Businesses must prepare for sales discounts to be put under the spotlight, says CCPC

The Price Indication Regulations set out clear-cut requirements for the use of Black Friday offers

"Engagement phase is now over and sales pricing is an enforcement priority for the CCPC," says CCPC member Kevin O'Brien



4 August 2023

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The Competition and Consumer Protection Commission (CCPC) has told businesses planning their winter sales that they will be watching to ensure sales discounts are genuine and consumers are not misled.

The announcement follows the introduction of new rules last year on price reductions and comes as many businesses plan their Black Friday and end-of-year sales campaigns.

Discount rules

“A discount must be a real discount and the CCPC will not allow businesses to mislead consumers into thinking that they are getting a better deal than they actually are,” said CCPC member Kevin O’Brien.

“The Price Indication Regulations set out clear-cut requirements for the use of discounts. Most announcements such as “sales” prices, “special offers” or “Black Friday offers” that create the impression of a price reduction fall within the scope of the rules,” he added.

By law, when a business makes price reduction announcements, they must display the lowest price a product was on sale for in the previous 30 days, and base the discount on this price alone.

Concerning practices

As the enforcement body for these and other consumer protection laws, the CCPC undertakes market surveillance to inform its future compliance activities. The CCPC undertook an analysis of pricing data from a number of websites of businesses late last year and into early 2023.

“Our analysis has shown a number of concerning pricing practices and demonstrated that a number of traders had not yet changed their practices around price reduction announcements following the introduction of the new rules last year,” O’Brien said.

Some of the issues the CCPC found included:

  • not using the lowest price applied to the product in the previous 30 days before the price of the product was reduced,
  • indicating a previous selling/prior price in a price reduction advertisement which never applied to the product in question,
  • indicating a recommended retail price only and presenting this price as having previously applied to the product in question.

Specific examples of these practices can be found at

Compliance priority

“It is an offence to breach these regulations,” O’Brien continued. “Up until now, the CCPC has been engaging with businesses to inform them of their new obligations. Businesses have been given ample opportunity to get their house in order. This engagement phase is now over and sales pricing is now an enforcement priority for the CCPC.”

“Our market monitoring is ongoing and we will be particularly active in the coming months as we build towards the busiest shopping months of the year. If we find any offers which mislead consumers, we will be engaging with businesses and taking enforcement action where necessary.”

More details about businesses’ obligations under the Price Indication Regulations can be found in the CCPC’s guide at



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