What the Price Indication Ordinance requires for Black Friday discounts
The German Price Indication Ordinance (Preisangabenverordnung, PAngV) obliges traders to state the lowest total price of the 30 days before the reduction whenever they announce a price reduction for goods to consumers (Section 11(1) PAngV). The rule implements Article 6a of Directive 98/6/EC, was incorporated into the PAngV as part of the transposition of the Omnibus Directive and has applied in Germany since 28 May 2022.
The Federal Court of Justice (Bundesgerichtshof, BGH) clarified on 9 October 2025 what this statement must look like (case I ZR 183/24): the 30-day price must be stated in a way that is unambiguous, clearly recognisable and easily legible for consumers. In the case decided, a food discounter had advertised a coffee in a leaflet with “-36 %” and mentioned the 30-day best price only in a footnote in small print. That was not sufficient; the advertising was unfair under the German Act against Unfair Competition (UWG). The standard derives from Section 11(1) PAngV in conjunction with the requirements for clearly and comprehensibly communicated material information under Sections 5a and 5b UWG. The BGH classified the advertising as misleading within the meaning of the UWG.
The requirements developed by the BGH for an unambiguous, clearly recognisable and easily legible statement apply to the announcement of price reductions to consumers and are therefore also relevant for banners, category pages and product pages in an online shop.
The key points at a glance:
Rule | What this means for your campaign |
|---|---|
Reference price | The lowest total price you charged consumers in the 30 days before the price reduction (Section 11(1) PAngV). |
Presentation | Unambiguous, clearly recognisable and easily legible. A footnote in small print is not sufficient (BGH, judgment of 9 October 2025, I ZR 183/24). |
Progressive reduction | If a discount increases step by step without interruption, the lowest price before the first step may be stated (Section 11(2) PAngV). |
Exceptions | Individual price reductions and perishable goods or goods with a short shelf life where spoilage is imminent (Section 11(4) PAngV). |
Scope | The obligation applies to consumers. Offers made exclusively to businesses are not covered by Section 11 PAngV. |
What this means for Black Friday 2026
In 2026, Black Friday falls on Friday, 27 November. If your campaign starts on that day, the 30-day window goes back to 28 October 2026. Every price change during this period can change the reference price. If the campaign starts in the week before, the window shifts accordingly. Percentages, discount badges and strike-through prices should therefore technically draw on the same reference price, so that the homepage banner does not show a different discount from the product page.
The EU is specifically checking discount campaigns
On 26 March 2026, the European Commission published the results of a coordinated check (“sweep”) of Black Friday and Cyber Monday. Authorities from 23 EU countries as well as Iceland and Norway examined 314 online traders:
Finding | What the authorities found |
|---|---|
30 per cent | referenced discounts incorrectly, i.e. not on the basis of the lowest price of the last 30 days. |
34 per cent | displayed price comparisons; 60 per cent of them did not clearly explain where the reference price came from. |
36 per cent | attempted to add optional items to the basket, 40 per cent of them without clearly asking for consent. |
18 per cent | used pressure-selling techniques such as countdown timers or scarcity claims; more than half of these cases were misleading. |
10 per cent | relied on “drip pricing”, where extra fees only appear late in the purchasing process. |
Following the sweep, national consumer protection authorities may take action against the businesses concerned. The discount is therefore only one of several checkpoints that come together in Black Week.
New since 27 September 2026: labels for legal guarantees and commercial guarantees
Since 27 September 2026, traders selling goods to consumers must refer to the statutory legal guarantee using a harmonised EU label; for certain manufacturer guarantees, a product-specific guarantee label is added. The legal basis is the EmpCo Directive (EU) 2024/825, implemented in Germany in Article 246(1) nos. 5 and 5a of the Introductory Act to the German Civil Code (EGBGB). The design and text of the labels are governed by Implementing Regulation (EU) 2025/1960. This does not create new consumer rights; what is new is the obligation to point out the existing rights prominently.
Legal guarantee label (harmonised notice)
Generally mandatory when selling the goods concerned to consumers. It provides information on the statutory legal guarantee, including the minimum period of two years, and contains a QR code linking to the EU portal “Your Europe”. In online retail, it must be displayed in colour. In online retail, integrating it into the terms and conditions could be sufficient; however, this has not been conclusively clarified. Alternatively or in addition, a clearly visible placement on the website may be considered. In addition, the label must be provided on a durable medium with the order confirmation, for example as a PDF file in colour.
Guarantee label (“GARAN”)
Mandatory if the manufacturer grants a free commercial guarantee of durability for the entire product lasting more than two years and makes this information available to the trader. The label shows the guarantee period, manufacturer and model, must be placed in colour next to the product image online and must appear in the basket for every product concerned. A nested display is possible.
Good to know
These information obligations do not apply to contracts between businesses (B2B). The guarantee label in particular is a data issue: duration, manufacturer and model must be available for each product. Anyone maintaining this information manually in the shop will quickly have gaps in large ranges.
How Shopware 6.7.16 supports merchants with discounts and labels
On 2 November 2026, Shopware released version 6.7.16.0, which addresses both obligations as standard. According to the release notes and the summary by the Shopware agency Splendid, these changes are particularly relevant for Black Friday campaigns:
Change | What it does in the shop |
|---|---|
Discounts based on the 30-day lowest price | If the lowest price of the last 30 days is stored for a product, the storefront calculates the percentage saving on this basis rather than on the regular strike-through price. If the selling price is not below it, Shopware no longer shows a discount or discount badge. |
Guarantee information in more places | GARAN labels and guarantee terms are available on product pages, in the checkout and in order confirmations. Guarantee terms can be stored per product as a PDF or link and are saved when the order is placed. |
Legal guarantee notice in the checkout | The notice on the statutory legal guarantee can be displayed directly below the terms and conditions, provided the general legal guarantee notice is activated. |
However, an update alone does not make a campaign legally compliant. The 30-day price must be maintained correctly for each product, and you should test themes, plugins or custom templates that calculate strike-through prices or badges themselves against the new behaviour before Black Week begins.
Who is affected?
Every company that sells goods to consumers or advertises prices to them is affected – including manufacturers and wholesalers that operate their own consumer channel alongside their B2B business. In practice, these are mainly:
B2C and D2C online shops advertising with percentages, strike-through prices or discount badges for Black Week.
Hybrid shops where business and private customers order via the same platform, for example with separate customer groups or sales channels.
Merchants whose manufacturers grant guarantees of durability of more than two years and provide this information.
Pure B2B shops that sell exclusively to businesses and offer consumers neither prices nor ordering options are covered neither by Section 11 PAngV nor by the label obligations. The decisive factor is whether consumers can actually see prices, receive offers or conclude contracts. However, check whether your shop really only addresses business customers and prices are not accessible to consumers.
Jochen Kernwein,
CSO at elio GmbH
Five steps to a legally compliant Black Friday campaign
Step 1: Clarify customer groups and channels
Determine where consumers see your prices: in the D2C shop, on marketplaces, in the newsletter or in a B2B shop with open registration. Section 11 PAngV and the label obligations apply only there – but there on every touchpoint.
Step 2: Check and document 30-day prices
Record the price history from 28 October 2026 and maintain the lowest price of the last 30 days for each product in the shop, ideally automatically from your ERP or PIM. Avoid short-term price increases before the campaign.
Step 3: Standardise the presentation on all touchpoints
Homepage banner, category, product page, basket and newsletter must use the same reference price. Show the 30-day price legibly next to the discount, not in a footnote, and explain comparison prices such as the RRP clearly.
Step 4: Integrate legal guarantee and guarantee labels
Include the legal guarantee label in colour on the website or in the terms and conditions and in the order confirmation. For products with a manufacturer guarantee of more than two years, the guarantee label belongs next to the product image and in the basket, fed from the manufacturer data.
Step 5: Update, test and check under load
Test the Shopware update, plugins, promotions and discount rules in a staging environment and check the checkout for the other sweep findings: no pre-selected additional items, no false countdowns, all fees visible early on. A load test before Black Week shows whether the shop can handle the rush.
Inaction can be costly
An infringement of Section 11 PAngV may be relevant under competition law as a misleading commercial practice under Sections 5a and 5b UWG and may give rise to risks of injunctions and warning costs. In the BGH case, the Wettbewerbszentrale (Centre for Protection against Unfair Competition) had sued for an injunction and reimbursement of the warning costs and won at every instance. In addition, there are the national authorities, which may take action following the EU sweep. Especially in the highest-turnover week of the year, a campaign stopped at short notice costs more than any preparation.
What this means for B2B decision-makers
Benefit | What changes in your company |
|---|---|
One price source instead of coordination chaos | If prices, price history and guarantee data come from one leading system, the risk of warnings falls, and e-commerce, marketing and sales no longer need to reconcile campaign prices by hand. |
Clear channel separation instead of a grey area | Clean customer groups for business and private customers ensure that consumer obligations apply where they are relevant and your B2B pricing logic remains unaffected. |
Campaign readiness instead of a hotfix in Black Week | If you map the rules in your shop system, you can launch campaigns at short notice without having templates, legal texts and discount logic checked individually before every campaign. |
The right partner at your side: how elio supports you
Many manufacturers and wholesalers operate their consumer channel alongside their B2B business and maintain prices in ERP, PIM and shop in parallel. This is exactly where we come in:
Shopware Update Flatrate
We regularly check, install and test core and plugin updates at a fixed monthly price – so changes such as those in Shopware 6.7.16 reach your shop in a controlled way. More: Shopware Update Flatrate
Shopware consulting
We analyse your shop technically, strategically and in terms of UX and develop concepts for B2B, B2C and D2C, for example for clean customer groups and sales channels. More: Shopware consulting
Shopware plugin development
If the standard is not enough, for example for your own price or label logic, we develop individual extensions. More: Shopware plugin development
elio Consulting Services
With load tests, system analyses and readiness checks, we prepare your shop for the peak season. More: elio Consulting Services
We estimate the effort individually after a brief assessment. We do not replace legal advice; please have the legal assessment of your campaign coordinated with your legal advisers.
Conclusion: legally compliant discounts are a question of clean price data
The Price Indication Ordinance does not require anything new for Black Friday 2026, but courts and authorities are looking more closely. The labels for legal guarantees and commercial guarantees add a second obligation that mainly concerns product data. Shopware 6.7.16 provides the right functions, but responsibility for correct prices and data remains with the merchant. Anyone who checks price sources, channels and presentation now will start Black Week safely and benefit from this in every future campaign.
FAQ on the Price Indication Ordinance for Black Friday
The lowest total price you charged consumers in the 30 days before the price reduction (Section 11(1) PAngV). It must be clearly recognisable and easily legible.
No. On 9 October 2025, the Federal Court of Justice ruled that a footnote in small print is not sufficient if it is not unambiguous and easily legible for consumers (I ZR 183/24).
Section 11 PAngV applies to consumers, and the labels for legal guarantees and commercial guarantees do not apply to B2B contracts. If you operate a mixed shop, the obligations apply to the consumer area.
When the manufacturer grants a free commercial guarantee of durability for the entire product lasting more than two years and makes this information available to the trader. The legal guarantee label, by contrast, is generally mandatory when selling the goods concerned to consumers.
Sources and further information
Section 11 PAngV (gesetze-im-internet.de, in German) https://www.gesetze-im-internet.de/pangv_2022/__11.html
Federal Court of Justice, press release no. 184/2025 on the judgment of 9 October 2025 – I ZR 183/24 (in German) https://www.bundesgerichtshof.de/SharedDocs/Pressemitteilungen/DE/2025/2025184.html
European Commission: EU check reveals misleading sales practices online, 26 March 2026 https://commission.europa.eu/news-and-media/news/eu-check-reveals-misleading-sales-practices-online-2026-03-26_en
IHK Munich: labels for legal guarantee and commercial guarantee (in German) https://www.ihk-muenchen.de/ratgeber/recht/vertragsrecht/labels-fuer-gewaehrleistung-und-garantie/
Commission Implementing Regulation (EU) 2025/1960 (EUR-Lex) https://eur-lex.europa.eu/legal-content/DE/TXT/HTML/?uri=OJ:L_202501960
Shopware: release notes 6.7.16.0 https://developer.shopware.com/release-notes/6.7/6.7.16.0.html
Splendid Internet: Shopware releases in November 2026 (in German) https://www.splendid-internet.de/blog/shopware-releases-im-november-2026/
The information published on this page does not constitute legal advice and is provided for information purposes only; due to changes in the legal situation, it may no longer be up to date. No liability is accepted for the accuracy or completeness of the content.
As of: 12 November 2026
Would you like to have your Shopware shop checked before Black Friday?
elio supports you with updates, Shopware consulting, individual extensions and preparation for the peak season – from the initial assessment to the load test.
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