Price marketing and signage: what can you say about the price
Reference price, sale, and rules for offers under the Marketing Act
Prices are something customers react most sensitively to, and consumer law therefore sets clear requirements for how you may disclose and market prices. The rules are enforced by the Consumer Ombudsman, and a company that deliberately or inadvertently misleads about prices risks both a lawsuit and a damaged reputation.
§Price information in store and online
When a customer enters a physical store, they must clearly be able to see what products cost—either via a price tag on the product, a shelf edge, or a hanging sign. The price must be the total price including VAT and other fees, not a net price the customer must add VAT to themselves. The same principles apply online, where the price must be clear before the customer puts the item in the cart.
§Reference price in sale
If a company puts an item on offer or sale, the stated former price must be the lowest price the item was actually sold at in a period before the reduction — as a rule the last 30 days. It is not permitted to artificially raise the price just before a sale and then be able to show a larger, but false, saving.
§How long may an offer last
An offer must be genuinely time-limited to be called an offer. Generally a short period counts as around 10 days while goods that deteriorate or become obsolete quickly — for example fresh food — can have a shorter period of around 5 days. If an 'offer' runs month after month without real interruption it is really just the normal price and so it must not be marketed as an offer.
- 01Don't use the word offer for a price that never changes
- 02Keep track of when the pre-price is really documented
- 03Avoid suggesting a saving that is larger than it really is.
- 04Be extra alert during campaigns that run in several waves
§Double signage and organised discount
Some shops give discounts to specific groups, e.g. members of a club or employees of a partner company. If organized discounts are provided, it must be clearly signposted at all entrances to the store and on the website which groups receive the discount and how much it is, so ordinary customers are not misled about what the price actually is for them.
| Situation | Rule | Consequences of breach |
|---|---|---|
| Price sign in store | Total price incl. VAT must be clearly shown | Case with the Consumer Ombudsman |
| Sale. | Reference price must be the actual lowest price in the last approximately 30 days | Misleading case, requirement to correct marketing |
| Time-limited offer | Short period as a starting point approx. 10 days | The offer must not be marketed as temporary |
| Organization of the working day | Signage at entrances and on website about who gets discount | Misleading ordinary customers |
If you work with price labeling, campaigns or web shop texts, it is a good habit to ask yourself whether an ordinary customer would understand the price and offer correctly without having to read fine print in many lines. If you cannot answer yes immediately, the labeling is probably not good enough yet.