Under the Omnibus rules, a discount must show the lowest price in the last 30 days, and the resulting questions sound simple: “Why is the discount based on a different amount?” or “It was cheaper two weeks ago, so where is the sale?”. Your agent has to explain numbers they did not set, and a guess can damage trust or concede a point that needs checking. Below are reply templates for five common situations and a rule for when a chat goes to the person who owns pricing.
This is not legal advice, and it does not judge whether a specific promotion complies. It is an EU rule, not a UK one, so check UK pricing rules separately for UK shoppers. Preparing the whole team for a campaign is covered in the guide to Black Friday customer support, and testing prices on the site before launch in the guide to your Black Friday landing page.
What the lowest price in the 30 days before a reduction means
Under Article 6a of the EU Price Indication Directive, added by the Omnibus Directive, any announcement of a price reduction must show the prior price: the lowest price the trader applied in at least the 30 days before the reduction. Member states implement it in national law; Poland, for example, has applied it since 1 January 2023. With different prices per sales channel, the lowest price is set separately for each channel.
The European Commission guidance on Article 6a explains the scope, the per-channel calculation and member state options for new products and progressive reductions. European Commission guidance, 2021. It does not say whether a particular promotion in your shop was correct.
The percentage shown must refer to the lowest 30-day price, not the price on the day before the campaign, so the reply should point to the reference price on the product page. A different amount in the cart is a bug to report.
What to check before you reply
Most replies depend on data the shopper cannot see: when the reduction started, earlier prices and whether the product was even on sale for 30 days. Get it from the shop admin or whoever set up the promotion. Without access, tell the customer you are checking the price history and say when you will reply.
- The start date of the reduction and the sales channel in question: online shop, app or physical store.
- The price history in that channel for the 30 days before the reduction.
- The first day of sale and any breaks, such as stock-outs.
- The amount the percentage is based on, on the product page and in the cart.
- The type of offer: a reduction on a specific product, a “3 for 2” deal, a discount code or a loyalty member price.
Five situations that come back with every promotion
Questions about the 30-day price follow a few patterns. The table shows what to establish and the core of each reply.
Scroll the table sideways to see all columns.
| Situation | What to establish | Core of the reply |
|---|---|---|
| Product on sale for under 30 days | The first day of sale | The period may run from the start of sale; check your country |
| Progressive reduction, first -20%, then -40% | Prices before each step | Rules differ by country; check yours before replying |
| Struck-through price differs from the lowest price | What each amount on the page means | Name both amounts and say which one the discount uses |
| Conditional offer, such as “3 for 2” | Whether a single product's price was cut | A bundle deal may not require the 30-day price |
| Fake sale accusation | Price history and the shopper's screenshot | Log it, check it and pass it to the pricing owner |
The 2023 explanations from Poland's consumer authority UOKiK state that Polish law has no separate rule for progressive reductions, and that “3 for 2” offers without a price cut on a specific product do not need the 30-day price, unlike “third item 50% off”. UOKiK explanations on price reductions (Polish). They describe Polish practice only and do not replace court rulings.
For progressive reductions, the directive leaves the choice to member states: Germany's price regulation allows the price before the first step, Poland does not. Selling abroad? Agree the rule for each market with whoever owns pricing.
Reply templates to save as macros
These templates use a fictional kitchenware shop. Fill the bracketed fields from the product page.
“We have been selling this kettle since [date]. That is why the reference price for the reduction is the lowest price since that day, [amount]. The [percentage] discount is calculated from it.”
“The reduction grew in two steps. Under the rule we apply in [country], the reference price for the second step is [amount]. So the percentage looks smaller than a comparison with the pre-campaign price.”
“You can see two amounts on the page. [Struck-through amount] is [label from the page], and [amount] is the lowest price in the 30 days before the reduction. We calculate the [percentage] discount from the second one. If your cart shows something else, send me a screenshot.”
“The “3 for 2” deal does not lower the price of a single item; it adds a third one to the set. That is why we do not show a 30-day price for one item in this deal. One pot still costs [amount].”
When a customer says the sale is fake
“You raised the price before the sale” is the hardest message, because the customer may be right. Your agent should not deny it unchecked or admit that the shop broke the law; the job is to collect facts and escalate.
- Thank them and ask for evidence.Ask for a screenshot or date of the lower price, and the channel: website, app or store.
- Compare with the price history.Check whether that amount applied in the same channel in the 30 days before the reduction.
- Pass it to the pricing owner.Describe the case in an internal note: product, dates, amounts and the screenshot. Do not promise a refund of the difference or a price correction.
- Reply by the time you promised.Share the result in the same conversation and explain any correction.
The Court of Justice press release on its judgment of 26 September 2024 in case C-330/23 (Aldi Süd) states that a reduction announced as a percentage or as a promotional claim must be based on the lowest price in at least the 30 days before it. CJEU press release No 152/24. The ruling does not assess promotions in any particular online shop.
A first reply: “Thanks for flagging this. I will check this product's price history and get back to you by [time]. If you have a screenshot of the lower price, please send it here.” Refunding the difference after a purchase is covered in the guide to price adjustment requests after Black Friday. Individual discounts are covered in the guide for when a customer asks for a discount.
A tag for products and a pricing note in the Help Center
Questions about the 30-day price are a signal for pricing. Create one tag, such as “30-day price”, add it to every related conversation and write the product name in an internal note. In Meetlead customer support each tag has a usage counter, so you see the volume, and tagged chats show which products people asked about. Consistent naming is covered in the guide to tagging conversations and tickets.
Save the templates as team macros in one category. Macros support variables and an editable preview for amounts and dates. Publish a short pricing note in the Help Center shown in the widget: what the lowest 30-day price means, what your discounts are based on and how to raise a concern. If you use Meet AI, published articles reach its knowledge automatically, so the assistant and Copilot suggestions rely on the same text as your team.
Keep product amounts out of the note and update it the same day the price display changes.
Questions about the lowest 30-day price
Can an agent admit that a promotion was wrong? They should not. Judging compliance belongs to the pricing owner and, when in doubt, to a lawyer. The agent collects facts and hands the case over.
Does a discount code also need the lowest 30-day price? The Commission guidance treats codes that many or most customers can use as announced reductions, while personalised discounts, such as a birthday offer, fall outside the rule. If a code does not work at all, use the guide to a discount code that is not working. This text is not legal advice.
