The 30-day lowest price and product variants

Shop owners searching for “Omnibus Directive variants” usually have a practical problem: a product comes in several sizes or colours, the prices are not all the same, and the page has room for one line that says “lowest price in the last 30 days”. Which price goes there?

This guide looks at what the EU texts say, where they are silent, and why keeping a price history per variant is the cautious way to work. The rule itself is explained in the Omnibus Directive and the 30-day lowest price.

What the texts say, and what they leave open

Article 6a of the Price Indication Directive requires that an announced price reduction indicates the prior price, defined 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”.

The Commission’s guidance says the trader “must identify the lowest price that it charged for the respective good or goods”. In the Aldi Süd judgment (C-330/23), the Court of Justice speaks of “the ‘prior price’ of that product”. The directive defines the selling price as the final price “for a unit of the product, or a given quantity of the product”.

None of these texts uses the word “variant”. There is no official sentence that says “work it out per size and per colour”. What can be said is this:

• The prior price is a price that was applied, meaning actually charged.
• It belongs to the good the announcement is about.
• A variant with its own price has its own history of prices applied.

The guidance takes a similar line on sales channels. Where a trader sells at different prices in different shops or channels, it must indicate for each one “the lowest price that it applied in that respective sales channel”. That passage is about channels, not variants, but the logic is the same: the figure follows the price that was applied where the shopper buys.

So a per-variant figure is a careful reading of the rule, not a quotation from it. Check your national law.

Why one figure per product can mislead

A single figure per product goes wrong in two situations.

Variants with different prices

Example 1 (illustrative figures). An olive oil is sold in two sizes: 250 ml at €12 and 500 ml at €20. Neither price has changed for two months. The shop reduces the 500 ml bottle to €16 and shows “−20 %”.

A line under the 500 ml offer reading “lowest price in the last 30 days: €12” tells the shopper nothing about that bottle. It is lower than the offer price itself, and it does not match the “−20 %”.

Same price, different discount histories

Example 2 (illustrative figures). A T-shirt comes in blue and red, both at €50. From 1 to 5 June the blue one was on promotion at €40. On 20 June the shop puts both colours at €42 with “was €50”.

For the red shirt, “was €50” is the prior price and the reduction is 16 %. For the blue shirt, the prior price is €40. In Aldi Süd the Court held that a price presented as reduced “cannot in fact be the same as that ‘prior price’, or be higher than it”, so €42 cannot be presented as a reduction on the blue shirt.

A single product-level figure fails either way. If the page uses the last price (€50) for both colours, the blue shirt shows a reference that is not its prior price. If it uses the lowest price across all colours (€40) for both, the red shirt shows a figure that was never applied to it, and its 16 % reduction no longer matches the line beneath it.

What to show when the shopper switches variant

The price on a product page changes when the shopper picks another size or colour. The prior price line needs to change with it.

• Follow the selection. When the shopper selects a variant, show the prior price of that variant.
• Show nothing where nothing is announced. If the selected variant is not reduced, there is no reduction to give a prior price for.
• Keep the figures together. The crossed-out price, the percentage and the prior price line should all describe the same variant.

Two points are not settled by the texts:

Before any selection. Many pages open with a default variant or a “from” price. The directive and the guidance do not say how to present a prior price for a price range. A cautious approach is to show the line for the variant whose price is displayed.

Category pages and product cards. For general announcements, the guidance says the prior price must be indicated “at the point of sale”, which online means the “price sections in online shop interfaces”. If a product card shows a crossed-out price, that card announces a reduction. Whether the card itself must carry the prior price, and for which variant, is not spelled out. Check your national law and guidance from your consumer authority.

New variants with less than 30 days of history

Article 6a(4) reads:

Where the product has been on the market for less than 30 days, Member States may also provide for a shorter period of time than the period specified in paragraph 2.

Four points from the guidance matter here.

1. It is an option for Member States, not for traders. The guidance describes it as what “enables Member States to allow price reduction announcements” for goods the trader has been selling for less than 30 days.
2. It is not a complete exemption. A Member State that uses the option must set a specific period, or let traders choose the period and state it together with the prior price.
3. “On the market” refers to the trader’s own selling of the goods, not to how long the product has existed elsewhere.
4. Goods that come back are not new. If you resume selling the same goods after a break, for example seasonal clothing or an item that was out of stock, the option does not apply. The guidance says the trader can then use a longer reference period in which the goods were on sale for at least 30 days in total, and indicate the lowest price of that whole period.

Whether a new colour of an existing product counts as a “product on the market for less than 30 days” is not addressed. It is a question for national law.

Example 3 (illustrative figures). A shop adds a green version of a bag on 1 September at €50 and wants to reduce it to €40 on 15 September. It has 14 days of price history for the green bag. Where the Member State has used the option, the national rule says which shorter period applies. Where it has not, check your national law before announcing the reduction. In both cases the only price on record for the green bag is €50, and a line should not claim more history than exists.

Bundles and multipacks

The guidance draws one clear line. “Combined or tied conditional offers”, with the examples “buy one, get two” and “30 % off when buying three”, are “outside the scope of Article 6a” and remain subject to the Unfair Commercial Practices Directive. A quantity discount of that kind is not a price reduction announcement in the sense of the 30-day rule.

Beyond that, the texts say little, and it is better to say so.

• A fixed bundle or multipack sold as its own product. The guidance does not mention it. The selling price is defined as the price for “a unit of the product, or a given quantity of the product”, so a pack with its own price has its own price history. If you cross out the pack’s own earlier price, the cautious reading is to treat that as a reduction on the pack and show the pack’s own prior price.
• “Bundle €45 instead of €60 bought separately”. This compares the bundle with the sum of the single items. The texts do not say whether that is a price reduction or a price comparison. Say on the page what the higher figure is, and read the section on comparisons in crossed-out prices and “was/now” discounts.

Keeping records per variant

Article 6a contains no record-keeping duty. In practice you cannot show a prior price, or explain one to a customer or an authority, without a record. Penalties are set by each Member State.

A workable record holds, for each variant:

Records begin on the day you start recording. For a variant that is already discounted on that day, you have no 30 days of history unless you bring in earlier prices from another source. It is better to show no figure than one you cannot back up.

StoreCompliant works this way: it records prices per variant from the day it is installed and works out the 30-day lowest price for each variant. For a product that was already discounted on that day it shows nothing until earlier prices are imported from a file. It is a compliance aid, not legal advice. Plans are on the pricing page, and the guide for Wix Stores covers one platform in detail.

A short checklist for products with variants

• List the products where variants have different prices or are discounted separately.
• Record every price change per variant, with the time.
• Before each reduction, find the lowest price of the previous 30 days for each variant concerned.
• Work out the percentage from that figure, variant by variant.
• Make the prior price line follow the selected variant.
• For new variants, bundles and price ranges, check your national law, because the EU texts leave these points open.