Most countries let you decide what your product used to cost. Norway does not. The crossed-out number beside your sale price has to be a real price you really charged, recently, and there is a regulator who checks.
The rule in one sentence
When you market a price as reduced, the reference price you show has to be the lowest price you applied in the 30 days before the campaign started.
That is it. The whole thing. Every complication below is a consequence of taking that sentence seriously, and most of the trouble shops get into comes from assuming it means something looser than it says.
Norwegians call the reference price the førpris, the before-price. The word comes up in every enforcement letter on the subject, so it is worth knowing.
What counts as a lawful førpris
Three conditions, all of them at once. It has to be a price you really charged, not one you quoted or one a supplier suggested. It has to be the lowest such price across the 30-day window, not an average and not the highest. And the window ends when the campaign starts, so you cannot count the campaign period itself.
The purpose behind the rule is stated openly by the regulator: to stop shops marketing artificially high before-prices. Once you read it that way, the edge cases mostly answer themselves. If a discount only looks like a discount because of a number you invented, it is the thing the rule is aimed at.
Four ways shops break it
None of these involve anyone setting out to mislead. All four are ordinary European retail practice that happens to be unlawful here.
- The sale that never ends
- A discount runs from March, pauses for a weekend, and comes back at the same reference price. After the first few weeks that reference price is no longer the lowest price of the previous 30 days, because the sale price is. The item has a new normal price and the shop is the last to know.
- The recommended retail price
- Crossing out a manufacturer's suggested price you have never charged is not a discount from anything. If nobody ever paid it at your shop, it is not your reference price.
- The two-day setup
- Raising a price, holding it briefly, then discounting from it. The rule looks back 30 days precisely so this does not work, and it is the pattern the rule was written to stop.
- The members' price you forgot about
- If your loyalty scheme or newsletter list had it cheaper during those 30 days, that lower price counts. Prices offered to a customer club or another large group are part of the picture, not a separate one.
The first is the one that catches the most people, and it is the hardest to notice from inside a business. A sale that has been running since spring does not feel like a compliance problem. It feels like a pricing strategy.
What the regulator does
Forbrukertilsynet, the Norwegian Consumer Authority, supervises this. Their published ladder runs from guidance, to orders, to coercive fines, to violation penalties for breaches they consider serious or systematic.
It is not theoretical. They have fined a clothing retailer over a million kroner for unlawful førpriser, and in a separate sweep sent guidance letters to 76 businesses in the clothing sector about compliance with the sales marketing rules.
The word systematic is the one to watch. A single mispriced item is a mistake. A campaign structure that produces unlawful reference prices across a catalogue, month after month, is the thing that moves you up the ladder. Foreign shops running one pricing engine across many countries are, by construction, more likely to be systematic about it.
Why Black Friday is the flashpoint
Black Friday is bigger in Norway than in most of Europe, and it is the one week where every shop in the country discounts at once and says so loudly. That makes it the easiest possible moment to audit, and the regulator has run supervision around it.
Now put a foreign shop into that picture. Head office sets one campaign, one set of percentages, one banner, applied to every market on the same morning. In twenty-six countries it is fine. In this one, the reference prices behind it have to satisfy a rule nobody in the room has read.
The practical consequence is that the work has to happen in October. The 30-day lookback means a lawful November reference price depends on what you were charging weeks earlier, so a campaign checked the day before it launches is a campaign you can only cancel, not fix.
The rest of the price rules
The førpris rule gets the attention, but the guidance it sits inside is broader. Price information generally has to be correct, clear and complete, and the total price has to be stated clearly in the marketing.
For a foreign shop, the total price part deserves its own moment. If your Norwegian customer sees one number on the product page and a larger one at checkout, once VAT and fees have been added, you have a problem that has nothing to do with discounts. Consumer prices in Norway are inclusive prices.
Conditional offers carry their own rules too. Free delivery over a threshold, a gift with purchase, buy-two-get-one: the condition has to be as visible as the offer, not waiting in a footnote.
How to be safe
Keep price history. If you cannot show what you charged for an item on a given day three weeks ago, you cannot prove a reference price was lawful. Most platforms will export this. Very few shops have ever looked.
Put real gaps between campaigns. Long enough that a normal price exists again. This is the structural fix, and it is worth more than checking individual items.
Let Norway differ. The instinct to run one campaign everywhere is exactly what produces the systematic version of this problem. Norway needs its own reference prices, and sometimes its own campaign dates.
Check in October, not November. For the reason in the section above.
None of this requires a lawyer. It requires somebody to go through your shop against the published guidance and tell you where you sit, which is what the sale price review is. If you would rather do it yourself, everything you need is in the sources below, and that is a perfectly good outcome.
Have it checked before the campaign
We go through your shop against Forbrukertilsynet’s published guidance and write up what needs changing, with the source beside each finding. Fixed price, quoted before we start.
Sources
- Forbrukertilsynet, Salg og bruk av førpriser for the 30-day rule and what counts as the lowest applied price.
- Forbrukertilsynet, veiledning om prismarkedsføring for total price display and the wider price marketing guidance.
- Forbrukertilsynet, betingede tilbud for conditional offers.
- Forbrukertilsynet, klesbutikk får millionbot for ulovlige førpriser for the enforcement case.