Can I Show the RRP as the ‘Was’ Price?

No. When you announce a price reduction, you cannot use a manufacturer’s recommended retail price (RRP) as the struck-through “was” price. This is one of the most common misunderstandings about the Omnibus Directive, so it is worth being precise about why.

What the rule actually requires

The Omnibus Directive (EU) 2019/2161, applicable since 28 May 2022, amended Article 6a of the Price Indication Directive (98/6/EC). It says that any announced price reduction must display a prior price, and that prior price must be the lowest price you actually applied during at least the 30 days before the reduction.

The key words are “applied” and “lowest”. The reference price has to be a price the product was genuinely offered at in your shop, and it has to be the lowest such price in the window.

Why an RRP does not qualify

An RRP is a figure suggested by the manufacturer. It is not a price your customers were charged, and it is usually higher than your actual selling price. Because it is neither a price you applied nor the lowest price of the prior 30 days, it cannot serve as the “was” figure in a reduction announcement. Presenting it as the “was” price would overstate the saving and mislead the shopper, which is exactly what the rule exists to prevent.

Can you mention the RRP at all?

You can still show an RRP as a comparison, but you must present it clearly as the recommended retail price and not as your own previous selling price. It must not be the struck-through figure in a “was/now” reduction claim. Keep it visually and textually separate from your announced discount.

• Reduction announcement: use your 30-day lowest price as the “was” figure.
• RRP comparison: label it clearly and keep it out of the discount calculation.

See our complete Omnibus guide or a deeper look at the 30-day rule for more detail.

This article is educational and does not constitute legal advice.