30-day lowest price: what applies to compare-at prices and discounts

When the rule applies

§ 11(1) PAngV applies to anyone required to state total prices to consumers, “whenever a price reduction for a product is announced”. In an online store this mainly means:

• compare-at prices (“was €12.99”),
• discounts in percent or euros (“−20%”, “€5 off”),
• labels such as “sale” or “reduced” together with an earlier price.

For goods offered with a unit price only (loose goods), the rule applies accordingly (§ 11(3)).

How the lowest price is determined

What counts is the lowest total price that applied in the 30 days before the reduction. An example:

The 30 days before 1 April run from 2 to 31 March. €21.99 also applied in that period – so the statement is: “Lowest price in the last 30 days: €21.99”.

If the price is lowered further during the promotion without interruption – for example to €17.99 and then €14.99 – the lowest price from before 1 April may still be stated (§ 11(2)).

Percentage discounts: based on the lowest price

The Court of Justice of the European Union decided on 26 September 2024 (C-330/23, Aldi Süd): where a reduction is announced as a percentage or with promotional wording highlighting a particularly good price, it must be determined on the basis of the lowest price of the preceding 30 days. A “−20%” may therefore not refer to a higher price that applied shortly before.

Exemptions

Under § 11(4) PAngV, the rule does not apply to

• individual price reductions,
• reductions for perishable goods or goods with a short shelf life, if the price is lowered because they are about to spoil or expire and this is made clear to consumers.

In your Shopify store

In Shopify, the strikethrough price is a variant’s “compare-at price”. Shopify keeps no price history – to state the lowest price, you need to record the prices of the last 30 days yourself.

1. Record prices

   Note every change of price and compare-at price with its date, for every variant.

2. Determine the lowest price

   Before each promotion, look up the lowest price of the 30 days before.

3. Show it next to the compare-at price

   “Lowest price in the last 30 days: …” wherever the reduction is announced.

4. Check percentages

   A percentage discount must match the lowest price, not the higher price before it.

What happens if it is wrong

A missing or incorrect lowest price is an administrative offence under § 20 PAngV. Misleading discounts can also be challenged under the German Act against Unfair Competition.