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Regulation·5 min read

Omnibus Directive 30-day rule (Article 6a) explained for e-commerce

The Omnibus Directive's Article 6a requires every discounted product to display the lowest price from the 30 days before the sale began. Here is what the rule says, who enforces it, and where it breaks on Shopify and WooCommerce stores.

The Omnibus Directive 30-day rule requires every storefront advertising a price reduction to display the lowest price the trader applied in the 30 days before the discount started. The rule lives in Article 6a of Directive 98/6/EC, the Price Indication Directive, as inserted by Directive 2019/2161. It came into force across the EU on 28 May 2022.

The wording is short and the wording matters.

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.
Article 6a(1), Directive 98/6/EC as amended

Member states set the determined period at 30 days as the default. A handful of states allow exceptions for perishable goods or for products on the market for less than 30 days, but the 30-day reference is the rule a merchant should design for.

What does Article 6a actually require?

If a product is shown as discounted, the lowest price the trader applied in the 30 days before the discount must be shown next to the discounted price. Not the original RRP. Not the manufacturer's suggested price. The lowest actual selling price during that window.

HandhavingGermany, Higher Regional Court of Düsseldorf, 2023 (case I-20 U 152/22): displaying a strikethrough price without the 30-day reference is itself a misleading commercial practice under the UCPD, opening a second enforcement path on top of consumer association lawsuits.

Where the rule commonly breaks on Shopify and WooCommerce

Shopify and WooCommerce stores frequently configure sale price via the compare-at-price field. That field defaults to the original or RRP, not the lowest 30-day price. A bulk-edited sale across a catalogue often imports an arbitrary comparison number, and most theme templates will happily render it.

Stores running flash sales every two or three weeks face a second risk. If a price has been at the discounted level for most of the prior 30 days, the lowest 30-day price is effectively the discounted price, and there is no genuine reduction to advertise.

Who enforces the Omnibus 30-day rule?

Enforcement so far has focused on the visible price label. Bundesverband der Verbraucherzentralen, the German consumer association, has filed multiple actions against major retailers on this exact point. The Czech Trade Inspection Authority has fined Alza and several smaller marketplaces. Italian AGCM and Polish UOKiK both list 6a compliance on their published enforcement priorities for 2025 and 2026.

Zo testen wij ditComplianceGuardHQ does not assume your storefront violates Article 6a. We assume your sale-price configuration probably was not designed around it. A scan checks the rendered discount label, the compare-at value, and 30-day price history where available, and tells you which products fail and why.

What to audit this week

Audit every product currently shown as discounted. For each, confirm the strikethrough price equals or is below the lowest selling price in the 30 days before the sale started. If your theme cannot render that distinction natively, swap to one that does or remove the strikethrough until you can.

Run a free scan of your live storefront and ComplianceGuardHQ will flag any discount labels that do not satisfy 6a, with the exact product URLs and the rendered price strings as evidence. The scan takes about 60 seconds and requires no install.

Veelgestelde vragen

What is the Omnibus Directive 30-day rule?

Article 6a of the Price Indication Directive 98/6/EC, as amended by Omnibus Directive 2019/2161, requires any trader announcing a price reduction to display the lowest price they applied in the 30 days before the reduction started, alongside the discounted price.

When did the Omnibus 30-day rule come into force?

The Omnibus Directive was adopted on 27 November 2019 and member states had to transpose it by 28 November 2021. The rules apply across the EU from 28 May 2022.

Does Article 6a apply to flash sales?

Yes. The rule applies to any announcement of a price reduction. For a flash sale, the displayed prior price must still be the lowest applied in the 30 days before the flash sale started, not the RRP or the price from one year ago.

Are there exemptions to the Omnibus 30-day rule?

Limited ones. Member states may exempt perishable goods with short shelf life. Some states also exempt products that have been on the market for less than 30 days. The exemptions are narrow and member-state specific.

What is the fine for breaching Article 6a?

Penalties depend on the member state. Most jurisdictions allow fines up to 4 percent of annual turnover, with consumer associations also able to seek injunctive relief and legal costs. In practice, fines of 5,000 to 600,000 euros have been issued in early enforcement decisions.

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ComplianceGuardHQ voert een geautomatiseerde technische scan uit. De bevindingen verwijzen naar de tekst van de richtlijnen en naar handhavingsprecedent. Zij vormen geen juridisch advies. Voor een bindende uitleg in uw rechtsgebied raadpleegt u een gekwalificeerd advocaat of functionaris voor gegevensbescherming.