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# What should EU retailers check about reviews and discounts?
- URL: https://conversion.club/playbook/eu-retailer-reviews-discount-price-checks/
- Published: 2026-10-29T09:14:30.000Z
- Updated: 2026-10-29T09:49:55.000Z
- Description: EU-facing retailers should verify reference prices, truthful review claims and supporting records before promotions. Check national implementation and exceptions.
- Author: Jeremie Werner
- Tags: Run your e-commerce, #playbook, Product Page, Shopify

Before an EU-facing promotion, check the reference price behind every discount and the claims made about customer reviews. Keep the supporting records. The Omnibus reforms are European consumer-protection rules implemented through national law, relevant to some non-EU sellers targeting EU consumers as well as businesses based in the region.

## The benchmark

Directive (EU) 2019/2161 amended several consumer directives. The source explains France's implementation through its Consumer Code; an international regional article should begin with the EU framework and then assess each destination's implementation.

| Topic                        | EU-level issue to check                                                                      |
| ---------------------------- | -------------------------------------------------------------------------------------------- |
| Price-reduction announcement | Indicate the applicable prior price under the price-indication framework                     |
| Review information           | Explain whether and how reviews are checked as coming from actual users or purchasers        |
| Authenticity claims          | Take reasonable and proportionate steps before making covered verified-user/purchaser claims |
| False or manipulated reviews | Do not submit, commission or misrepresent reviews to promote products                        |

The general prior-price rule uses the lowest price applied during at least the preceding 30 days. National options and exceptions exist, including certain perishable goods, new arrivals and progressive reductions. Do not assume France's treatment of every loyalty or private-sale arrangement is identical throughout the EU.

In Aldi Süd, C-330/23, the Court of Justice explained that an advertised percentage reduction or promotional price advantage must be determined from that prior price. Showing the correct 30-day low in small print does not justify calculating the main percentage from a higher recent price.

The source also cites the Commission's review sweep, published in January 2022, covering 223 major websites. At least 55% potentially violated the relevant rules. This was an enforcement screening, not a random sample establishing that 55% of every online store breaks the law.

The original article gives a turnover-based penalty summary. Enforcement and penalty conditions depend on the applicable national provisions and infringement type; do not use that compressed figure as a universal maximum fine. See the [price-reference article](https://conversion.club/playbook/what-does-the-law-say-about-strikethrough-prices/) and [review-display guidance](https://conversion.club/playbook/how-many-reviews-do-you-need-and-where-should-you-show-them/) for related operational issues.

## The rule

Audit before the offer goes live and preserve evidence. Give a reviewer other than the campaign builder responsibility for the check. Someone who configured a discount can easily read what they intended rather than what the customer actually sees.

A compare-at field is a display input, not a complete price-history audit. Similarly, manual moderation is not proof that a reviewer purchased the product. Match the label to the evidence, and make the explanation usable on mobile rather than burying it in a legal page.

Apply the audit to product variants, channels and destination markets. A single spreadsheet price for a parent product may miss variant pricing or market-specific histories. A migration must preserve the evidence too.

## The steps

1. Recalculate each advertised reduction. Export products and variants with compare-at prices, obtain the applicable price history and calculate `discount = 1 − promotional price ÷ valid prior price`. If no history exists, begin storing it before the campaign; daily exports may need supplements for intraday changes. Shopify displays entered fields rather than independently proving their legal validity.
2. Include earlier promotions in the relevant window. A public flash sale can affect a separate Black Friday offer three weeks later. The Commission distinguishes genuine personalized benefits from broadly available offers and distinguishes continuous progressive reductions from separate interrupted campaigns. Review the actual mechanics instead of assuming that calling an event “private” excludes it.
3. Read the review disclosure on a phone. Explain the real collection and verification process. A possible factual description is: “We invite customers after ordering and link eligible reviews to their order. We moderate for abuse and irrelevant content.” Use that wording only if it accurately describes the system; disclose other review sources appropriately.
4. Audit verified badges by source: post-purchase invitations, previous-store imports, marketplace imports and manual entries. Keep a badge only when its meaning is substantiated. An in-store customer's unverified feedback may need different presentation and legal review; removing a badge does not cure fabricated or misleading content.
5. Compare reviews received with reviews published over three months, by rating. Document legitimate moderation decisions and investigate missing low ratings. Selectively presenting praise can misrepresent the overall evidence. Anonymized fashion-brand discussions in the source considered hiding ratings below four stars; that setting should not be used to create a misleading impression.

## The pitfall

A baby-products brand described by the contributors discovered that “verified” meant only that the team received a notification and approved a comment manually. That moderated content, but did not verify a purchase. Migration to another application could have copied the unsupported badge unless each source was reviewed.

Export price history and review provenance before a [store redesign](https://conversion.club/playbook/what-should-you-audit-before-a-shopify-redesign/). A cleaner interface does not replace missing evidence for the first promotion on the new platform. Add this review to the [pre-Black Friday checklist](https://conversion.club/playbook/which-site-settings-to-freeze-before-black-friday/).

## What to tell your team

> “In this fictional prelaunch audit, we recalculated 412 discount references and corrected nine. Review-verification information is visible on mobile, and 1,200 imported reviews no longer carry unsupported verified-purchase badges. The evidence is archived, with the next review scheduled before the next major offer.”

## Sources

- [Omnibus Directive, English text](https://eur-lex.europa.eu/legal-content/en/ALL/?uri=CELEX%3A32019L2161&ref=conversion.club)
- [Commission Article 6a guidance](https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=oj%3AJOC%5F2021%5F526%5FR%5F0002&ref=conversion.club)
- [Court of Justice, Aldi Süd](https://curia.europa.eu/jcms/upload/docs/application/pdf/2024-09/cp240152en.pdf?ref=conversion.club)
- [Commission review-sweep record](https://commission.europa.eu/topics/consumers/consumer-rights-and-complaints/enforcement-consumer-protection/sweeps%5Fen?ref=conversion.club)