Black Friday 2026: 674 EU Shopify stores checked against four EU rules

Why it matters on Black Friday

Black Friday is when reduced prices are most visible, when the most orders are placed and returned, and when consumer authorities and competitors are looking. Each rule below is now in force in at least some of the sampled markets.

1. The 30-day prior price (Omnibus Directive). Since 28 May 2022, any announced price reduction must be measured against the lowest price the store charged in at least the 30 days before it. Poland requires that lowest price to be shown next to the reduced price. The Dutch ACM expects permanent text next to the reference price. In Germany a separate line is not strictly required, but after a 2025 Federal Court of Justice ruling the 30-day low must be unambiguous, and a line is the safe design. Country by country: EU Omnibus rules by country.

2. GPSR product information (since 13 December 2024).Every online listing of a consumer product covered by GPSR must show the manufacturer’s name and postal and electronic address, the EU responsible person where the manufacturer is outside the EU, product identifiers and any warnings or safety information. We checked the maker details only.

3. The withdrawal button (since 19 June 2026).Online shops must offer a function labelled “withdraw from contract here” or an unambiguous equivalent, prominently displayed and available throughout the withdrawal period, followed by a confirmation step. In our sample it is in force in Germany, France, Italy, the Netherlands, Belgium and Austria (Austria since 1 October 2026). It is not yet in force in Poland or Spain, so those stores were not counted.

4. The EU guarantee notice (since 27 September 2026). The harmonised notice about the two-year legal guarantee must be shown prominently before the order, as pre-contractual information. We checked the product page only; the notice may also appear later in checkout. In our sample it applies in Germany, Italy, the Netherlands, Belgium and Austria, not in France, Spain or Poland.

Results by rule

The 30-day price line

Poland, where the line is mandatory, does best, but still more than 4 in 10 sale pages lacked it. This figure is conservative: we counted every 30-day line as shown, including wordings the Polish authority (UOKiK) considers inadequate. In the other five markets, 161 of 207 sale pages (78%) showed no separate line. That is not automatically a breach there: the crossed-out price can itself be the 30-day lowest price. We do not count those stores as non-compliant.

GPSR maker details

Of 674 pages checked, 38 (6%) showed the manufacturer’s name and addresses, 41 (6%) showed part of them and 595 (88%) showed none. The hand-check confirmed the “missing” verdict in 32 of 37 cases (86%).

The withdrawal button

Of the 495 stores in markets where it is in force, the automated checker misses about two in three real withdrawal functions, so we publish a cautious estimate based on 21 hand-judged stores: roughly two in three showed no online withdrawal function. Many showed only information about the right of withdrawal (268), a returns portal (32) or a contact form (4).

The guarantee notice

Of the 387 stores where it applies, 330 (85%) showed no guarantee notice and 41 (11%) only plain text, with 16 (4%) likely showing the notice. The hand-check confirmed “no notice shown” in about 94% of cases.

What store owners can do before 27 November

1. Reduced prices: check that every crossed-out price is the lowest price of the last 30 days, and show that price as a separate line if you sell in Poland (required), the Netherlands (expected) or Germany (safest).
2. GPSR:add the manufacturer’s name, postal address and an email address to every product page.
3. Withdrawal button:add a “withdraw from contract here” link that leads to a confirmation step, in every market where the rule is in force.
4. Guarantee notice: show the EU harmonised notice prominently before the order where it applies.

The full list, item by item, is in our Black Friday 2026 EU checklist.

Method

• Sample: 710 stores drawn at random (reproducible seed) from StoreLeads: active Shopify stores headquartered (by StoreLeads) in Germany, France, Italy, Poland, Spain, the Netherlands, Austria or Belgium, with estimated sales of at least $50,000 a month. Complimus customers were excluded. 674 stores could be captured; 392 of them (58%) are on Shopify Plus.
• What we checked: one product page per store, a reduced product where the store had one, captured 27 to 29 October 2026 from a Hungarian IP address (some stores redirected to a Hungarian storefront; those were not judged on price). 365 stores had a visible reduction.
• How: an automated checker read each page for the four items. Each rule was counted only in markets where it is in force.
• Accuracy:we checked a random sample by hand (63 stores for prices, 40 stores for the other three rules). When the checker flagged a missing 30-day line, it was right 91% of the time, and it undercounts overall (78% by hand against 70% by the checker). The GPSR “missing” verdict was right about 86% of the time (97% once non-product pages, gift cards, food and B2B stores are excluded). The checker finds only about one in three real withdrawal functions, which is why that figure is given as an estimate.
• Limits:one page per store, a snapshot in time, a heuristic checker. The results describe the market, not any named store, and no store’s result is shared.
• Next:after Black Friday we will publish part 2, comparing Black Friday crossed-out prices with each store’s daily prices in the 30 days before.

Journalists and bloggers may quote the figures with a link to this page. For the per-market data, write to admin@complimus.com.