EU Omnibus Rules: How to Show Sale Prices and Reviews Correctly on Shopify

Black Friday, summer sales and "was/now" pricing are some of the biggest revenue moments for any store. But if you sell to EU customers, the way you display those discounts is regulated, and most Shopify themes don't do it correctly out of the box.

The rules come from the EU's Omnibus Directive (2019/2161), which has applied since May 2022. It affects two things every store uses: sale prices and customer reviews.

Rule 1: The 30-Day Lowest Price

When you announce a price reduction to EU customers, the "before" price you show must be the lowest price you charged in the 30 days before the discount. You can't raise the price the week before Black Friday and then "discount" it back down.

On Shopify, the "compare-at price" is what creates the crossed-out price and the sale badge. The problem: Shopify lets you type any number there. It doesn't check your price history. So a store can easily show a compare-at price that breaks the rule without anyone noticing.

What compliance looks like in practice

• Keep a record of each product's price over time (per market, if your EU prices differ).
• When a product goes on sale, set the compare-at price to the lowest price from the previous 30 days.
• Or show a line such as "Lowest price in the last 30 days: €49" near the sale price.
• For gradual discounts during one campaign, the reference can be the price before the first reduction.

Rule 2: Honest Reviews

If you display customer reviews, you must tell customers whether and how you check that reviews come from people who actually bought or used the product. You also can't:

• Post fake reviews or pay for reviews presented as genuine.
• Hide negative reviews while showing positive ones.
• Present imported or incentivised reviews as verified when they're not.

A short "How we verify reviews" note near your reviews section, linked to a fuller explanation, covers the disclosure part. Most review apps (Judge.me, Okendo, Yotpo, Loox) mark verified buyers, which helps.

Other Omnibus Points Worth Knowing

• Personalised pricing: if prices change based on a customer's behaviour or profile, you must say so.
• Paid ranking: if products are promoted because someone paid for placement, that should be labelled.
• Penalties: for widespread infringements, fines can reach at least 4% of annual turnover in the countries concerned, or €2 million where turnover data isn't available.

Why Shopify Stores Get This Wrong

1. Compare-at prices set once and forgotten, so they show an "original" price you haven't charged in months.
2. Bulk sale apps that apply a percentage off without checking price history.
3. Different prices per market through Shopify Markets, which makes the history harder to track.
4. Review widgets with no explanation of verification.

How to Set It Up Properly

1. Track price history automatically. A small custom app or script can save each product's price daily into a metafield.
2. Calculate the 30-day low per product and per EU market.
3. Display it on the product page for EU visitors: "Lowest price in the previous 30 days: €X".
4. Validate compare-at prices before a sale goes live, flagging any that are higher than the 30-day low.
5. Add a review verification note to your review section and FAQ.

For small catalogs you can handle this manually with a spreadsheet. Beyond a few dozen products, automation saves hours every campaign and removes the risk of a costly mistake on your busiest days.

Frequently Asked Questions

Does this apply to UK customers?

The Omnibus Directive is EU law. The UK has its own pricing rules under the Consumer Protection from Unfair Trading regime and new digital markets and consumer law, which also prohibit misleading reference prices.

Does it apply to "free shipping" or "buy one get one" offers?

The 30-day rule is about announced price reductions. Other offers must still not be misleading, but the specific prior-price rule targets price cuts.

Does it apply to new products?

If a product hasn't been on sale for 30 days, the rules on the reference price can differ by country. Keep records from day one.

This article is general information, not legal advice.

Want automatic 30-day price tracking and compliant sale badges on your Shopify store? I build custom price history tools and theme updates for EU sellers. Get a free quote or see custom Shopify app development.