What the CMA expects in UK product feed prices and promotions

What to take away

What the CMA expects from online prices and promotions

The Competition and Markets Authority is the UK body that enforces consumer protection law against unfair commercial practices. Its online sales guidance matters to any retailer selling through a shopping feed, because a feed is an advertisement as well as a data file.

The CMA has published Consumer protection guidance for businesses - GOV.UK covering how it applies consumer law to online pricing and promotions. That guidance is the starting point for feed copywriters, not the marketplace help centre.

The core principle is simple. A price or saving shown to a shopper must be accurate, clear and capable of being proved. If your feed says a jacket is half price, the CMA expects you to show what it was half of, and when.

Misleading claims sit under the Consumer Protection from Unfair Trading Regulations 2008, which prohibit commercial practices that deceive the average consumer. The Consumer Protection from Unfair Trading Regulations 2008 applied to feed content until 6 April 2025, when the unfair commercial practices provisions of the Digital Markets, Competition and Consumers Act 2024 replaced them.

From 2025 the Digital Markets, Competition and Consumers Act 2024 changed the enforcement picture. The Digital Markets, Competition and Consumers Act 2024 gives the CMA powers to decide breaches and impose penalties directly, without going to court first.

That shift raises the stakes for feed teams. A sloppy was/now field is no longer only a marketplace policy risk. It is a consumer law risk with a regulator that can act on its own.

Advertising rules run alongside consumer law. The CAP Code sets standards for promotional pricing and urgency claims in UK advertising, and the Advertising codes - ASA | CAP are enforced by the Advertising Standards Authority.

Google adds its own layer for paid listings. Its Legal requirements - Advertising Policies Help require advertisers to comply with local consumer protection and fair trading law, which for UK campaigns means CMA expectations.

The practical result is that multichannel ecommerce teams need one pricing standard used across eBay UK, Google Shopping UK, Amazon UK and their own sites. Different channels, same underlying claim.

Reference prices and was/now claims in eBay UK feeds

A reference price is the earlier price a discount is measured against. In eBay UK feeds it usually appears as a was price, a list price or a strike-through. The CMA expects that figure to be genuine and recent.

Reference price rules in the UK are not set out as a single statute. They come from the combination of the 2008 Regulations, CMA guidance and sector precedents. The working test is whether the previous price was the price the product actually sold at.

If a product never sold at £80, showing it as was £80 and now £40 misleads the shopper about the size of the saving. That is the kind of claim the CMA has acted on in online retail.

The period matters too. A price that ran for two days months ago is weak support for a current was/now claim. A price that ran for a sustained period immediately before the promotion is stronger.

The CMA does not set a single fixed period, but the ASA and trading standards commonly treat a previous price charged for at least 28 days as a benchmark.

For eBay UK promo feed fields such as was price, list price and markdown event, the practical requirement is consistency. The was price in the feed must match the price shown on the listing, the price on your own site and any email you send in the same campaign.

Feed copywriters should treat the was price as a factual field, not a marketing field. It should be populated from a pricing history table, not typed into a spreadsheet by hand.

That means keeping a dated record of when each price applied. A simple price history table with SKU, price, start date and end date covers most was/now claims.

Where a product is new and has no prior selling price, do not invent one. Use a recommended retail price only if it is genuine and you can show the source, and label it clearly as an RRP rather than a was price.

Bundle and multibuy claims need the same treatment. If a bundle saves £10, the CMA expects the comparison to be against the genuine cost of buying the items separately at the time of the claim.

For teams working through the wider rule set, our guide to shopping feed rules and ethics covers how marketplace policy and consumer law overlap.

Urgency claims and countdown messaging in Google Shopping UK

Urgency claims tell a shopper to act now. They include countdown timers, limited stock messages, today only banners and closing soon language. The CMA expects these claims to be true.

Urgency claim guidance from the CMA and the ASA is consistent on this point. If you say stock is low, stock must actually be low. If you say a sale ends at midnight, it must end at midnight.

Countdown timers are the most common problem in Google Shopping UK promotion attributes. A timer that resets when the page reloads, or restarts when the promotion ends, is a misleading practice.

Google Shopping UK promotion attributes include fields for promotion ID, title, redemption channel, promotion effective dates and, for some formats, percent off or money off values. Each of those fields is a claim.

If the promotion effective dates say the offer runs from 1 September to 30 September, the landing page must not show a timer counting to a different date. The feed and the page must agree.

Stock urgency is harder to automate honestly. A message such as only 3 left should be driven by live inventory, not by a static feed value that was set weeks ago.

Scarcity claims based on demand, such as selling fast or popular, need evidence. Website analytics showing genuine sales velocity can support them. A feeling that a product is popular cannot.

Google's advertising policies require compliance with local law, and the CMA treats fake urgency as an unfair commercial practice. The two enforcement routes can both apply to the same listing.

A safer approach is to make urgency claims only where you can automate the truth. If you cannot connect the timer to a real deadline, remove the timer.

For smaller retailers, the practical burden is heavier because there is no compliance team. Our piece on shopping feeds advertising rules sets out how to keep claims proportionate.

Promo data, discounts and the Digital Markets, Competition and Consumers Act 2024

Promo data is the structured information behind a discount: the promotion type, the value, the dates and the products included. Under the Digital Markets, Competition and Consumers Act 2024, that data is evidence.

The Act gives the CMA a direct enforcement route for unfair commercial practices, including misleading pricing and urgency claims. It can investigate, decide and fine without a court order.

For multichannel ecommerce teams, the operational change is record keeping. If the CMA asks why a product was advertised as 30 percent off on a given date, you need the underlying price history.

Discounts should be calculated from a genuine previous price. A percentage off an inflated price is a misleading claim even if the arithmetic is correct.

The safest pattern is to run promotions from your own price history. The feed pulls the was price from the same table that your ecommerce platform uses, so every channel shows the same figure.

Where marketplaces impose their own promo structures, map them to your internal promotion types. An eBay UK markdown event and a Google Shopping UK promotion should both trace back to one campaign record.

Campaign records should include the promotion name, the products included, the start and end times, the reference price used and the person who approved it. That is a small amount of admin for a large amount of protection.

A disclosure policy helps here. Our seven-step guide to a shopping feeds disclosure policy explains how to document promotional claims so they can be audited.

Membership and loyalty pricing also falls under these rules. If a lower price is available only to members, the non-member price should be presented clearly rather than hidden.

Personalised pricing is a further area the CMA watches. If a price is tailored to a shopper, the claim about the saving must still be accurate for that shopper.

Evidence files a multichannel ecommerce team should keep

Evidence is what turns a pricing claim into a defensible one. The CMA does not require a particular format, but it does expect records that show the basis of a claim.

Start with a price history table. One row per SKU per price change, with the price, the channel, the start date and the end date. This single file supports most reference price claims.

Next, keep a promotion register. One row per promotion, with the promotion ID used in the feed, the channels it ran on, the dates, the discount type and the reference price source.

Keep the feed snapshots. A dated export of the eBay UK promo feed and the Google Shopping UK promotion attributes for each campaign shows exactly what shoppers were shown.

Keep the landing page evidence too. A screenshot or archived copy of the product page during the promotion shows whether the timer, stock message and price matched the feed.

Use this checklist to audit a promotion before it goes live:

A worked example shows how this fits together. A retailer sells a lamp at £50 for most of the year. In November it raises the price to £60 for two weeks, then advertises was £60, now £45.

The was price is weak because £60 was not the usual selling price. A stronger claim would use the £50 price as the reference, giving a smaller but honest saving.

In the feed, the promotion ID, dates and discount value should all match the promotion register. The landing page timer should end when the register says the promotion ends.

If the CMA or a marketplace asks, the retailer can produce the price history, the register, the feed snapshot and the page screenshot. That is a complete evidence file for one promotion.

Scale that pattern across every campaign and the compliance workload becomes routine. The alternative is reconstructing evidence after a complaint, which is slower and less convincing.

Common questions