EU Omnibus Directive: showing the lowest prior price on Shopify

Not legal advice. This article is general information about an EU rule as it applies to online stores. Member states implement it in their own laws, with some differences. For decisions about your own store, check the rules in the countries you sell to or speak to a lawyer.

What Article 6a says

The EU's “Omnibus” Directive (EU) 2019/2161 updated several consumer protection laws. One of its changes added Article 6a to the Price Indication Directive (98/6/EC). Member states have applied it since 28 May 2022.

In plain terms, the article says two things:

• Any announcement of a price reduction must show the prior price the trader applied for a set period before the reduction.
• The prior price is the lowest price the trader applied during a period of not less than 30 days before the reduction was applied.

The article also lets member states set different rules for a few situations, such as goods that spoil quickly, products that have been on sale for less than 30 days, and reductions that increase step by step during a sale (where the prior price can be the one before the first step). Whether these options apply depends on the country.

In 2024 the Court of Justice of the EU added an important detail in case C-330/23 (Aldi Süd): a percentage reduction or similar price claim has to be calculated from that 30-day prior price, not from some other reference price.

When it applies

The rule is about announcements of a price reduction made to consumers. On a Shopify store, that typically includes:

• a struck-through “was” price next to a lower price;
• a badge such as “−20%” or “Save €15” on a specific product;
• a product listed in a sale collection with a reduced price shown against an earlier one.

Some cases are less clear-cut: loyalty-scheme prices, multi-buy offers, comparisons with a recommended retail price, or general slogans that don't refer to a specific product. The European Commission has published guidance on interpreting Article 6a that discusses cases like these. If your offer falls into one of them, read the guidance or ask an adviser rather than guessing.

A worked example

Take a product whose price changes several times in the autumn:

The sale starts on November 1. The 30 days before it run from October 2 to October 31. During that window the product was sold at €79 (October 2 to 5) and €89 (from October 6). The lowest of those is €79, so that is the prior price.

Notice what the short September promotion did: it lowered the reference price for a sale that started weeks later. That is the point of the rule. It stops a store from raising a price just before a sale to make the discount look bigger, but it also means that frequent promotions keep pulling the prior price down.

Why this is tricky on Shopify

• Compare-at price is just a field. Shopify shows whatever you type in it. It does not know what you charged over the last 30 days, and it is often set to the regular price rather than the lowest one.
• Badges are often calculated from compare-at. If the badge percentage comes from the compare-at price, it can be wrong in exactly the way the example shows.
• Variants have their own prices. The prior price applies to what the customer is buying, so each variant can have a different 30-day history.
• App discounts are reductions too. An automatic discount that shows a lower price on the product page is also an announced reduction.
• Several markets, several prices. If you sell in more than one currency or set prices per market, each price shown to consumers has its own history.

How Discount Easy displays it

On the Basic and Pro plans, Discount Easy can show a line such as “Lowest price in the last 30 days: €79” next to the discounted price in its storefront widgets. It sits right by the price, where shoppers see the reduction, so the information is in the place the rule is concerned with rather than tucked away on a separate page.

Whatever tool you use, check the result yourself. Pick a few products whose price you changed recently, work out the lowest price from your own records, and compare it with what the storefront shows. Make sure any percentage in your sale badges is consistent with the prior price, not just with the compare-at price.

A practical checklist

1. List the countries where you sell to consumers and check whether any of them use the optional rules mentioned above.
2. Keep a simple record of price changes per product or variant, with dates.
3. Do not raise prices in the 30 days before a planned sale.
4. Show the lowest prior price next to every announced reduction.
5. Base percentages and “save” amounts on that prior price.
6. Review sale badges, photo labels and banners for claims that don't match.
7. Be careful with frequent short promotions, which lower the reference price for later sales.
8. For unusual offers, read the Commission's guidance or ask an adviser.

Summary

• Article 6a requires the prior price to be shown with any announced price reduction to EU consumers.
• The prior price is the lowest price in at least the 30 days before the reduction.
• Percentages and savings should be calculated from that prior price.
• On Shopify, compare-at prices and badge percentages do not handle this on their own.
• Discount Easy can display the lowest 30-day price on Basic and Pro; check it against your own records.

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