Claims, prices and reviews that are routine in one market can be unlawful in another. The EU harmonises the core rules, including a 30-day reference price for any advertised reduction, while the UK has given its competition authority direct fining powers of up to 10% of turnover from April 2025. The US relies on the FTC Act and, since 2024, a specific federal rule on fake reviews. Language rules add a further layer in markets such as Saudi Arabia.
Price claims and reductions
In the EU, any announced price reduction must show the prior price, which is the lowest price the trader charged in at least the 30 days before the reduction. Germany implements this in section 11 of its Price Indication Ordinance. A "was" price that was only charged for a few days, or a reference to a recommended retail price presented as the trader's own previous price, risks breaching the rule.
The UK goes further on total price. Under the Digital Markets, Competition and Consumers Act 2024, an invitation to purchase must give the total price including any mandatory fees, taxes and charges, set out with as much prominence as other price information. Hidden booking or service fees added late in the checkout are therefore a misleading omission.123
Reviews, endorsements and enforcement
Both the UK and the US now target fake reviews directly. In the UK, submitting or commissioning a fake consumer review is unfair in all circumstances under Schedule 20 of the 2024 Act. In the US, the FTC's rule at 16 CFR Part 465 prohibits writing, selling or buying reviews that misrepresent whether the reviewer exists or used the product, alongside the general prohibition of unfair or deceptive practices in section 5 of the FTC Act.
Enforcement risk has risen. Since 6 April 2025 the UK's Competition and Markets Authority can itself impose penalties of up to £300,000 or 10% of turnover, whichever is higher, without going to court. In the EU, Member States must allow fines of at least 4% of turnover, or at least EUR 2 million, for widespread cross-border infringements.456789
Language and labelling
Labelling and language rules are often set by product regulation rather than general consumer law. In Saudi Arabia food labels must be in Arabic, and warnings and safety instructions on imported goods must be in Arabic or in Arabic and English, with the country of origin marked indelibly. Similar national language requirements apply in France and elsewhere and should be confirmed for each product category before artwork is finalised.1011
| Market | Rule | Figure | Source |
|---|---|---|---|
| EU | Prior price for announced reductions | Lowest price in at least 30 days | Directive (EU) 2019/2161 |
| EU | Fines for widespread infringements | At least 4% of turnover or EUR 2 million | Directive (EU) 2019/2161 |
| Germany | Price reduction announcements | Lowest total price in last 30 days | PAngV s. 11 |
| United Kingdom | Total price including mandatory fees | Same prominence as other price information | DMCC Act 2024 s. 230 |
| United Kingdom | CMA direct penalties | £300,000 or 10% of turnover if higher | DMCC Act 2024 s. 182 |
| United States (federal) | Fake reviews and testimonials | Prohibited (16 CFR 465.2) | eCFR |
| Saudi Arabia | Warnings and safety instructions | Arabic, or Arabic and English | US Country Commercial Guide |
Decisions to make
- Can the business show the lowest price charged in the 30 days before any advertised reduction in the EU?12The prior price must be that 30-day lowest price.
- Does the UK checkout show the full price, including mandatory fees, from the first price display?37Omitting mandatory charges from the total price is a misleading omission under the 2024 Act.
- How are customer reviews collected, incentivised and moderated?45Fake or bought reviews are banned outright in the UK and under the FTC rule in the US.
- Which labelling languages are mandatory for each product and market?1110Saudi rules require Arabic for food labels and safety information.
Documents usually needed
- Price history records supporting any reference or "was" price
- Substantiation file for objective advertising claims
- Review collection and moderation policy, including incentives offered
- Label artwork approved for each market's language requirements
- Checkout screenshots showing how total price and fees are displayed
Common mistakes
- Using a recommended retail price or a short-lived higher price as the reference for an EU discount
- Adding mandatory booking or service fees only at the end of a UK checkout
- Paying for or filtering reviews in ways that misrepresent customer experience
- Assuming UK consumer enforcement still needs a court order before a penalty
- Finalising packaging before confirming Arabic or local-language requirements
Questions businesses ask
What price can be shown as the "before" price in an EU sale?
The lowest price the trader applied during at least the 30 days before the reduction.12
How large can UK consumer law penalties now be?
Under its direct enforcement powers the CMA can impose up to £300,000 or 10% of total turnover, whichever is higher.8
What this guide does not yet confirm
These points need checking with a qualified local professional before you rely on them.
- France's language law (Loi no. 94-665, the Toubon law) could not yet be checked on Legifrance, so French-language advertising and labelling rules are not stated as claims.
- India's Consumer Protection Act 2019, CCPA misleading-advertisement guidelines and dark-pattern guidelines could not yet be checked.
- UAE federal consumer protection law and Singapore's Consumer Protection (Fair Trading) Act were not researched.
- US state consumer protection and price-advertising laws, and the effective date of the FTC review rule, were not confirmed.
- Sector rules on advertising (financial services, health, food, alcohol) are outside this module.
Sources and review status
Each statement is numbered to the source it was checked against. We use official sources where we can, and each statement says whether it was checked against an official or a secondary source. Sources last checked on 19 October 2026. None of it has been professionally reviewed yet: it is research checked against official and secondary sources by WONE Global, not legal or tax advice.
In the EU, any announcement of a price reduction must state the prior price, which is the lowest price the trader applied during a period of not less than 30 days before the reduction. EU Member States; Article 6a of Directive 98/6/EC as inserted by Directive (EU) 2019/2161. Member States may set limited derogations (for example for perishable goods or new products) not reviewed here.
In Germany, a trader announcing a price reduction must state the lowest total price it charged consumers in the 30 days before the reduction. Federal; section 11(1) of the Price Indication Ordinance (PAngV), implementing the EU rule.
Under the UK Act, an invitation to purchase omits material information if it does not give the total price, which includes any fees, taxes, charges or other payments the consumer must pay, set out with as much prominence as any other price information. United Kingdom; section 230. Where a price cannot reasonably be calculated in advance, the way it is calculated must be given, along with delivery or postal charges not included in the total.
Submitting or commissioning a fake consumer review, meaning one that purports to be but is not based on a person's genuine experience, is a commercial practice considered unfair in all circumstances in the UK. United Kingdom; Schedule 20, paragraph 13 of the 2024 Act.
The FTC's rule on consumer reviews and testimonials prohibits businesses from writing, creating or selling reviews or testimonials that materially misrepresent whether the reviewer exists or used the product, and from buying or disseminating such reviews when they knew or should have known. Federal; 16 CFR 465.2 (published at 89 FR 68077, 22 August 2024). Hosting reviews and general solicitations to purchasers are carved out for some limbs.
The effective date was not stated on the page read.
US federal law declares unfair or deceptive acts or practices in or affecting commerce unlawful. Federal; section 5(a)(1) of the Federal Trade Commission Act, 15 U.S.C. 45(a)(1), enforced by the FTC. State consumer protection statutes apply in addition.
US Code text reproduced by Cornell LII; the official version is at uscode.house.gov, which could not yet be checked.
Unfair commercial practices are prohibited under the Digital Markets, Competition and Consumers Act 2024, with the prohibition in force from 6 April 2025. United Kingdom; section 225, brought into force by S.I. 2025/272. Misleading actions, misleading omissions and aggressive practices are defined in sections 226 to 228.
A final infringement notice issued by the CMA under its direct consumer enforcement powers may require a monetary penalty of up to £300,000 or, if higher, 10% of the respondent's total turnover. United Kingdom; section 182(6) of the 2024 Act. Separate caps apply to breaches of undertakings and directions.
For widespread consumer law infringements with an EU dimension, Member States must make the maximum fine at least 4% of the trader's annual turnover in the Member States concerned, or at least EUR 2 million where turnover information is not available. Coordinated actions under the Consumer Protection Cooperation Regulation; applies under the Unfair Commercial Practices Directive (Article 13 as amended) and the Unfair Contract Terms Directive (Article 8b).
Food labels and accompanying information must be in Arabic, and imported meat and poultry need a health certificate from the competent authority of the exporting country and, for unprocessed meat and poultry, a halal slaughter certificate. Food for manufacturing or restaurant use may be labelled in English with a commitment submitted via FASAH.
The country of origin must be marked on all imported goods, in Arabic or English, in a way that cannot be removed, and warnings and safety instructions must be in Arabic or in Arabic and English. Imported goods generally; food and cosmetics have additional SFDA labelling rules.
Secondary (foreign government) source; SASO's labelling technical regulations could not yet be checked.
Questions on this topic
11 statements on consumer protection and advertising rules
