knowledge 25 November 2025 |

Black Friday Sales – How retailers can stay compliant with pricing laws

What is the law?

• A trader announcing a price reduction must indicate in the announcement the prior price of the product. The “prior price” is the lowest price applied to the product during a period of not less than 30 days before the application of the price reduction. The purpose of the 30-day period is to prevent traders from increasing the price of a product for a short period in order to then decrease it shortly afterwards and present it as a significant price reduction that misleads consumers.
  
  EXAMPLE: A shop wishes to announce a price reduction in the selling price of TV on 28 November (i.e. Black Friday). The reduced Black Friday price is €500. The selling price the week leading up to the sale was €800. However, the selling price for the 3 weeks before that was €550. The trader is required to indicate €550 as the prior price as this was the lowest price in the previous 30 days even though the selling price immediately before the sale was €800. 

• Where there are consecutive price reductions, the prior price to be indicated is the lowest price applied during a period not less than 30 days before the initial price reduction. The prior price to be indicated remains the same for all subsequent price reductions.
  
  EXAMPLE: The reduced Black Friday price is €500, and the prior price is €550. €550 is therefore required to be indicated as the prior price in the first price reduction announcement. €550 remains the prior price to be indicated when announcing any further reductions e.g. if the price is further reduced to €450. The initial reduced Black Friday price of €500 is not the prior price in such a scenario.

• The situation is different for separate price reductions during a 30-day period e.g. sales that follow each other such as Black Friday and Cyber Monday, where the general obligations apply. 
  
  EXAMPLE: On Black Friday, the prior price of the TV is €550, and the reduced Black Friday price is €500. The price then returns to €550 on the Saturday and Sunday, following Black Friday. The next day, Cyber Monday, the reduced price is stated to be €500. However, the prior price to be indicated is €500 (i.e. the reduced Black Friday price) so in effect no price reduction may be announced. 

Who does it apply to?

• These obligations apply to traders who sell products to Irish customers including in-store and online.

What are the penalties for non-compliance?

• Failure to comply with these obligations is an offence, which can give rise to criminal prosecution (including a fine of up to €5000). Prosecutions are highly publicised and therefore risk reputational damage. 

• Pricing transparency is an area of enforcement focus for the CCPC.  The CCPC recently successfully prosecuted DID Electrical Appliances, Lifestyle Sports (Ireland), Rath-wood Home and Garden World and Boots Retail (Ireland) Limited for breaches of the obligations outlined above, following online sweeps conducted by the CCPC over the 2023-2024 winter sales season, including Black Friday. Each retailer was fined €1,000 and ordered to pay the CCPC’s costs.  

* The European Union (Requirements to Indicate Product Prices) (Amendment) Regulations 2022 SI No. 597 of 2022