Price Indication Ordinance (PAngV)

Basics and objectives

Since its amendment in May 2022, the Price Indication Ordinance has formed the central legal framework for price indications to consumers in Germany. The primary aim of the law is to ensure price truth and clarity in retail. The regulation obliges companies to display prices transparently and in full, including all price components. The regulations apply to all goods and services offered to end consumers. The PAngV creates uniform standards for price labeling in stationary and online retail. The regulation strengthens the position of consumers by improving their ability to compare prices. The regulations concern both the indication of final prices and basic prices. The regulations apply to all traders who offer goods or services. Compliance is monitored by the competition authorities. The sanctions for infringements can include substantial fines. The regulation has been adapted to current market developments. The digital transformation of trade has been taken into account.

Price disclosure obligations and basic prices

The Price Indication Ordinance stipulates that all prices must include VAT and all price components. The mere indication of net prices to consumers is not permitted, even with the addition “plus VAT”. Since the amendment, basic prices must always be indicated for 1 kilogram or 1 liter. The previous exception for goods under 250 grams or milliliters has been removed. The basic price must be unambiguous, clearly recognizable and easy to read. The prices must be clearly attributable to the product. Online stores must also clearly indicate the shipping costs. The price information must be visible at a glance. The use of hidden additional costs is not permitted. The basic price obligation applies to almost all goods according to weight, length or volume. The exceptions are regulated conclusively in the law. Price transparency is intended to promote competition.

New regulations on price reductions

The 2022 amendment introduced new obligations when advertising price reductions. Companies must state the lowest price of the last 30 days as a reference for price reductions. This regulation applies to all types of price reductions and discounts. The obligation to provide information already begins when the impression of a discount is created. The only exceptions are personal discounts and food with a short shelf life. The regulation is intended to enable consumers to better assess offers. The transparency of special offers will be significantly increased. Manipulation through artificially high starting prices will be prevented. Documentation of price history will become mandatory. The comparability of offers will be improved. The regulation also applies to online stores. Price transparency will be strengthened. Advertising with bogus discounts will be prohibited.

Special regulations for online trading

Online retailers must make all price components transparent from the outset. The shipping costs must already be visible on the product page. The basic price must be displayed without additional links or mouse-overs. The price display must be easy to read on all end devices. The price information must remain consistent throughout the entire ordering process. The additional costs must be clearly shown before the order is completed. The price information must also be displayed correctly in the mobile version. The use of dynamic prices must be transparent. The price history must be documented. The basic prices must also be calculated correctly for variants. The technical implementation must be legally compliant. Checks are also carried out by means of mystery shopping.

Supervision and sanctions

Compliance with the Price Indication Ordinance is monitored by various authorities. Violations can be punished with fines of up to 25,000 euros. The Wettbewerbszentrale can issue warnings and file injunctions. The documentation requirements enable effective monitoring. The sanctions have both a preventive and repressive effect. The authorities can carry out inspections and test purchases. International cooperation has been strengthened. Enforcement also takes place across borders. The limitation periods have been adjusted. Case law continues to develop the standards. Sanctions can also affect managing directors personally. The compliance requirements have been increased.

Practical implementation

The implementation of the PAngV requires systematic pricing processes. The technical systems must guarantee correct price calculations. The price history must be fully documented. Employees must receive regular training. The processes must be checked regularly. Price labeling must be checked daily. The basic price calculation must be automated. Discount campaigns must be designed to be legally compliant. Price communication must be standardized. The systems must automatically detect errors. Compliance must be ensured on a permanent basis. The processes must be documented.

Future prospects

Digitalization will continue to change pricing. Dynamic pricing requires new regulations. International harmonization will progress. Consumer protection standards will continue to rise. Technical developments will enable new forms of price display. Transparency requirements will increase. Control will be improved by digital tools. Price comparability will be further optimized. Case law will develop new standards. Compliance requirements will increase. The importance of price transparency will increase. The integration of new technologies will progress.