Norway regulates discounts harder than most of Europe, and it does it through a body with teeth. Forbrukertilsynet has fined a clothing retailer over a million kroner for unlawful reference prices, and has written to dozens of others about the same thing.
The rule that catches people
When you advertise a price as reduced, the crossed-out price you show beside it is not yours to choose. Under the Norwegian rules it has to be the lowest price you charged in the 30 days before the campaign started.
That single sentence breaks a lot of ordinary European retail practice. Running a short sale, ending it, then restarting it a week later at the old reference price does not work here. Neither does quoting a recommended retail price you never charged, nor a price you held for two days purely so you could discount from it afterwards, nor a members-only price that was lower than the one you are now calling the before price.
Black Friday is where this turns into money, because it is the one campaign nobody runs quietly. Forbrukertilsynet watches that week specifically, and a foreign shop running a single Europe-wide banner is the easiest thing in the world for them to spot.
Who this is for
This is for you if
- You run discounts, sales or campaign pricing at Norwegian customers.
- You use crossed-out reference prices, recommended retail prices, or percentage-off claims.
- Your campaign calendar is set centrally and applied across several countries at once.
- You have a Black Friday or seasonal campaign coming and have never had the Norwegian rules checked.
Do not buy this if
- You sell at one steady price and never discount. There is very little here for you.
- You sell only to businesses. These are consumer protection rules and they do not reach B2B pricing.
- You want somebody to sign off that you are compliant. We produce findings against published guidance, not an assurance.
- You are already in correspondence with Forbrukertilsynet about something. At that point you want a Norwegian lawyer, not us.
What we check
The review runs against a fixed list, built from Forbrukertilsynet's own published guidance rather than from opinion. The main headings:
- Reference prices
- Every crossed-out price on the storefront, tested against the 30-day rule and against what your own price history shows.
- Campaign structure
- How long sales run, how quickly they repeat, and whether the gaps between them let a lawful reference price exist at all.
- Discount claims
- Percentage-off and 'up to' claims, and whether the headline number is true of enough of the range to be usable.
- Total price display
- Whether the price a Norwegian customer first sees is the price they end up paying, including what is added at checkout.
- Conditional offers
- Bundles, thresholds, free delivery over a value, and gift-with-purchase, where the condition has to be as visible as the offer.
- Countdowns and scarcity
- Timers, stock counters and 'ends tonight' claims, and whether they describe something real.
- Marketing copy
- Campaign emails and banners aimed at Norwegian customers, checked against the same rules as the storefront.
How it runs
- 01
You send the shop and the calendar
A link to what a Norwegian customer sees, and a note on when campaigns run. If you can export your price history for the last few months, that makes the reference price findings exact rather than inferred.
- 02
We go through it and screenshot everything
Findings are evidenced. Each one names the page, shows what was on it, and quotes the guidance it sits against.
- 03
You get a written review
Every finding with the regulator's own wording beside it, a link to the source, and the specific change that resolves it. Ordered by how exposed each one leaves you, not by how easy it is to fix.
- 04
We talk it through
A call to go over anything unclear, and to answer the question everyone asks, which is how much of this really matters.
Turnaround is about a week from the point we have what we need. If a campaign is imminent, say so and we will tell you straight whether we can be useful in time.
What it costs
Fixed before we start, once we have seen the shop and the range. A single storefront with one seasonal sale sits at the low end. What pushes it up is the size of the range and how many separate campaign mechanics are running: tiered discounts, a loyalty scheme and country-specific banners each add to the checking. You get the number before you commit, not after.
A re-check before your next campaign, once the first review is done, costs less than the first one. That is the version most people want in the run-up to November.
For comparison, a Norwegian law firm doing the same work bills it as five to ten hours of an advokat's time. This is cheaper because it is a compliance review against published guidance rather than a legal opinion, which is exactly the distinction in the next section.
This is not legal advice
Worth being blunt about. We are not lawyers and this review is not a legal opinion. What it is: a careful, evidenced comparison between what your shop does and what the Norwegian consumer authority has published about what it expects.
That is enough for most shops, because most breaches are not close calls. They are a reference price nobody ever charged, or a sale that has run continuously since spring. You do not need an advokat to tell you those are problems, you need somebody to find them and show you where they are.
Where a finding really is a close call, the review says so rather than pretending to certainty, and that is the point at which we will tell you to go and get a Norwegian lawyer.
Where the rules are
Check it yourself
Salg og bruk av førpriser is Forbrukertilsynet's page on reference prices, and the source of the 30-day rule described above.
Veiledning om prismarkedsføring is the fuller guidance document covering total price display, conditional offers and discount claims.
Klesbutikk får millionbot for ulovlige førpriser is the enforcement case, and the most direct answer to anyone who thinks these rules go unenforced.
The longer written explanation of all this, free and with no service attached, is Norway’s sale price rules. Read that first. If it turns out you are fine, you have saved yourself the fee and we would rather that than the alternative.
Send us the shop
A link to your Norwegian storefront and a note about when your next campaign runs. We will tell you whether there is anything worth reviewing, and quote a fixed price before starting.