The 30-day lowest price rule for Black Friday 2026

Black Friday is on 27 November 2026. If you sell goods to consumers in the EU and announce a reduction, the price you show as the “before” price must be your lowest price in the 30 days before the reduction. Here is how that works in practice, with worked examples.

By Adam Hale · updated 2026-10-12

The rule in one paragraph

Since 28 May 2022, Article 6a of the Price Indication Directive requires that “any announcement of a price reduction shall indicate the prior price applied by the trader for a determined period of time prior to the application of the price reduction”, and defines the prior price as “the lowest price applied by the trader during a period of time not shorter than 30 days prior to the application of the price reduction” (Directive 98/6/EC, Article 6a, inserted by Directive (EU) 2019/2161). Member states may set different rules for perishable goods, products on the market for less than 30 days, and progressive reductions. Germany, for example, wrote the same rule into § 11 of its Price Indication Ordinance (PAngV).

Why Black Friday is where shops get it wrong

The Commission's guidance says that announcements such as “sales” price, “special offers” or “Black Friday offers” are covered even when no percentage is shown, and that the lowest price “shall include any previous ‘reduced’ price during that period” (Commission guidance 2021/C 526/02, sections 1.1 and 2.1). November is full of overlapping promotions: Singles' Day on 11 November, early Black Friday weeks, Black Friday itself, Cyber Monday on 30 November and pre-Christmas sales. Each of them can set the prior price for the next one.

The guidance addresses exactly this: for successive campaigns such as “‘Singles day’, ‘Black Friday’, ‘Cyber Monday’ or Christmas sales campaigns in November/December”, where the price goes back up in between, the prior price for each campaign is the lowest price in the 30 days before it, “including the reduced price during the previous promotions” (section 4.3).

Worked examples

1. A Singles' Day discount sets the Black Friday prior price

The lowest price in the 30 days before 27 November is €49.99. The Black Friday offer must show €49.99 as the prior price, and the reduction is 10 %, not 25 %. Showing “€59.99 €44.99 −25 %” would be wrong on both counts.

2. Raising the price before the sale does not help

The prior price is €79.00, the same as the sale price, so there is no reduction to announce at all. This is the pattern the Directive was written to stop: the guidance says the 30-day period exists to prevent “increasing the price for a short period in order to decrease it afterwards” (section 2.1).

3. The Aldi Süd case: the percentage must use the prior price

In October 2022, Aldi Süd advertised bananas at €1.29 with €1.69 struck through and a −23 % badge. The bananas had cost €1.29 in the week of 19–24 September, so the 30-day lowest price was €1.29. On 26 September 2024 the Court of Justice ruled that a reduction announced “in the form of a percentage, or in the form of a promotional statement intended to highlight the advantageous nature of the announced price, must be determined on the basis of the ‘prior price’” (judgment in C-330/23 Aldi Süd, ECLI:EU:C:2024:804). Showing the 30-day low in small print next to a percentage calculated from a higher price is not enough.

4. A progressive sale versus two separate campaigns

Your lowest price before 20 November was €100. You cut it to €80 on 20 November and to €70 on 27 November, without the price going back up in between. Where the country uses the progressive-reduction option, the €70 step can keep €100 as its prior price: the guidance allows this only when “the price is reduced progressively, without interruptions and without increasing the indicated ‘prior’ price” (section 4.3). Germany allows it (PAngV § 11(2)), France, Austria and Italy prescribe it, the Netherlands allows it for up to three calendar months. Poland and Spain have no such option, so the €70 step must show €80.

If the €80 offer ended on 22 November and the price went back to €100 before Black Friday, the two offers are separate campaigns and €80 is the prior price for Black Friday in every country.

5. Different prices in your shop and online

If you sell through several channels at different prices, the prior price is set per channel: “the lowest price that it applied in that respective sales channel/point of sale during at least 30 past days” (guidance, section 2.1). Austria writes this into its law (“in demselben Vertriebskanal”, PrAG § 9a). Add a channel column to both CSV files and the checker keeps them apart.

Time zones and the exact start

The window ends when the reduction starts. If your shop system schedules Black Friday at 00:00 UTC, the sale starts at 01:00 in Berlin, and your price history for 27 November may already show the sale price for the first hour of the day. The checker reads dates without an offset in each sale country's time zone, keeps explicit offsets like Z or +01:00, counts 30 local calendar days across daylight-saving changes, and warns when a sale does not start at local midnight.

Checklist before you publish your Black Friday prices

1. Export the price history for every SKU in the sale, per channel and currency, covering at least 40 days before the start.
2. List the planned sale prices, start dates and the prior prices and percentages you intend to show.
3. Run them through the checker and fix every “Fix needed” row.
4. For “Incomplete data” rows, find the missing history or do not announce a reduction for that SKU.
5. Set your shop's “compare at” or crossed-out price to the prior price, and calculate badges from it.
6. Export the evidence file and keep it with your CSV exports in case a competitor, a consumer association or an authority asks.