The Omnibus Directive in your store comes down to one rule: if you announce a price reduction, you show the lowest price you charged in the 30 days before the promotion next to the new price. That’s it. Implementation is the harder part. Below I explain who this obligation applies to, how to work out the reference price, which campaigns trigger it and how to set up automation in WooCommerce and PrestaShop, so that nobody has to sit over a spreadsheet recalculating prices by hand.
Table of contents
What the Omnibus Directive means for a store and who it applies to
Article 6a of Directive 98/6/EC, added by Directive (EU) 2019/2161, requires every price reduction announcement to state the prior price of the goods. This has applied across the EU since 28 May 2022. The Commission guidance on Article 6a clarifies that this means the lowest price from a period of at least 30 days. In Poland it is implemented by the Act on Informing about Prices of Goods and Services.
Who is responsible? The seller, meaning the party to the contract with the consumer. That also holds when they sell through a marketplace. The intermediary itself and a price comparison site fall outside the provision. The rule covers goods, meaning movable items, in both brick-and-mortar and online stores. Services and digital content? Excluded. We cover seller obligations in more detail in our article on how to protect consumer rights in online stores.
How do you work out the lowest price from the 30 days before a reduction?
The prior price is the lowest amount you charged in the 30 days before the reduction. Not the last regular price. The lowest one. Earlier promotions count towards that period too, so if you leave out the price from a previous campaign, you are breaking the rule (and this is probably the most common slip you see in stores).
You calculate the discount percentage from this value. In its guidance on price reduction announcements, the Commission gives a simple example: the slogan “half off”, a lowest price of EUR 100, and the goods most recently cost EUR 160. The basis is EUR 100. Not 160.
- You do not have to state how long the prior price applied.
- You show it at the start of the promotion and can keep it until the campaign ends, even if it runs for more than a month.
- Selling through several channels at different prices? You work out the lowest price separately for each channel.
When price reduction information is mandatory and when it is not
A message that merely suggests a reduction is enough. It does not have to mention an amount at all. Below is a breakdown of what requires the 30-day price and what does not.
- Required: a percentage or fixed-amount discount, a crossed-out price, “VAT off”, slogans such as “sale”, “Black Friday” and “special offer”, a discount code available to all visitors.
- Not required: ongoing loyalty programmes and discount cards, genuinely personalised coupons (e.g. birthday ones), the slogan “lowest prices” with no reference to a reduction, bundles such as “2 for the price of 1”, a cashback from the manufacturer.
But note: promotions outside this provision are still subject to the ban on unfair commercial practices. So they must not mislead the customer, and that is all there is to it. Oh, and the same Omnibus package also changed the rules on publishing customer reviews. That is a separate story, though.
How to display the prior price on the product page and in a banner
A general banner such as “discount on the entire range” does not have to include the prior price. However, every product covered by the campaign must show it in the price section in the store. Has the price stayed the same over the last month with no other campaign? Then the existing amount is enough. If there was a price increase or an earlier promotion, the displayed reference price needs to be corrected.
In my view, a simple layout is the clearest: the promotional price, and next to it the lowest price from 30 days with a clear label, e.g. “lowest price in the 30 days before the reduction”. An additional “regular price”? You can show it, but only with an explanation and in a way that does not draw attention away from the reference price. If you extend a promotion, mark it as an extension, not a new campaign. And since you are digging into the product page template anyway, take care of the remaining mandatory online store information while you are at it.
Omnibus in WooCommerce and PrestaShop: automatic price history
Manual calculation will break down sooner or later, because the store has to remember every price change. That is why I recommend one thing: price history in the database, with the value on the front end calculated automatically. The implementation looks roughly like this:
- Recording the price history of every product and variant.
- Automatically calculating the minimum from the 30 days before the promotion starts.
- Displaying that value on the product page and in listings.
- Handling scheduled prices and discount codes available to everyone.
- A test on a product that had two promotions within a month.
Omnibus in WooCommerce can be handled with a plugin that records price history or with custom code. Check variants and prices set by other plugins, because that is where data is most often missing. We help with changes like these as part of our stores built on WooCommerce service.
Omnibus in PrestaShop requires a module that records price history and takes cart rules into account. And then there are catalog price rules - these can lower a price without leaving any trace in the product history, so review them too. The configuration is covered by our PrestaShop store implementations.
Mistakes that most often break promotion compliance
Number one: a discount calculated from the regular price instead of the lowest price from the last month. Next come raising the price just before a campaign, leaving out the previous promotion and a missing reference price on product variants.
Discount codes “for everyone” that someone treats as personalised are risky too. Or a slogan about record markdowns when only a handful of products were marked down that heavily. Very long promotions are additionally assessed for unfair commercial practices.
Before you launch your next campaign, check one thing: whether the Omnibus Directive in your store is handled automatically through price history, or through a spreadsheet that someone updates by hand. If it is the latter, start there.
Frequently asked questions
Can a new product that has been on sale for less than 30 days be discounted?
The Directive allows member states to introduce a shorter reference period for goods that have been on the market for less than a month. How this exception works in Poland is settled by the Act on Informing about Prices of Goods and Services. Before you run a promotion on a new product, check its current wording.
Which price should I show when I lower the price gradually during a single promotion?
The Directive allows states to provide that, where a reduction is increased gradually, the prior price is the price before the first reduction. Does the Polish act make use of this? Check that before you plan the next stages of the markdown.
Does a discount code in a newsletter require the 30-day price?
Yes, if the code goes to many or most customers. It then works like a public price reduction announcement. A genuinely individual coupon, e.g. one granted after an earlier purchase, does not require it.
