Unit Pricing: The Second Price Your Online Shop Has to Show

The CCPC published its latest batch of enforcement actions on 27 July. Thirty-one fixed payment notices and compliance notices, eighteen traders, and three headings. The middle heading is the one nobody quotes: failure to display unit pricing. Five retailers sit under it, carrying eleven separate notices between them at 300 euro a time ^[1].

Every business named there has a front door. Convenience stores, homeware shops, a hardware and pet centre. So the natural conclusion is that unit pricing is a shelf-edge problem, something that happens to people with price guns, and that a website has nothing to do with it.

I made that exact call myself a couple of years ago. A food producer asked me whether the price display rules were going to be a problem for the shop they were building online, and I told them price display was a shop floor issue. I was answering from the shop floor version of the rule rather than from the regulation, and the regulation says something wider. Worth reading before you answer, which is the whole reason for this piece.

What a unit price actually is

Two prices, not one. The selling price is the number a customer pays for the thing in front of them. Alongside it sits the unit price, what that works out at per standard quantity, so a shopper can compare a 250g bag against a 1kg bag without doing sums in a supermarket aisle or on a phone.

The European Communities (Requirements to Indicate Product Prices) Regulations 2002 set out both. Regulation 2 defines the unit price as the final price in euro, including VAT and all other taxes, for one kilogram, one litre, one metre, one square metre or one cubic metre of a product ^[2]. Two categories get their own quantities in the Schedule: wine, sparkling wine, liqueur wine and fortified wine are priced per 75cl, and spirits per 70cl.

The CCPC adds one detail that catches drinks sellers. Calculation runs on the total cost of the good including all taxes and charges, but where the Re-turn deposit applies, the deposit is left out of the calculation ^[3]. That is the same deposit that has its own set of display rules on your product page, and the two rules pull in opposite directions, so it is worth getting straight once rather than guessing twice.

The line that puts this on your product page

Regulation 5(1) is the duty itself: where a trader indicates that a product is or may be for sale to a consumer, the trader shall indicate the unit price of the product. No reference to a shop. Nothing about a shelf.

Regulation 6(1) is where it lands. It says the indication of the selling price and, where appropriate, the unit price must be unambiguous, clearly visible and legible, and "in proximity to the product or, in the case of a product for sale by distance contract, to the description of the product" ^[2].

Read that last clause again. The drafters stopped mid-sentence in 2002 to write a rule for people who were not selling across a counter. A distance contract is defined in the same regulations as a contract entered into by any means not involving the trader and consumer being present together. That is your website, your phone orders, and your order form. The place the unit price has to sit, in that setting, is beside the product description. Which is a product page.

I want to be straight about the limits of that, because it matters. Every trader named under the unit pricing heading in July was inspected in a physical shop, and I have not seen a published Irish notice issued against a website for a missing unit price. What the CCPC does say is that the enforcement actions came from inspections and investigations carried out by its officers "in store and online" ^[1]. The rule text reaches product pages. Visible enforcement, so far, has been in shops. Those are two different facts and you should plan against both of them.

Which of your products this actually catches

Most catalogues are a mix. Some lines need the second price, several do not, and one category flips the rule the other way round.

What you are selling	What has to be shown	Where the rule sits
Pre-packed goods over 50g or 50ml sold by weight, volume or measure	Selling price and unit price	Regulations 4 and 5
Pre-packed goods of 50g or 50ml and under	Selling price only	Regulation 5(2)(a)
Items where price is not tied to quantity	Selling price only	Regulation 5(2)(b)
An assortment of different items in one package	Selling price only	Regulation 5(2)(e)
Loose goods weighed in front of the customer	Unit price only	Regulation 4(2)(a)

Pre-packed goods sold by weight, volume or measure. Coffee, flour, oil, cleaning products, pet food, loose-leaf tea, paint, rope by the metre, compost by the litre. If the pack is over 50g or 50ml and the price relates to how much is in it, both prices are due. This is the bulk of a food, drink or hardware catalogue.

Small packs. Regulation 5(2)(a) exempts anything pre-packaged with a content equal to or less than 50 grams or 50 millilitres. Sample sachets, spice packets, small confectionery. The CCPC gives packets of sweets, crisps and popcorn as its examples ^[3]. No unit price needed, and adding one on a 15g sachet produces a number that helps nobody.

Price not related to quantity. Regulation 5(2)(b) covers the case where the selling price has nothing to do with how much of the product you get. The CCPC's examples are a melon or a turnip sold by the item, and cuts of meat where the weight varies but a fixed price is charged ^[3]. A bespoke piece, a single artwork, a made-to-measure item: same logic.

Assortments. A hamper, a gift box, a mixed case. Regulation 5(2)(e) exempts a product comprising an assortment of different items sold in a single package, which is a relief for anyone who has tried to work out the price per kilo of a Christmas box containing chutney, a candle and shortbread.

Loose goods. This one runs the opposite way. Products sold in bulk, meaning not pre-packaged and measured in the presence of the consumer, are outside the selling price duty under Regulation 4(2)(a), and the CCPC's position is that where a product is sold loose by weight, only the unit price is displayed ^[3]. A deli counter is the classic case. It translates awkwardly to a website, because nothing is measured in front of anybody online, so if you list a cheese at a price per kilo and let people order a rough weight, take advice on how you are describing the sale.

There is one further exemption worth naming honestly rather than leaning on. Regulation 5(2)(g) removes the unit price duty for goods sold other than in bulk in a premises where the trader does not use shelf edge label printing equipment or point of sale scanning, and for itinerant traders ^[2]. It was written for the small shop with a biro and a notepad. Whether it does anything for a seller who has no shop at all and takes every order through a website is not obvious from the text, and it is not the kind of question to settle by reading a blog post. If your catalogue turns on that exemption, put it in front of a solicitor.

What getting it wrong costs

Three layers, and only the first is the one people picture.

A fixed payment notice is a set fine of 300 euro that the CCPC can issue for failing to display prices correctly ^[1]. The unit price offence is on that list by name: section 85(1)(c) of the Consumer Protection Act 2007 lists Regulation 5(5) of the 2002 regulations among the offences an authorised officer can deal with by fixed payment notice ^[4]. Pay within 28 days and no prosecution follows.

Prosecution is the second layer. Regulation 12(2) originally carried a fine not exceeding 3,000 euro. The 2022 amending regulations replaced that with a class A fine, which runs to 5,000 euro, and added sentencing criteria covering the nature, gravity, scale and duration of the breach, any previous infringements, and the financial benefit gained ^[5].

The third layer is the one that lasts. Names get published. The July release is a public web page with trading names, addresses and the specific notices attached, and it stays there. Nobody is going to ring you about it. It simply sits in the search results under your own business name, three years from now, when a supplier or a customer looks you up, saying that a state agency found something wrong with your prices. That is a cheap fine and an expensive footnote.

The comparison you are not letting people make

Set the law aside for a paragraph, because the commercial case is stronger than the compliance one.

Consider a coffee roaster in Roscommon selling a 250g bag at 9.50. In a supermarket aisle, that bag sits next to a 1kg bag at 26 euro with both unit prices printed underneath, and the shopper can see in a second that one is 38 euro a kilo and the other is 26. Online, on the roaster's own site, there is one number and no context. The customer has a price they cannot place against anything. Some will work it out. Most will half-remember what they paid last time, decide the small bag looks dear, and close the tab.

That is the loss. Not a notice, not a fine. A comparison the customer wanted to make, could not make, and resolved against you by default. Publishing the second price is one of the few compliance jobs that is also a conversion job, because for anyone selling a decent product in a bigger pack, the per-kilo number is the argument.

Putting the second price on your product pages

Four steps, and the whole job is smaller than the reading that got you here.

Audit. Export your product list and mark every line that is pre-packed by weight, volume or measure and over 50g or 50ml. That marked set is your scope. Everything else is either exempt or a question for your solicitor.

Calculate. Work out the price per kilogram, litre or metre from the final price including VAT and every other charge. Wine goes to 75cl, spirits to 70cl, and the Re-turn deposit stays out of the figure.

Automate. Store the pack weight or volume as a product field and have the template calculate the unit price from the live selling price. Do not type the number into the description. WooCommerce ships no unit price field of its own, so this is a plugin or a small template change, and the free Unit Price for WooCommerce plugin in the WordPress directory is one of several that do the arithmetic for you ^[6].

Verify. Open three product pages as a customer and read them. The unit price should be beside the description, legible, and obviously attached to that product rather than floating in a specification tab nobody opens.

The automation step is not tidiness for its own sake. A hand-typed unit price is correct on the day you publish and wrong the first time you run a sale, and a stale unit price is worse than none, because it is a price statement that is now inaccurate. There is a second trap in a discount too. Where you announce a reduction in a unit price, Regulation 5A requires the prior unit price in the announcement itself, which is the same 30-day rule that already applies to sale prices on Irish websites. One calculated field handles both. Two manual ones will not.

Being able to add a field to your own product template is the part people underestimate until they need it. Full WordPress means the change is yours to make in an afternoon, with everything included for 60 euro a year rather than an hourly rate and a wait for somebody else's calendar. On a closed builder, you get the fields the platform decided to give you, and when a rule changes you get to ask politely.

Which brings the honest caveat. If your catalogue is a dozen made-to-measure or one-off pieces, where nothing is priced by quantity and the unit price exemption in Regulation 5(2)(b) covers the lot, a hosted site builder with a fixed product template genuinely does the job and none of this applies to you. Spend the ten minutes confirming that, then go back to work. The rule bites on catalogues with pack sizes, and it bites hardest on the ones with several.

Conclusion

Unit pricing is an old rule that has been quietly waiting for e-commerce. It was written in 2002 with a sentence about distance contracts in it, it is enforced today with a 300 euro notice and a published name, and it is being applied by officers who say they inspect online as well as in store.

The useful thing is that it is a small job with a commercial payoff, which is a rare combination. Export the list, mark the lines that are sold by weight or volume, and let the template do the arithmetic. Then the shopper holding your 250g bag against somebody else's kilo can see exactly what they are choosing between, which is all either of you wanted.

Frequently Asked Questions

Do unit pricing rules apply to online shops in Ireland?

The obligation in Regulation 5(1) of S.I. No. 639 of 2002 applies where a trader indicates that a product is or may be for sale to a consumer, and it is not limited to shops. Regulation 6(1)(c) goes further and says the price indication must appear in proximity to the product or, in the case of a product for sale by distance contract, to the description of the product. An online sale is a distance contract, so the rule points at your product page. Published enforcement under this heading has so far involved physical premises, though the CCPC states that its inspections are carried out in store and online.

How do I calculate the unit price?

Take the final price the customer pays, including VAT and every other tax or charge, and express it per one kilogram, one litre, one metre, one square metre or one cubic metre, depending on how the product is measured. Wine and fortified wine use 75cl and spirits use 70cl. Where the Re-turn deposit applies to a container, the deposit is excluded from the unit price calculation.

Which products are exempt from unit pricing?

The main exemptions are pre-packaged products of 50 grams or 50 millilitres and under, products whose selling price is not related to quantity such as a melon sold by the item or a fixed-price cut of meat, products whose unit price is identical to the selling price, goods reduced because they are damaged or perishing, assortments of different items sold in one package, and vending machine sales. There is also a narrow exemption for premises that do not use shelf edge label printing or point of sale scanning, which was written with very small shops in mind.

What is the penalty for not displaying a unit price in Ireland?

An authorised officer can serve a fixed payment notice, a set fine of 300 euro, because the unit price offence at Regulation 5(5) is listed in section 85(1)(c) of the Consumer Protection Act 2007. On prosecution, Regulation 12(2) now carries a class A fine of up to 5,000 euro following the 2022 amendment, and the court must consider factors including the scale and duration of the breach. The CCPC also publishes the names of traders who receive notices.

Does WooCommerce show a unit price automatically?

No. WooCommerce has no unit price field in core, so the figure has to come from a plugin or a template change that reads the pack weight or volume and divides the live price by it. Several plugins in the WordPress directory do this, including a free one. What matters is that the unit price is calculated rather than typed, so it stays correct when you change a price or run a promotion.

Do I need a unit price on goods I sell loose by weight?

For goods sold in bulk, meaning not pre-packaged and measured in front of the consumer, the CCPC's guidance is that only the unit price is displayed. That maps cleanly onto a deli counter and awkwardly onto a website, where nothing is measured in the customer's presence. If you are listing goods at a price per kilo and shipping an approximate weight, get advice on how the sale is described before you build the checkout around it.

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