Introduction

The presentation of prices for product sets and information about promotions in an online store must comply with the provisions of the Omnibus Directive and national regulations on price information - otherwise the seller exposes himself to accusations of unfair practices.

Growing competition in e-commerce is causing sellers to increasingly offer attractive product bundles or promotional packages. However, the proper presentation of such offers in terms of pricing and information requires careful analysis – both in terms of the Omnibus Directive and national regulations on pricing and promotions.

Case description

The retailer implemented product bundle sales, which were presented in the online store, including the bundle price and the prices of individual products. However, there was no analysis of whether to display the lowest price from the 30 days prior to the discount (the so-called omnibus price) and how to properly present a price comparison between bundles and non-bundles. The way sales were presented on the receipt and in the sales systems was ambiguous, potentially misleading customers and violating regulations regarding the communication of promotions.

Solution method

We analyzed sales models and applicable legal regulations, including the Omnibus Directive and national regulations on the display of product prices. We determined that if a bundle functions as a single product (with its own code and receipt item), it is safe to display both bundle prices without the obligation to use the bundle omnibus price. However, if the offer includes two separate products (combined only in a conditional promotion), it is necessary to display the omnibus price for each product and to limit such a promotion to a specific time period to avoid being considered misleading to consumers ("open-ended promotion").

We updated sales documentation, developed guidelines for price presentation in the store and on receipts, and trained the team on new rules for communicating promotions and bundles.

Effects

The implemented changes allowed the retailer to legally conduct promotional campaigns involving product sets. Consumers received clear and transparent information about the promotion rules and prices, minimizing the risk of interpretational uncertainties and potential regulatory interventions. The company could continue selling the sets safely – as a new product or a temporary promotion, while adhering to all formal requirements.

Summary

Every promotional campaign using product bundles must be based on a thorough analysis of the regulations regarding price and promotion disclosure. The sales model (bundle as a product or conditional promotion) determines the seller's obligations regarding price disclosure and the use of omnibus pricing. Proper implementation of these rules not only protects against allegations of legal violations but also builds transparency and customer trust in the store.