TL;DR
- German law requires every Black Friday discount to show the lowest price of the previous 30 days next to the sale price (PAngV §11, since 2022)
- The 2024 BGH ruling (I ZR 80/23) extends this to "up to X% off" banners — the reference price must sit next to the headline, not in a footnote
- Crossing out a price you never genuinely charged is a Mondpreis and counts as misleading advertising under §5 UWG
- An Abmahnung costs 5,000-15,000 € in Streitwert plus fees; fines reach 50,000 €; marketplaces remove non-compliant listings during peak traffic
- Black Friday 2026 is 27 November, so the 30-day reference window reaches back to late October — plan warm-up sales accordingly
Every Black Friday discount shown to German consumers must display the lowest price of the previous 30 days next to the sale price. Leave it out and you hand a competitor the cheapest Abmahnung of the year. This guide covers what the law requires, the 2024 court ruling that tightened the rules, and how to run a Black Week sale that holds up.
What German law requires for Black Friday discounts
Section 11 of the Price Indication Ordinance (PAngV) has applied since 28 May 2022. When you announce a price reduction to consumers, you must state the lowest total price you charged for that product in the 30 days before the reduction. The reference price is your own previous low, not the manufacturer's recommended price.
A worked example for Black Week:
- 1 November: the jacket sells for 199 €.
- 10 November: you drop it to 169 € for a mid-month push.
- 27 November: Black Friday price is 139 €.
The correct label is "139 €, lowest price in the last 30 days: 169 €". Writing "139 € instead of 199 €" is wrong, because 199 € was not the 30-day low.
The 2024 BGH ruling that tightened "up to 50% off"
On 6 June 2024 the German Federal Court of Justice ruled (case I ZR 80/23) that headline claims like "up to 50% off" must reference the 30-day low, and the reference price has to sit next to the advertised price, not buried in a footnote. A banner that screams a percentage without the 30-day figure is non-compliant even when the individual product page later shows the correct number.
For Black Friday this matters because the discount lives in three places at once: the homepage banner, the collection page, and the product page. All three count as advertising.
Streichpreise: what a crossed-out price may reference
A crossed-out price is legal, but you have to make clear what it refers to. The safe references and the risky ones:
| Reference | Status | Condition |
|---|---|---|
| Your own 30-day lowest price | Required for reductions | Must be the genuine low, with the label next to the sale price |
| Manufacturer UVP | Allowed, higher risk | Must match the current manufacturer list; outdated UVPs draw warnings |
| A price you never seriously charged | Illegal | This is a Mondpreis (dummy price) and counts as misleading under §5 UWG |
The Mondpreis is the classic trap. If you lift a price for a few days only to cross it out on Black Friday, the comparison is misleading and anticompetitive. Courts look at whether the original price was charged for a sufficient period, judged per product and market.
What an Abmahnung actually costs
Three consequences are documented across German e-commerce, and all three spike during Black Week:
| Consequence | Who triggers it | Typical cost |
|---|---|---|
| Competitor warning (Abmahnung) | Competitors, Wettbewerbszentrale, consumer associations | Streitwert 5,000-15,000 € plus legal fees |
| Administrative fine | State supervisory authority, usually after a tip-off | Up to 50,000 € per violation |
| Listing removal | Amazon, Google Shopping, TikTok Shop | A lost selling day during the highest-traffic window of the year |
Black Friday 2026: the dates that set your 30-day window
Black Friday 2026 falls on 27 November. Black Week runs 20 to 27 November, and Cyber Monday lands on 30 November. The practical consequence: your 30-day reference window reaches back to late October. Any price you set in that window becomes the low you must reference. Plan promotions backward from this date so a mid-November "warm-up" sale does not lock you into an awkward reference price on Black Friday.
Compliance checklist for a Black Friday sale
- Does the 30-day lowest price sit next to the Black Friday price on every surface (banner, collection, product)?
- Is it clear that this reference is the 30-day low under §11 PAngV, not a UVP?
- Do "up to X%" claims reference real 30-day lows, per the 2024 BGH ruling?
- Did you avoid lifting prices in early November only to cross them out (Mondpreis)?
- Do you have a timestamped price history you can show if an Abmahnung lands?
- Are exempt cases (perishables, genuine new-product launch prices) labelled correctly?
How Heartly keeps Black Friday sales compliant
Heartly records every price change with a timestamp. When a flash sale goes live, it calculates the lowest price of the previous 30 days in real time and displays it next to the sale price on the dedicated flash sale page. The full price history stays available per product, which is the audit trail you want if a warning ever arrives.
For the merchant this means: create the sale, set the discount, publish. The 30-day low appears correctly without custom fields or theme edits. For the legal background, see the PAngV §11 guide and the Omnibus Directive explainer. For the operational setup, see implementing the 30-day lowest price.
Frequently Asked Questions
Can I advertise with crossed-out prices on Black Friday in Germany?
Yes, but the crossed-out price must reference your 30-day lowest price, and that reference must appear next to the sale price. Crossing out a price you never genuinely charged is a Mondpreis and counts as misleading advertising under §5 UWG.
What is the 30-day lowest price rule?
Under §11 PAngV, any announced price reduction must state the lowest total price the seller charged for that product in the 30 days before the reduction. It applies to every reduction shown to German consumers, including Black Friday and Cyber Monday.
Does the rule apply to "up to 50% off" banners?
Yes. The 2024 BGH ruling (I ZR 80/23) confirmed that percentage claims must reference real 30-day lows, and the reference price has to be visible next to the advertised price, not hidden in a footnote.
What happens if I ignore the 30-day price rule?
The most common outcome is a competitor Abmahnung with a Streitwert of 5,000 to 15,000 € plus legal fees. Administrative fines reach 50,000 € per violation, and marketplaces remove non-compliant listings, which costs a selling day during peak traffic.
Are Black Friday sales exempt from the 30-day rule?
No. There is no seasonal exemption. Black Friday and Cyber Monday reductions must show the 30-day lowest price exactly like any other discount.
This article is information, not legal advice. For a specific case, consult a lawyer for German e-commerce law.