In short. A German shop announcing a reduction for goods must generally show its lowest total price in the preceding 30 days under PAngV Section 11.
Definition: As of 17 October 2026, Germany's Price Indication Ordinance (PAngV), Section 11, requires an announced reduction for goods sold to consumers to show the seller's lowest total price in the preceding 30 days. Total price includes VAT and other price components.
Key facts
- PAngV Section 11(2) permits the original reference price throughout an uninterrupted, progressively increasing reduction.
- PAngV Section 2(3) defines total price as the amount payable, including VAT and other price components.
- The European Commission's Article 6a guidance includes earlier promotional prices in the reference period.
- The Court of Justice's Aldi Süd judgment, dated 26 September 2024, requires percentage reductions to be calculated from the prior price.
Which prices enter the calculation?
The Commission guidance, Section 2.1, requires earlier reduced prices within the reference period to count. Where an online shop and physical shops charge different prices, each channel or point of sale uses its own lowest price when covered by a general reduction announcement.
A unit price is the price per unit of measurement, including VAT and other price components, under PAngV Section 2(4). For sellers required to state only a unit price under Section 4(2), Section 11(3) applies the prior-price rules correspondingly.
How must the advertised reduction use that price?
In Case C-330/23, Aldi Süd, paragraph 29, the Court interprets Article 6a(1) and (2) of Directive 98/6/EC to require the prior price as the basis for a percentage reduction or a promotional statement highlighting the announced price advantage.
Paragraph 27 states that a selling price presented as reduced must be below that prior price. Paragraphs 24 to 26 explain that merely displaying the prior price for information while calculating the reduction from another price undermines the rule's purpose.
Can the reference price stay unchanged through successive markdowns?
PAngV Section 11(2) allows the lowest price from the 30-day period before the first reduction to remain the reference throughout progressively increasing reductions. The reductions must increase without interruption.
Which reductions are exempt?
PAngV Section 11(4) exempts individual reductions. It also exempts reductions for rapidly perishable goods or goods with a short shelf life when impending spoilage or expiry causes the markdown and consumers are appropriately informed of that reason.
The Commission guidance, Section 2.3, gives birthday reductions as an example of personal discounts. Codes made available to potentially all online shoppers during a particular period fall within Article 6a's announcement rules.
Related terms
- What prior price must a shop show when announcing a discount?
- When must an online shop display a unit price?
- When must a shop disclose automated personalized pricing?
FAQ
Does every lower price trigger the announcement rule?
The Commission guidance, Section 1.1, excludes price decreases without a reduction announcement. Announcements such as “special offers” that create the impression of a reduction fall within Article 6a.
Can I use the price immediately before the sale?
Under PAngV Section 11(1), you use the lowest price applied in the preceding 30 days, subject to the section's exceptions. The immediately preceding price qualifies when it is that lowest price.
Sources
- Gesetze im Internet, "PAngV Section 11: Zusätzliche Preisangabenpflicht bei Preisermäßigungen für Waren", undated
- Gesetze im Internet, "PAngV Section 2: Begriffsbestimmungen", undated
- European Commission, "Guidance on the interpretation and application of Article 6a of Directive 98/6/EC", 29 December 2021
- Court of Justice of the European Union, "Judgment in Case C-330/23, Aldi Süd", 26 September 2024
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