Sale Prices and the 30-Day Rule Irish Websites Keep Breaking

A bed and mattress showroom in Longford switched on its summer clearance one Friday morning. Frames that had carried a €899 tag for most of the year went live as "Was €899. Now €599." Real stock, real intent to shift it, no wish to mislead anyone.

The problem sat in June. A quiet ten-day promotion had put those same frames at €649, and it ended less than a month before the clearance began. Nobody thought about it again.

That forgotten promotion is what turned an honest markdown into an offence. This is a composite of a pattern we see constantly rather than one named business, and it is far and away the most common way an Irish trader breaks the sales pricing rules while trying to do the right thing.

What the Law Actually Asks You to Do

The rule arrived with S.I. No. 597 of 2022, signed on 28 November 2022, which inserted a new Regulation 5A into the 2002 price indication regulations ^[1]. It gives effect to the EU Omnibus Directive, and it is short enough to quote.

Where a trader announces a reduction in the selling price of a product, the trader must indicate, in that announcement, the prior price. The prior price means the lowest selling price applied by the trader to that product during a period of not less than 30 days before the reduction. Contravening it is an offence.

So the test is not whether €899 was a genuine price. It was. The test is whether €899 was the lowest price in the previous 30 days. It was not. Once that June promotion is inside the window, the lawful announcement reads "Was €649. Now €599," and the saving on the banner is fifty euro rather than three hundred.

A separate paragraph in the same instrument, Regulation 6(2A), adds that the announcement must be unambiguous, easily identifiable as referring to that product, and clearly visible and legible. A prior price buried in a tooltip does not satisfy it.

I got this wrong myself a few years ago. I told a client that as long as the higher figure was a price they had genuinely charged at some point, they were covered. That was true before 2022, and I was slow to notice it had stopped being true. The rule is not "a real price". It is "the lowest recent price".

Your Shop Software Writes the Announcement For You

The part that catches owner-operators has nothing to do with intent.

In a WordPress shop, you fill in two fields: a regular price and a sale price. From that moment the software generates the announcement on your behalf. The strike-through on the product page. The "save 33%" badge on the category grid. The sale flag in your product feed. The price block in the automated email that goes to your list on Friday evening.

Every one of those is an announcement under Regulation 5A. And your shop has no idea what you charged in June, because nothing in the software was ever asked to remember.

That is the difference between this and a plain mistake on a product page. If a price on your own site is simply wrong, the question is what you owe the customer who ordered at it. Here, nothing about the transaction is wrong at all. The customer pays €599 and gets a bed frame worth having. The offence lives entirely in the sentence beside the price.

Four Ways This Goes Wrong on Irish Product Pages

The CCPC has been specific about the practices it sees, and they map almost exactly onto the settings in a typical shop plugin.

What the page says	Why it fails	What to publish instead
"Was €899, now €599" after a €649 promotion three weeks earlier	The struck price is not the lowest in the previous 30 days	"Was €649, now €599"
"RRP €120, our price €69"	An RRP you never charged is not a prior price	Your own lowest recent price, or no reduction claim
A ten-week campaign moving 20%, then 30%, then 50% off	Later stages measured against the sale price, not the pre-sale price	Every stage measured against the price before the campaign began
"20% off everything" banner, no prior prices on product pages	The general banner is fine; the individual products still need prior prices	Prior price shown on each product page

The forgotten promotion. This is the showroom's problem, and it is the one that punishes organised businesses hardest. The more responsive you are with short offers, the more likely one of them sits inside your 30-day window when the big sale starts. The CCPC guidance notes the day the reduction is applied is not itself counted in the 30 days ^[2].

The RRP dressed up as a price. Presenting a manufacturer's recommended price as though it were previously yours is on the CCPC's list of breaches. Nothing stops you telling a customer what the RRP is. What you cannot do is measure your discount against a number you never charged.

The campaign that keeps deepening. Regulation 5A(3)(b) handles this directly. Where reductions are consecutive, the prior price is the lowest price in the 30 days before the first reduction. It does not reset each time you go deeper, which means a January campaign still measures against your December price in March.

The site-wide banner. A general announcement such as "20% off everything" does not need a prior price in the banner itself. The CCPC is clear, though, that the prior price still has to appear for the individual goods, on the tag in the shop or on the product page online. That is where automated sales, applied to a whole category at once, quietly create hundreds of announcements nobody checked.

What Enforcement Looks Like Now

For a while this looked like a rule without teeth. That ended some time ago.

The CCPC ran an engagement phase, then said publicly in July 2023 that sales pricing had become an enforcement priority, with Kevin O'Brien putting it plainly: "A discount must be a real discount." The first prosecutions under the 2022 legislation followed in March 2025, when Lifestyle Sports, DID Electrical and Rath-Wood Home and Garden World each pleaded guilty in the District Court to contravening Regulation 5A ^[3]. Each was ordered to pay €1,000 to charity plus the CCPC's costs, which ran from roughly €2,500 to €3,600 across the three cases. All three were detected by online sweeps over the 2023 to 2024 winter sales season, including Black Friday.

In January 2026 the department store group Brown Thomas Arnotts pleaded guilty on the same ground, following sweeps the CCPC carried out between October and December 2024 ^[4].

Then the scale of it. A coordinated European screening published on 26 March 2026, run by the Commission with the CCPC and authorities across 23 member states, looked at 314 online traders in cosmetics, fashion, furniture and electrical goods. Roughly three in ten were referencing discounts incorrectly ^[5]. Screening flags apparent problems rather than proven ones, so treat that as an indication of how ordinary the breach is rather than a conviction rate. About one in five used scarcity claims or countdown timers, and more than half of those were judged misleading.

The financial exposure is modest and beside the point. S.I. 597 of 2022 raised the penalty to a class A fine, currently up to €5,000 per offence, and told the court to weigh the nature, gravity, scale and duration of the breach. It also added the offence to the list in section 85 of the Consumer Protection Act 2007, which means an authorised officer can serve a fixed payment notice of €300 rather than prosecute ^[6].

Three hundred euro is not what should worry a small trader. Publication is. The CCPC names every business that receives a notice, with trading name and location, in a press release that ranks for your business name and stays there. In February 2026 it published eight fixed payment notices at €300 each for price display failures, alongside compliance notices to pubs, a jeweller and two influencers. Forecourt shops and discount retailers sat in the same list as household names. That page is now part of what a customer finds when they search you.

Where the Rule Stops, and What It Cannot Do For You

Two honest limits, because both change what you need to do on Monday.

The first is scope. The CCPC states that these obligations apply to businesses selling goods and do not apply to services, including digital services and digital content ^[2]. A salon discounting a colour treatment, an accountant taking twenty per cent off a first-year fee, a trainer running an offer on a block of sessions: none of that falls under Regulation 5A. That is not a licence to say anything you like. Misleading commercial practices under the Consumer Protection Act 2007 still apply to service pricing, and if your comparison is one you could not substantiate, take advice on it before it goes live rather than after.

The second limit is the awkward one. No shop platform will do this for you. WordPress will not, and neither will the hosted alternatives, because none of them keeps a durable, dated record of what you charged for each line over the previous month in a form you could hand to an officer. Your order history proves what customers paid, which is close but not the same thing as what you displayed. So the compliance work is a log you keep yourself, and it takes about five minutes before each sale.

If you run several thousand lines across a shop, a marketplace and a wholesale channel, that answer stops being good enough, and dedicated retail pricing software with a proper audit trail earns its licence fee. For a catalogue of a few dozen products, a spreadsheet and a folder of screenshots is genuinely sufficient.

What matters more is that you can reach your own pricing at all. A shop where you control the product data, export it whenever you want and keep your own records is a different proposition to one where pricing history lives inside somebody else's platform. That is one of the practical arguments for a full WordPress shop with hosting, backups and SSL included for €60 a year: the data is yours, in a database you can query, on infrastructure that keeps nightly backups of the lot.

Running a Sale That Holds Up: Five Steps

Record. Before you touch a price, export your current product list with prices and the date. A CSV from your shop and a screenshot of two or three key product pages is plenty.

Verify. For each item going into the sale, check the lowest price you actually charged in the previous 30 days, including short promotions, discount codes applied at the item level, and flash offers to your email list.

Price. Set your sale price against that verified figure, and set the displayed prior price to match it. If the discount now looks smaller than you hoped, that is the accurate number.

Deploy. Push the change and read the result the way a customer meets it: product page, category grid, search results on your own site, and the marketing email. Every surface carries the same prior price.

Retain. Keep the export, the screenshots and the campaign dates for at least a year. If a query ever lands, the evidence takes minutes to produce instead of days.

Back to the Showroom

The frames sell either way. That is the thing worth sitting with.

"Was €649. Now €599" is a smaller headline than "Was €899. Now €599," and it converts perfectly well, because the customer walking into a bed showroom in July is comparing your €599 against other shops' €599, not against your own history. The €300 claim was never doing the work the owner thought it was doing. It was just carrying a risk nobody had priced.

Sales pricing sits in the same category as the wording on your returns page: a small piece of text that most owners treat as marketing and the law treats as a statement of fact. Both are cheap to get right in advance and awkward to explain afterwards.

Conclusion

I was on a call this week with an owner planning an autumn clearance, and the whole conversation took about ten minutes once the rule was on the table. What did you charge in the last month. What is the lowest of those figures. That is your starting number.

The thirty-day lookback is not a trap for people trying to mislead anyone. It mostly catches businesses that run frequent, genuine offers and then forget them. Before your next sale goes live, the useful question is not what your usual price is. It is what your lowest price was.

Frequently Asked Questions

What is the prior price for a sale in Ireland?

It is the lowest selling price, or unit price where that applies, that you charged for the product during a period of not less than 30 days before the reduction. That definition sits in Regulation 5A(3) of the 2002 price indication regulations, as inserted by S.I. No. 597 of 2022. It has to appear in the announcement itself, clearly and legibly, not in a footnote.

Does the 30-day rule apply to a small online shop?

Yes. The regulations apply to traders selling goods to consumers and carry no turnover or headcount threshold, so a sole trader selling three dozen product lines is covered on the same terms as a department store. The CCPC confirms the obligations extend to distance selling, which covers online, phone and mail order.

Can I advertise a discount against the recommended retail price?

Presenting an RRP as though it were a price you previously charged is one of the practices the CCPC has specifically identified as a breach. You can mention an RRP for context. What you cannot do is measure your reduction against a figure you never applied yourself.

How does the rule work if my sale runs for weeks with deeper discounts?

Regulation 5A(3)(b) deals with consecutive reductions. The prior price stays the lowest price applied in the 30 days before the first reduction, so every later stage of the campaign is measured against the same pre-sale figure rather than against the previous sale price.

Do these rules apply to services?

The CCPC states that the obligations apply to businesses selling goods and do not apply to services, including digital services and content. A service discount is outside Regulation 5A. Misleading pricing claims about services can still fall under the Consumer Protection Act 2007, so a comparison you cannot substantiate remains a risk worth checking with your solicitor.

What happens if I get it wrong?

The penalty on conviction is a class A fine, currently up to €5,000 per offence, and a court weighs the scale and duration of the breach. An authorised officer can also serve a €300 fixed payment notice instead of prosecuting. In practice the bigger cost for a small business is publication, because the CCPC names the businesses that receive notices and the release stays searchable.

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