Irish Discount Pricing: The 30-Day Prior Price Rule

That "Was €99, now €49" label on your Irish webshop's product page might be illegal. Since 29 November 2022, traders selling goods to consumers in Ireland must show the lowest price the product was actually sold at in the previous 30 days when advertising a discount. No more inflated "original" prices to make the discount look bigger than it is.

Where this rule comes from

The EU Omnibus Directive (2019/2161) updated several older consumer protection laws, including the Price Indication Directive 98/6/EC. The goal was simple: stop fake discounts. Too many online shops were raising prices a week before a sale, then "discounting" back to the normal price. Customers thought they were getting a deal. They were not.

Ireland transposed the price-reduction rule through S.I. No. 597 of 2022, the European Union (Requirements to Indicate Product Prices) (Amendment) Regulations 2022. It amends S.I. No. 639 of 2002 (the original Price Indication Regulations) and inserts a new Regulation 5A that codifies the 30-day prior price requirement. The Regulations were made on 28 November 2022 and the new obligation took effect on 29 November 2022.

The Competition and Consumer Protection Commission (CCPC) enforces the rule and has published official price-reduction guidance for businesses.

Run a free scan to check your discount labels against the prior-price rule before your next sale.

This applies to any trader selling goods to consumers in Ireland. Online shops, bricks-and-mortar retailers, marketplaces. It does not matter whether you are a sole trader on Adverts.ie or a national chain.

How the rule works in practice

When you announce a price reduction on goods, you must show a prior price. That prior price is the lowest price you charged for the same product in the 30 days before the reduction started. The reduction amount and any "was/now" label must be calculated against that prior price.

Here is what compliant and non-compliant labels look like in practice. The same product (a jacket) across four pricing histories.

The middle two rows are the ones that trip up most webshops. The "raised to €99 then discounted" pattern is exactly what the Omnibus Directive was designed to stop. The "never sold at original price" pattern is a separate offence under the Consumer Protection Act 2007 even when the directive does not apply.

Progressive reductions

Black Friday week is a useful example. Say you start Monday with a 20% discount, Wednesday you go to 30%, and Friday you hit 40% off. Do you need to recalculate the prior price for each new reduction?

No. For progressive, uninterrupted price reductions on the same product during a single sales campaign, the prior price stays the same. It is the lowest price in the 30 days before the first reduction. So if the product was €100 before Monday's discount, that €100 remains your prior price throughout the campaign, even when you drop to 40% off on Friday. The CCPC's guidance is explicit on this.

The key word is "uninterrupted." If you end the sale and start a new one a week later, that is a new price reduction and you recalculate against the new 30-day window, which now includes the discounted prices from the previous sale.

What is excluded

Not every price change falls under the prior-price rule. The CCPC's published guidance identifies the main carve-outs.

Loyalty programmes and personalised discounts. A reduction offered only to scheme members, or a coupon code sent to a specific customer, is not a price-reduction announcement to consumers generally. But if you publish the coupon publicly or post it on social media, it counts as announced and the rule applies.

Conditional offers. "Buy one, get one free" and similar volume-based offers are not price reductions on a single item.

Services and digital content. The Irish rule under S.I. 597/2022 applies to goods. Services and digital content sit under separate consumer protection rules.

Price changes with no promotional announcement. Quietly relabelling a product at a lower price is not a price-reduction announcement. The rule only bites when you communicate a discount to consumers.

End-of-line goods. Where a product was interrupted from sale and then re-offered, the CCPC accepts a prior price drawn from a longer historical period.

Unlike the directive's optional carve-outs for rapidly perishable goods and for goods on the market for less than 30 days, the Irish regulations as enacted do not include an explicit perishables exemption. Treat those carve-outs as not in force in Ireland until the CCPC publishes guidance to the contrary.

How the CCPC enforces this

The CCPC investigates suspected breaches under the Price Indication Regulations and the Consumer Protection Act 2007. Breach of the price-indication rules is a summary offence. On conviction it attracts a Class A fine, capped at €5,000 per offence under the Fines Act 2010, and the court takes the nature, gravity, scale and duration of the breach into account. The CCPC may also issue fixed-payment notices for certain offences and refer serious or repeated breaches for prosecution on indictment under the Consumer Protection Act 2007, which carries materially higher penalties.

In practice the CCPC tends to start with compliance advice and the opportunity to correct. Repeat offenders and blatant cases of artificial price inflation get less patience.

How to implement this in your webshop

The practical challenge is tracking price history. You need to store the price of every product for at least 30 days and automatically pull the lowest price when you create a discount.

Details for each platform below.

Shopify

Shopify does not natively track 30-day price history. Two options.

1. Use an app. Apps like "Omnibus Price" or "Prior Price" add automatic price tracking and display the correct prior price on product pages. Most cost a few euros per month.
2. Manual tracking. Keep a spreadsheet of your product prices. Before applying any discount, check the lowest price from the past 30 days and enter it as the "compare at" price. Workable for small catalogues. Painful at scale.

Whatever you do, do not just put the current price in the "compare at" field and drop the actual price. That is exactly the pattern the Omnibus Directive was designed to prevent.

WooCommerce

WooCommerce stores the regular price and sale price but does not track price changes over time by default. Options.

1. Plugins. Search for "Omnibus Directive" in the WordPress plugin directory. Several free plugins add a price-history log and automatically show the lowest 30-day price on the frontend.
2. Custom implementation. Hook into the woocommerce_product_set_price action to log price changes into a custom database table. Then display the lowest price from the last 30 days wherever you render the sale badge.

For either platform, test your implementation by changing a product's price, waiting a day, then creating a discount. Verify the displayed prior price matches the actual lowest price, not the most recent regular price.

Common mistakes to avoid

Mistake 1: Using a manufacturer's recommended retail price (MRRP) as the prior price. The prior price must be the lowest price you actually charged. Not the MRRP, not a competitor's price, not a fictional "list price."

Mistake 2: Forgetting about marketplace pricing. If you sell the same product on your own webshop and on Amazon.ie or eBay.ie, the 30-day price history applies per sales channel. The prior price on your own site is based on your own site's history.

Mistake 3: Ignoring the rule for percentage-based discounts. "20% off everything" still needs a prior price for each product. The rule applies to any announced price reduction, whether expressed as a fixed amount or a percentage.

Mistake 4: Assuming it only applies to "sale" events. Any communication about a price reduction triggers the rule. Banners, product-page strikethrough prices, email campaigns, social-media posts. If you tell customers the price is lower than before, you need a valid prior price.

How this connects to your broader compliance

Price display is one piece of a bigger picture. Irish webshops also need to display the trading disclosures required of Irish businesses, provide a working order button matching the legal labelling rule, respect the 14-day right of withdrawal and meet the legal notices required on Irish business websites. If you are checking your discount pricing, it is worth reviewing the whole list.

Want to see how your webshop scores on pricing rules and other compliance checks? Run a free scan and get your results in under a minute.

FAQ

Does the 30-day rule apply to services or only physical goods?

S.I. No. 597 of 2022 amends the Price Indication Regulations, which target goods. Services and digital content sit under separate consumer protection rules. That said, the Consumer Protection Act 2007 still forbids misleading commercial practices generally, so deceptive "discount" claims on services can be challenged under that broader prohibition.

What if I give a discount through a coupon code instead of a site-wide sale?

A targeted coupon sent to specific customers is typically not a price-reduction announcement under the rule. But if you publish the coupon publicly, post it on social media or make it available to anyone who visits your site, it is effectively an announced reduction and the 30-day rule applies.

Do I need to show the prior price on listing pages or only on the product detail page?

Anywhere you display the reduced price alongside a discount claim, the prior price should be visible. That includes category pages, search results within your shop, homepage banners and any other surface where the customer sees a "was/now" comparison or a percentage discount. The consumer should never see a claimed discount without the prior price.

Can the CCPC actually check my historical pricing?

Yes. The CCPC has statutory powers to request your pricing records as part of an investigation. Third-party price-tracking tools also archive public pricing data. If a customer or competitor files a complaint, the CCPC can cross-reference your claimed discount against publicly available price history. Keeping accurate internal records protects you when questions come up.