The Amazon EU reference price is the crossed-out or comparison price shown next to your offer, and on EU stores it is lawful only when any discount you announce is measured against the lowest price you charged in the 30 days before the cut. That 30-day test comes from Article 6a of the Price Indication Directive 98/6/EC, inserted by the Omnibus Directive (EU) 2019/2161 and applied in every Member State from 28 May 2022. Amazon layers its own rules on top. Its EU reference price policy limits the recommended retail price to a price applied outside short-term discounts, computes the Was Price itself from historic prices paid, and states a 30 calendar day maximum for discounts on some European stores. The Marketplace Fair Pricing Policy then decides whether you keep the Featured Offer, the offer or the account.

How the Amazon EU Reference Price Rule Differs From the US

Sellers who learned discounting on Amazon.com often carry US habits into Amazon.de, Amazon.fr, Amazon.it, Amazon.es, Amazon.nl and the other EU stores. Both regions punish fake savings. Only the EU writes a fixed number of days into the law.

The US approach

On the US store, the Amazon policy on reference prices says a List Price must represent a price at which you, or other retailers or sellers, have recently made or intend to make substantial sales. The same page tells sellers with several listings of one product to keep the List Price consistent across all of them, and it lets you enter a value of 0 when you have no List Price. The legal backdrop is general. Section 5 of the FTC Act, 15 U.S.C. 45, bans deceptive practices in commerce. The FTC’s Guides Against Deceptive Pricing, 16 C.F.R. Part 233, say in section 233.1 that a former price supports a comparison only when it was the actual, bona fide price offered to the public on a regular basis for a reasonably substantial period. Federal law sets no day count.

The EU approach

The EU sets the number. Article 6a(1) requires any announcement of a price reduction to indicate the prior price. Article 6a(2) defines the prior price as the lowest price the trader applied during a period of not less than 30 days before the reduction. Directive (EU) 2019/2161 required Member States to adopt their national measures by 28 November 2021 and apply them from 28 May 2022. Each Member State enforces the rule through its own transposing law, so the German, French, Italian and Spanish texts can differ on the optional paragraphs.

Penalties are national too. The amended Article 8 of Directive 98/6/EC requires penalties that are effective, proportionate and dissuasive. Authorities must weigh the nature, gravity, scale and duration of the breach, any steps the trader took to remedy it, and any previous infringements. Under the parallel penalty article of the Unfair Commercial Practices Directive, a coordinated cross-border action under Regulation (EU) 2017/2394 can carry a maximum fine of at least 4% of the trader’s annual turnover in the Member States concerned.

Point	US store	EU stores
Amazon reference price field	List Price, tied to recent or intended substantial sales	Recommended retail price, tied to prices applied outside short-term discounts
No supportable figure	Enter 0	Leave the field blank (German page) or enter 0 (UK page)
Legal test for a discount	Bona fide former price over a reasonably substantial period, 16 C.F.R. 233.1	Lowest price in at least the 30 days before the reduction, Article 6a(2)
Who carries the duty	The seller advertising the price	The seller, including sellers on online marketplaces and non-EU sellers targeting EU consumers
Discount duration	No maximum stated by Amazon	Amazon states a 30 calendar day maximum on some European stores
Rights after an Amazon action	Amazon’s internal process	DSA statement of reasons, a 6-month complaint window and certified out-of-court settlement

Why sellers get caught

The usual trigger is a brand that enters a recommended retail price nobody charges, or lifts its price for a week before a promotion, then runs a large strike-through saving. On Amazon.com that pattern already risks the misleading reference price clause. On an EU store it can also breach the national law implementing Article 6a, because the saving is measured from a price that was never the 30-day low. German sellers call the crossed-out price the Streichpreis, and the leading court ruling on how to calculate it came from a German consumer association’s claim against a supermarket chain.

The 30-Day Prior Lowest Price Rule

Article 6a has five paragraphs. Each one changes how you plan a promotion calendar.

What the five paragraphs say

Paragraph 1 requires every announced price reduction to show the prior price the trader applied for a set period before the reduction.
Paragraph 2 fixes that period at not less than 30 days and defines the prior price as the lowest price applied in it.
Paragraph 3 lets Member States set different rules for goods liable to deteriorate or expire rapidly.
Paragraph 4 lets Member States allow a shorter period for a product on the market for less than 30 days.
Paragraph 5 lets Member States treat a progressively increased reduction as one campaign, with the prior price taken from before the first cut.

What counts as a price reduction announcement

The European Commission published its guidance on Article 6a in the Official Journal on 29 December 2021 as notice 2021/C 526/02. Its examples include “20 % off,” “EUR 10 off,” a new price shown beside a crossed-out older price, and a current price presented as a starting price ahead of a higher upcoming one. A general banner such as “20 % off on everything today” is also covered, with the prior price shown on each price display. Discount codes available to potentially all consumers fall inside the rule, and the prior price is then the lowest publicly available price in the last 30 days.

Some claims fall outside Article 6a. The guidance lists comparisons with other traders’ prices or with the manufacturer’s recommended retail price, multi-buy offers such as buy one get two, long-term loyalty schemes, and personalised vouchers that were never announced. Those claims stay fully subject to the Unfair Commercial Practices Directive 2005/29/EC. Article 6(1)(d) of that Directive treats deception about the price, the way it is calculated, or the existence of a specific price advantage as a misleading action. A recommended retail price comparison on Amazon can therefore escape Article 6a and still be unlawful.

Earlier promotions count toward the low

The Commission’s guidance states that the lowest price includes any previous reduced price during the 30-day window. A seller who ran a flash deal at EUR 24 two weeks ago cannot ignore it and quote a higher regular price as the prior price. The guidance also treats successive campaigns, such as a discount every Sunday in December, as separate reductions. Each one needs its own 30-day lookback that includes the earlier Sundays.

A reduction may run longer than 30 days. The prior price stays the lowest price in the 30 days before the reduction began, and an extension must be presented to consumers as an extension. Excessively long reduction periods are assessed under the Unfair Commercial Practices Directive.

Who the rule applies to on a marketplace

The guidance places the duty on the trader who is the party to the sales contract. Sellers who use online marketplaces are named. Intermediaries that only provide the means for traders to sell are outside the rule, unless they are the actual seller or sell on behalf of another trader. Traders based outside the EU who direct sales to EU consumers are covered as well. For a third-party seller on Amazon.de or Amazon.fr, the prior price duty for your own announced discounts sits with you, whether you ship from Leipzig, Shenzhen or Los Angeles.

How the discount must be calculated

In Case C-330/23, Verbraucherzentrale Baden-Württemberg eV v Aldi Süd Dienstleistungs SE & Co. OHG, the Court of Justice ruled on 26 September 2024 that a reduction announced as a percentage, or through a promotional statement about the price advantage, must be determined on the basis of the prior price under Article 6a(2). Showing the 30-day low in small print while computing the headline percentage from a higher figure does not comply.

The Commission explains the purpose of the 30-day window. It stops traders from raising a price for a short time and then presenting the cut as a significant reduction. Amazon’s Fair Pricing Policy names the same pattern a misleading reference price.

Walk through the composite EU example period by period and see which price becomes the prior price and why a discount from the higher one overstates the saving.

A worked example

Take a composite product on Amazon.de. Over the last 30 days it sold at EUR 39 for 21 days and at EUR 34 for 7 days during a short promotion. For the remaining 2 days it was out of stock. The seller now wants a deal at EUR 29. The prior price is EUR 34, the lowest price applied in the window. A strike-through of EUR 39 overstates the saving. The correct headline is about 15% off EUR 34, not about 26% off EUR 39. If the product launched 12 days ago and the destination country uses the paragraph 4 option, the national rule may allow a shorter lookback, so check it country by country.

Promotion tools carry the same risk. Our guide to Amazon coupons for sellers covers coupon setup, and our note on Lightning Deals before Black Friday and Cyber Monday covers the event calendar where 30-day lookbacks collide most often. Pricing rules sit beside product rules on EU stores, which is why our checks on FBA prohibited products before you ship and releasing FBA inventory flagged as unsuitable belong in the same pre-launch routine.

A strike-through that has already drawn a warning on Amazon.de or Amazon.fr is a listing problem first. Our listing recovery desk reviews the price history and the notice before any reply goes to Amazon.

How Reference Prices Show on EU Storefronts

Amazon’s policy on reference prices for the German store has three parts, the recommended retail price, the Was Price and the duration of discounts. The UK version of the same page uses close wording with two differences worth knowing. Read the version for each store you sell in.

Recommended retail price

In many categories you can enter a recommended retail price or a manufacturer’s suggested retail price. Amazon may show it on detail pages and in search results to show savings and for price comparison. The German page requires that figure to represent the price applied by you or other retailers or sellers outside of short-term discounts. You must keep it current. If you have no figure that meets the test, the German page tells you to leave the field blank when adding a new product, while the UK page tells you to enter 0. Amazon may ignore a figure it cannot verify, and it reserves the right to stop displaying a recommended retail price or savings message it considers misleading.

Was Price

The German page says a Was Price may display on detail pages and in search results, and that Amazon determines it from historic prices paid by customers on the Amazon store, excluding promotional prices from limited-time promotions. The UK page adds the deals page as a display location. No Seller Central field lets you type a Was Price. Amazon computes it. You influence it only through the prices you charge, which become the history Amazon reads.

Duration of discounts

Both pages say discounts must respect any legal minimum and maximum durations. The German page states that some European stores apply a maximum of 30 calendar days, and the UK page says the same for some EU stores. Amazon also asks for intervals between discounts. A permanent sale price that runs for months fails twice. It can exceed the duration Amazon applies, and once 30 days pass the sale price becomes your new prior price, so the advertised saving disappears in law.

What Amazon does not publish

Amazon’s public help pages do not say how EU stores calculate or label a 30-day prior lowest price beside a deal, or whether that figure comes from your own offer history or the product’s history across all offers. Treat any prior price Amazon shows as Amazon’s display. Your own records must still prove the lowest price you applied in the 30 days before every discount you announced.

Amazon EU requirements checklist for Amazon EU reference pricing

The recommended retail price reflects prices applied outside short-term discounts, or the field is blank on Amazon.de and 0 on Amazon.co.uk.
Every announced discount is calculated from the lowest price you applied in at least the 30 days before it, flash deals included.
No price was lifted in the weeks before a promotion to widen the saving.
Each promotion stays within the 30 calendar day maximum Amazon applies on that store, with a gap before the next one.
Coupon codes open to all shoppers are measured against the lowest public price in the last 30 days.
Per-unit prices for larger packs are not higher than for smaller packs.
Shipping charges follow public carrier rates for weight, dimensions, speed and distance.
National options for new products and perishables have been checked for each destination country.

How a Pricing Problem Shows Up on an EU Store

Most sellers learn about a reference price problem from Amazon, not from a regulator. The signs arrive in a fixed order, and catching the first one saves the account.

A Pricing Health alert. Amazon’s German page on maintaining customer trust with competitive prices says sellers are notified on the Pricing Health page when an offer is ineligible for the Featured Offer because of a significantly high price.
A missing savings badge. The strike-through stops displaying because Amazon could not verify the recommended retail price or judged the savings message misleading.
A lost Featured Offer. The Buy Now button moves to another seller or disappears when recent prices show your offer sits well above the typical price.
A policy warning email. A message citing the Marketplace Fair Pricing Policy, often with an option to resubmit the listing after fixing the price.
An account-level action. Selling privileges suspended after repeated cases, delivered on EU stores with a statement of reasons under the Digital Services Act.

Subscribed sellers can also receive the pricing notifications by email and API, according to the same German page. Route those messages to whoever owns pricing, not a shared inbox nobody reads.

Price Histories to Keep for Each Market

The prevention rule for EU sellers is to store 30-day price histories for each EU marketplace and set every reference price from that data. Amazon builds its own figures from its own data. Your records prove, store by store, that the discount you announced was genuine.

What to record

Daily price per SKU per store, including the shipping charge, with the date and time of every change.
Who or what changed it. The repricer rule, the promotion tool or the named person.
Promotion records. Start and end dates, the advertised saving, and the prior price used to compute it.
Recommended retail price source. Where the figure comes from and proof that it reflects prices applied outside short-term discounts.
Launch dates. Products on the market under 30 days, where national law may allow a shorter lookback.
Amazon messages. Pricing Health alerts, warning emails and any statement of reasons, filed against the SKU.

How long to keep it

Keep at least the full 30-day window before every promotion, and far longer in practice, because complaints and enforcement often arrive months after a deal ended. Our standing advice is a rolling 12 months of daily prices per store, exported weekly from your own systems instead of relying on one third-party tool that may change its retention.

One market at a time

Prices differ by store, and so do the national options under Article 6a. A discount that is lawful on Amazon.it can mislead on Amazon.es if the prior prices differed. Run the 30-day check separately for each EU store, in that store’s currency. A store that lists outside the euro needs the lookback in its own currency, because converted figures move with the exchange rate and can hide the true low.

Each station is a source of price changes that has to be recorded for every EU store. Tap one to see what it changes and the record it needs.

How each business model applies it

Brands entering a recommended retail price should set it only to a price applied outside short-term discounts and revisit it whenever the normal price moves. With no such price, leave the field blank on Amazon.de as the German page instructs.

Resellers running repricers across EU stores need a ceiling per store. A repricer that climbs during a competitor stockout and then falls back creates a fake reduction on the way down. Our Amazon repricer guide covers how min and max rules interact.

Merchant-fulfilled sellers shipping cross-border should build shipping charges from carrier rates for each destination. The German Fair Pricing Policy measures shipping against public carrier rates for package weight, dimension, speed of delivery and distance.

Wholesale and private label sellers selling multipacks should check per-unit maths before launch. The German policy gives its own example of a breach, a 10-pack of shampoo at EUR 50, or EUR 5 per unit, beside a 5-pack at EUR 10, or EUR 2 per unit.

A monthly prevention routine

Export 30 days of daily prices, shipping included, for every SKU on every EU store you sell in.
Compare each recommended retail price with the prices applied outside short-term discounts, and clear any you cannot support.
List every promotion planned for the next 30 days and compute its saving from the lowest price in its own lookback window.
Check that no promotion will exceed 30 calendar days and that a gap exists before the next one.
Review repricer ceilings and floors per store, and record who approved each change.
Open Pricing Health and clear every alert, then file the alert and the fix with the SKU’s price history.

Fair Pricing Enforcement That Still Applies

National consumer authorities enforce Article 6a. Amazon enforces its own policy separately, and Amazon’s decision is the one that touches your offers and account first.

The German Fair Pricing Policy

The Marketplace Fair Pricing Policy on the German store says Amazon uses statistical models fed by objective data, including historical offer prices, prices from other retailers and sales data, to detect significantly high or erroneous prices. Sellers agree that Amazon may remove the Featured Offer or the offer, suspend a shipping option, or in repeated cases suspend or terminate selling privileges. The named practices are prices that are misleading, fraudulent or unfair in violation of applicable laws, with German book fixed price laws as the example, higher per-unit prices for larger packs, excessive shipping fees, and prices significantly above recent prices online or in physical stores.

Read the first practice twice. On Amazon.de, a price that breaks applicable law is itself a Fair Pricing breach. A discount announced against a prior price that fails the national Article 6a rule can become an Amazon policy case as well as a legal one.

The UK and US wording

The UK Fair Pricing Policy and the US Fair Pricing Policy name four practices. They are a reference price that misleads customers, a price significantly higher than recent prices on or off Amazon, a multi-unit offer priced higher per unit than a single unit, and an excessive shipping fee. Both say Amazon weighs current public carrier rates, reasonable handling charges and buyer perception when judging shipping. The US page lists removing the Featured Offer, removing the offer, suspending the ship option, and in serious or repeated cases suspending or terminating selling privileges. The UK page speaks of removing the Buy Box.

First time compared with repeat cases

Enforcement escalates. A first flag usually lands at offer level, as a lost Featured Offer, a hidden savings badge or a removed offer with an option to resubmit. The German page offers that resubmission route once the issue is fixed. Repeat cases move to the account. Every version of the policy reserves suspension or termination of selling privileges for repeated cases, and the US and UK pages add serious ones. Our guide to repeated pricing violations and suspension covers the account-level appeal.

How to respond to a pricing notice

Pull the notice and identify the SKU, the store and the practice Amazon cites.
Export that SKU’s 30-day price history for the affected store, shipping included.
Find the mechanism. It is usually a repricer rule, a promotion setting, a recommended retail price entry or a shipping template.
Correct the price or clear the recommended retail price, then fix the rule that produced it.
Audit every other SKU and every other EU store for the same mechanism.
Resubmit the listing where Amazon offers it, or contact Selling Partner Support to dispute the determination.
For an account-level action, write a plan that names root cause, corrective steps and preventive controls, and attach the price history and the corrected configuration.

Our method on EU stores matches the one we use on Amazon.com. Name the SKU, the store and the mechanism. Show the corrected price, the catalog audit and a written pricing procedure with reference price review and a per-store change log. The parent article on the Amazon Fair Pricing Policy warning walks through that appeal, and the companion piece on a Featured Offer removed for pricing covers the offer-level fix.

Your rights under the Digital Services Act

When Amazon restricts an offer or account on an EU store, the Digital Services Act, Regulation (EU) 2022/2065, requires a clear and specific statement of reasons under Article 17. Article 20 gives you an internal complaint-handling system, free of charge, for at least 6 months after the decision. Article 21 lets you take the dispute to a certified out-of-court settlement body. File the statement of reasons with your price records, because it names the exact practice you must answer. Our guides to reading an EU statement of reasons and DSA complaints and mediation cover both routes in detail.

Where the Amazon EU notice and appeal path differ from the US

Policy wording. The German policy names law-breaking prices and pack-size pricing and describes statistical models. The US version names misleading reference prices, recent prices, multi-unit pricing and shipping.
Reference price field. A recommended retail price outside short-term discounts on EU stores, against recent or intended substantial sales for the US List Price.
Discount length. Promotions on Amazon.de and several sister stores stop at a month, while Amazon.com publishes no cap.
Complaint route. EU sellers hold DSA rights to reasons, internal complaints and out-of-court settlement on top of Selling Partner Support.
Legal exposure. National consumer authorities in each Member State enforce Article 6a and the Unfair Commercial Practices Directive.

The United Kingdom Is a Separate Case

Article 6a began to apply on 28 May 2022, after the UK had left the EU, so the EU 30-day prior price rule does not bind Amazon.co.uk as EU law. UK sellers answer to UK pricing law instead. Under the Digital Markets, Competition and Consumers Act 2024, section 226, a commercial practice is a misleading action if it gives false or misleading information about a product, or an overall presentation likely to deceive the average consumer, even when each individual statement is true. A fake saving fits that description. Amazon’s UK reference price page applies the same short-term discount test as the German page, and the UK Fair Pricing Policy names the same four practices as the US version.

The Digital Services Act does not apply in the UK either. UK sellers rely on the retained Platform-to-Business Regulation 2019/1150, Article 4. It requires reasons on a durable medium when a listing is restricted or suspended, and at least 30 days’ notice before a full termination. The notice period falls away where a legal obligation applies, where Amazon exercises termination for an imperative reason, or where the seller has repeatedly breached the terms. That last exception is why repeated pricing flags carry more risk in the UK than a single one. Our article on P2B termination notice periods sets out the timing. Treat this section as general information and take advice on your own facts.

Frequently Asked Questions

What is the Omnibus 30-day rule?

It is the EU requirement that any announced price reduction shows the lowest price the seller applied in at least the 30 days before the reduction. The rule sits in Article 6a of Directive 98/6/EC, was inserted by Directive (EU) 2019/2161, and has applied since 28 May 2022.

Does the Omnibus rule apply to Amazon sellers?

Yes, it applies to every trader selling to EU consumers, so discounts you announce on EU stores must follow it. The Commission’s guidance names sellers using online marketplaces and sellers outside the EU who target EU consumers.

Can Amazon remove my offer for a fake discount?

Yes, a misleading reference price is a Fair Pricing breach. On the German store the policy also covers prices that break applicable law, and Amazon can remove the Featured Offer or the offer, suspend a shipping option, or in repeated cases suspend or terminate selling privileges.

Do I need price history records?

Yes, a 30-day price history per market is the only proof that a discount you displayed was real. Amazon computes its own Was Price from its own data, and it will not share that data to defend your claim.

Can I set the Was Price on Amazon Europe?

No, Amazon computes the Was Price from historic prices paid on the store, excluding limited-time promotional prices. You control only the recommended retail price field and the prices you charge.

How long can a discount run on Amazon.de?

Amazon’s German reference price page says some European stores apply a maximum of 30 calendar days and asks for intervals between discounts. After 30 days at the reduced price, that price also becomes the new prior price under Article 6a.

Is the UK rule the same?

No, the UK is outside the EU, so the Article 6a 30-day rule does not apply there as EU law. Misleading price claims fall under section 226 of the Digital Markets, Competition and Consumers Act 2024, and Amazon’s UK reference price and Fair Pricing policies apply on Amazon.co.uk.

Get Help With Amazon EU Reference Pricing

Clean per-store price records and a recommended retail price you can support prevent most EU pricing flags. When a warning has already escalated to account level, the appeal must show a pricing control system that holds across every store. Our team designs and documents that system with you.

Start with our listing recovery service for offer-level removals, or our Amazon suspension and reinstatement service if selling privileges are already affected. You can submit your case for a free assessment or book a consultation to review an EU promotion calendar before it goes live. Pricing rarely fails alone, so we also check product compliance documents, restricted product listings and category and brand ungating during the same review.

Sellers on other marketplaces can browse the full range of marketplace reinstatement services by platform.

Amazon EU Reference Prices and the Omnibus Discount Rule