a single sale tag on one product, the same obligation applies as it would for a large online retailer. The good news: with the right tools and a bit of preparation, this requirement can be worked into daily operations even for small teams, without needing an in house legal department. Side business shops and small family run stores in particular should not be put off: once a system for tracking price history is set up, it largely runs itself from then on.

The sales channel you use also has no bearing on whether the rule applies. Whether it is your own online shop, an additional marketplace account on Amazon or eBay, a social media shop, or a traditional storefront with a window display advertisement, the duty to state the reference price applies equally as soon as consumers can see the advertised price reduction. For traders selling across several channels, this means the price history should be maintained consistently across all of them, so the same correct reference price appears everywhere.

4. Time limits and scenarios at a glance

The table below shows which reference period applies in which situation and who it affects. It helps you quickly work out whether your planned campaign falls under the standard rule or one of the special cases.

It is important that the special cases in the table remain genuine exceptions and are not used as a general excuse for skipping a price history. If you are unsure whether one of these exceptions applies to your product, it is usually safer to apply the standard rule and state the lowest price of the last 30 days. When in doubt, it also helps to check your shop system's product data to confirm the exact launch date of a product.

5. What you need to do in practice

To reliably follow the rule, you first need a dependable price history for every product you plan to discount. It is not enough to simply remember the last price before the sale, because what matters is the actual lowest price of the past 30 days, even if that was two or three weeks ago. Many shop systems offer extensions that automatically log price changes and calculate the correct reference price for every discount campaign. Without such an extension, the rule can still be followed, but only with a carefully maintained manual record in which every price change is logged with a date.

It is also important to display the reference price clearly, right next to the reduced price, so the comparison is transparent for customers. If you run campaigns regularly, coordinate the process in advance with everyone who manages prices in your shop, so no one raises a price shortly before a sale out of simple unawareness. Especially with several sales channels, such as your own shop plus an additional marketplace account, it is worth naming one single person responsible for keeping track of all ongoing price changes. The checklist below summarizes the most important steps.

Build in some lead time before a new discount campaign goes live: the correct reference price should already be confirmed when marketing, or you yourself, announce the campaign, not added as an afterthought once it is already running. This way you avoid rushed corrections shortly before or during a live campaign.

6. Fines and risks of non-compliance

In practice, violations of the price labeling regulation are pursued mainly through competition law warning letters. Competitors or competition associations can treat incorrect price labeling as a breach of the German Act Against Unfair Competition, known as UWG, because a market conduct rule such as Section 11 PAngV was disregarded. Such a warning letter usually comes with a demand to sign a penalty backed cease and desist declaration and to reimburse the costs of the warning letter. Especially during sale season, when many shops advertise at the same time, some competition associations check price labeling with spot checks and targeted reviews.

Beyond the civil law warning letter, a violation of the price labeling regulation can in principle also be pursued as a regulatory offense, for which the competent authority can impose a fine. How high a fine turns out to be in an individual case depends on the specific circumstances, so it would not be credible to name a fixed figure here. What is certain is that both warning letter costs and a possible fine can represent a noticeable financial burden, one that is easily avoided with correctly implemented price labeling. On top of that comes a less obvious but equally real cost: the time and effort needed to handle a warning letter, review a cease and desist declaration, and get legal advice where necessary, all of which draws attention away from your day to day business.

Also worth considering is the reputational damage that can arise if a flawed discount campaign becomes a topic of public discussion, for example in customer reviews or on comparison sites. Shoppers have become increasingly sensitive to suspected misleading prices, so a single incident can damage trust in your shop lastingly, even if no fine is ultimately imposed.

7. Common misconceptions

A widespread misconception is that you can simply use the price that applied right before the discount campaign and state it as the reference price. That is wrong: what matters is the actual lowest price of the past 30 days, even if it only applied briefly and was raised again afterward. A second misconception is the assumption that the rule only applies to large traders with their own legal department. In fact, it applies to every trader who advertises a discount to consumers, regardless of company size.

A third, riskier misconception is the assumption that a generic sale banner without a specific percentage figure is automatically exempt from the rule. As soon as a concrete reduced price is shown next to an original price, the duty to state the reference price is generally triggered, even if the discount is presented only as a new price rather than as a percentage. Finally, some believe the rule only needs to be considered once and never updated afterward. In reality, the reference price has to be freshly determined for practically every new discount campaign, because the 30 day window shifts with every new campaign. A fifth, less commonly mentioned misconception concerns progressive campaigns: some traders mistakenly recalculate a brand new 30 day period at every new discount step, even though the price before the very first reduction remains the reference throughout the same campaign.

One last, often overlooked point concerns the technical implementation: some shop systems do display a reference price, but calculate it incorrectly, for example by using the price at the start of the calendar month instead of the actual lowest price of the last 30 days. A quick test with a specific sample product will quickly show whether your system genuinely implements the rule correctly or only appears to.

8. What Mironsoft can take care of for you

As an agency for Magento and Hyvä based online shops, we know that the technical implementation of the 30 day rule often gets pushed aside in daily business, simply because it easily gets lost among everything else that needs attention. We take care of setting up an automated price history for you, so the lowest price of the last 30 days is reliably calculated for every product and correctly displayed with every discount campaign, without you having to track it manually. We also pay attention to special cases such as newly launched products or progressive discount campaigns, so the calculation stays correct in every situation.

Beyond that, we review your shop's existing sale and discount displays for compliance with current law, and advise you on how to structure recurring or progressive campaigns so the reference price rule is followed correctly from the very start. This way you can focus on your core business while we keep an eye on the technical and organizational side. On request, we also provide your team with a short, practical briefing, so everyone who manages prices knows the basic rule before the next sale campaign starts. Especially before larger campaigns such as a winter clearance sale, a quick check beforehand is worthwhile, so every advertised reduction is set up correctly before the first customer visits the shop.

Note: this article provides general information about the 30 day rule and does not replace individual legal advice.

9. Summary

Since 28 May 2022, you must state the lowest price of the last 30 days alongside the new price whenever you advertise a price reduction. This rule, which comes from the EU Omnibus Directive and is codified in Section 11 PAngV, applies to every trader who advertises a discount to consumers, regardless of company size. Exceptions only exist in special cases, such as very new products, perishable goods, or carefully documented progressive discount campaigns.

Anyone who ignores the rule risks costly warning letters and, in individual cases, a fine as well. With a properly maintained price history, a clear display of the reference price, and a bit of attention when planning discount campaigns, this risk can be avoided quite comfortably. Most importantly, the reference price should be treated as a fixed part of your regular pricing process rather than an annoying add on requirement, which makes day to day implementation noticeably easier. If you would rather not handle this alone, Mironsoft is happy to support you with the technical implementation and a review of your shop.

10. FAQ: The 30 Day Rule for Discounts