Are You Compliant with the Price Marking Order Reforms?

April 9, 2026

The new Price Marking Order reforms are live. If you are selling goods in store or online, now is the time to make sure every shelf label, online listing, and promotion is compliant and clear for customers.

As of 6 April 2026, retailers must comply with updated rules on how selling prices, unit prices, and deposits are displayed both in store and online.

What has changed under the Price Marking Order 2004?

The Government has amended the Price Marking Order 2004 to modernise how selling and unit prices are displayed in store and online. These changes will have a direct impact on:

  • pricing systems
  • product labelling
  • promotional displays
  • staff training

The effects will be most severe for retailers with large and complex product ranges where consistency is hardest to achieve at scale.

What is the Price Marking Order and why is it changing?

The Price Marking Order 2004 is designed to ensure consumers can make informed purchasing decisions by requiring clear and transparent price information. This is particularly important where products are sold in different sizes, or where promotions, discounts, and loyalty pricing apply.

What prices are covered under the Price Marking Order 2004?

There are three key definitions under the new Price Marking Order reforms.

  1. Selling price. This is the final price the consumer pays for the product including VAT and all other taxes but, excluding any refundable deposit. An example would be a bottle of milk shown at £1.50.
  1. Unit price. The price per standard unit such as kilogram, litre, metre, square metre or cubic metre or per item where the product is sold by number. Unit price also excludes any deposit. The example here would be £1.00 per litre of milk, regardless of bottle size.
  2. Deposit. This is a definition linked to deposit return schemes under the Environment Act 2021 and any such amount are not part of the selling price or the unit price. Under the Environment Act 2021, a deposit scheme is one where a customer pays an amount (“a deposit”) when supplied with a designated item, and a person who returns that item to an approved collector is entitled to a refund of that amount. Traders should display the deposit clearly and separately, so the product price remains transparent.

Under the Price Marking Order, traders are required to display the selling price.

When is unit pricing required?

In addition, the general rule is that a trader must indicate the unit price of any product that is or may be for sale to a consumer, in accordance with the provisions of the Price Marking Order. This requirement only applies in respect of products sold from bulk or required by certain legislation (such as the Weights and Measures Act 1985).

The purpose behind the recent Price Marking Order reforms is to strengthen this transparency. The changes expand the scope of unit pricing to more product categories, clarify how selling and unit prices should be displayed where multiple prices apply, and introduce updated definitions, including a new requirement to display deposits separately.

Who does the Price Marking Order apply to?

Price marking sets the rules for how traders display prices to consumers when selling goods. It applies to retail sales in store and online across Great Britain.

When do these reforms take effect?

The Government postponed the start date from 1 October 2025 to 6April 2026. That extension gave retailers time to adapt systems, redesign labels and train teams before enforcement began.

What are the Key Reforms and Rules to the Price Marking Order?
  1. Broader unit pricing. Obligations extend to more packaged goods including cereals, pasta, dried fruits, detergents, cleaning products and cosmetics. This is intended to support like for like comparisons on a wider range of everyday items.
  2. Standardised metric units. Where unit pricing is required, use kilogram, litre, metre, square metre or cubic metre as appropriate. Consistent units reduce confusion between similar products on the same shelf.
  3. Multiple prices and loyalty schemes. Where a product is offered at more than one price for example, a standard price and a loyalty price, traders must display both selling prices together and, where unit pricing applies, show the corresponding unit price for each. Traders should state the eligibility conditions clearly and next to the prices for example, that the loyalty price is available with a valid loyalty card, and ensure neither price is given undue prominence.
  4. Accessibility and legibility. Traders should use clear fonts of reasonable size, adequate spacing and consistent layouts. Prices must be unambiguous, easily identifiable, clearly legible and placed close to the product or its online description. Traders should factor in accessibility when designing labels and digital templates.
  5. Location. Prices can be shown on the product itself or on a label, ticket or notice placed on or immediately next to it. When displayed online, the selling price and, where required, the unit price should sit alongside the product description.
  6. Advertisements. The rules also deal with advertisements. An advertisement does not have to show a selling price by law but if it does, it must also include the unit price where unit pricing would normally be required.
What are the Key Exclusions and Exemptions?
  1. Small shops. A small shop is defined as having a relevant floor area not exceeding 280 square metres. Small shops are exempt from unit pricing for pre-packaged goods in constant quantities but must still show the selling price.
  2. Damaged or deteriorating goods. If an item is reduced because it is damaged or at risk of deterioration, traders should display the reduced selling price, but the reduced unit price does not need to be shown.
  3. Assortments and package deals. For mixed item assortments sold in a single package or at a combined promotional price (for example, “Dine in for 2 for £20”) traders must still display the selling price and, where required, the unit price for the items when sold individually, but you do not need to show a unit price for the combined package. In contrast, like for like multi buys where the products are individually identical (for example, “2 for £3 on own brand crisps”) do not benefit from this exemption. Traders must show both the regular and the offer selling price and, where required, the unit price.
  4. General reductions. A general notice such as “20 percent off all paint” can be used only where it is not reasonably practicable to update every label. For product specific promotions, traders should update the relevant selling price and, where required, the unit price.
How we can help

At Herrington Carmichael we help retailers and consumer facing businesses turn complex pricing rules into clear, practical processes that work across stores, ecommerce and marketing.

  • Compliance Reviews: Align your pricing practices with the revised Price Marking Order and related guidance, identify gaps and provide a clear, prioritised action plan.
  • Training and Change Support: Deliver concise, role‑specific training and tools for store, digital and marketing teams to embed the new requirements.
  • Consumer Rights Advice: Advise on the wider consumer protection regime and CMA expectations, setting out the steps needed to keep promotions and communications compliant.

Get in touch today to discuss how we can help you and your business.

Cesare McArdle
Partner, Commercial & Construction
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This reflects the law and market position at the date of publication and is written as a general guide. It does not contain definitive legal advice, which should be sought in relation to a specific matter.

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