UK pricing facing major overhaul following amendments to the Price Marking Order 2004

The question

What amendments have been made to the Price Marking Order 2004 following the 2024 and 2025 updates?

The key takeaway

The Price Marking Order (PMO) requires traders, both physical and online, to display clear and unambiguous selling and unit prices for goods offered to consumers. The latest amendments update definitions and provide expanded obligations and make clear that retailers must ensure price information is sufficiently transparent to enable consumers to make informed comparisons between products.

The background

The PMO was introduced to implement Directive 98/6/EC, with the aim of protecting consumers by standardising price display requirements. It defines key terms such as “selling price” – the total price a consumer must pay for a product – and “unit price”, which indicates the price per standard unit of measurement. These definitions enable consumers to make informed comparisons between products.

The development

The Government’s recent guidance on the 2024 and 2025 amendments to the PMO seeks to explain to retailers how they are now required to display products.

Examples of some of the key amendments made include clarification of the definitions of “selling price”, “unit price” and “deposit” – the latter as a result of the incoming Deposit Return Scheme – and a requirement to use metric units consistently across all products. In addition, the PMO as amended now covers modern retail practices, such as multi-buy offers, loyalty schemes and online sales, requiring all applicable selling and unit prices to be clearly displayed together with any relevant conditions.

Failing to adhere to the amendments could lead to strengthened sanctions being imposed as a result of the implementation of the Digital Markets, Competition and Consumers Act (DMCCA), which now include criminal prosecution (including unlimited fines) and, for civil penalties, fines of up to £300,000 or 10% of global turnover.

There are some exemptions to the requirements (eg for “small” shops). Schedule 2 of POM provides full details of these exemptions.

These amendments are expected to come into effect from April 2026.

What are some of the practical impacts?

• Exclusion of deposit from selling/unit price: the new amended definitions of “selling price” and “unit price” explicitly exclude any deposit amount (eg, for a container subject to a deposit-return scheme). Example: A bottled drink sold for £1.00 plus a £0.10 refundable deposit should display the selling price as £1.00 and not £1.10. The deposit must be displayed separately and not included in the unit price.
• Greater consistency in units of measurement, in particular liquids, solids etc: the guidance states that unit pricing must use appropriate standard metric units (eg kg, litre, metre, square metre, cubic metre) and that all like goods should use the same unit measure to enable comparisons. Example: A 1.5 litre bottle of water must display the unit price per litre, eg, if sold at £1.50, then unit price = £1 per litre. You can no longer use “per 500 ml” or per “bottle”.
• Selling price and unit price for products with multiple price types (eg for promotions and loyalty schemes) must be displayed: if a product is offered at more than one price, for example because there is a standard price and a discounted loyalty member price, each applicable selling price and each corresponding unit price must be displayed, together with any conditions. Example: A box of biscuits is normally £3, but £2.50 for loyalty members. The pricing must display both: “£3.00 (unit price £6.00 per kg)” and “£2.50 (unit price £5 per kg) for loyalty members only”.
• Promotional reductions need unit prices reflecting the reduced price: the amendments clarify that when a promotional reduction applies, the reduced unit price must be displayed and not just the original unit price. Example: A two litre bottle of fabric conditioner is on promotion and must show: the original price £12 (unit price £6.00 per litre), reduced to £10 (unit price £5.00 per litre). The label must show the reduced unit price (£5.00 per litre) with the reduced selling price of £10.
• Legibility, proximity and accessibility requirements: the guidance explains that price and unit price information must be “unambiguous, easily identifiable and clearly legible”, and positioned close to the product or its online description. Example: Online listing for a 500 ml shampoo bottle must display clearly the selling price and unit price (eg, £5.00, unit price £10.00 per litre) on the same page, near the product description, and in a font size/contrast (remember that accessibility standards must also be met). “Info” links etc are not sufficient.
• Expansion of product types subject to unit-price obligations: the range of goods that must now show unit prices has grown, and includes packaged food items (eg pasta, cereal) and non-food items (eg cosmetics and detergents).
• Exemptions clarified/adjusted: some exemptions (eg “small shops” under 280 m² floor area) remain. The definition of “small shop” is important because they are excluded from the requirement to display unit price-for products which are pre-packaged in constant quantities. However, if the shop offers a multi-buy of different package sizes, it may not be exempt.

Why is this important?

The PMO ensures that consumers have access to clear and comparable pricing information, allowing them to make informed purchasing decisions and encouraging fair competition. It also protects against misleading or unclear pricing, particularly in complex retail environments involving promotions, discounts, and loyalty schemes.

For retailers, compliance reduces the risk of enforcement action and reputational damage while supporting fair trading standards. The expanded sanctions regime under the DMCCA reinforces the importance of proactive compliance and transparent pricing practices.

The Government’s updated guidance consolidates the 2024 and 2025 amendments and provides practical examples of how businesses should meet their new obligations.

Any practical tips?

Businesses should review the new guidance and begin implementing any necessary changes well before the 6 April 2026 deadline.

Retailers should ensure prices are displayed clearly and accessibly, with the selling price and, where required, the unit price presented in an unambiguous, easily identifiable, and legible manner. All relevant information, such as VAT, should be included – but deposits should be excluded from the displayed price.

Other practical steps to consider:

• audit all pricing (labels etc) and online product listings to check that the unit of measure used for unit pricing corresponds to the correct metric (eg kg, litre)
• ensure any liquid volume is clearly stated (eg, “1 litre”) and that the unit price is per litre (not per 100 ml or per item, unless item is clearly specified as “per item”)
• check for promotions and loyalty schemes to ensure they reflect the reduced unit price and are clear
• ensure your internal pricing systems can cope, especially with multiple pricing scenarios (eg promotions, multi-buy, loyalty schemes) and the appropriate unit prices for each type of pricing
• review pricing presentation is clearly displayed with regard to font size, contrast and product proximity. This applies to all pricing, including shelf labelling and online listings
• look out for non-food products (such as cosmetics and detergents) which may now be caught by the new unit pricing rules and work out a pricing/labelling plan, and finally
• watch the clock! 6 April 2026 is not far away and there will be lots to achieve in terms of amending labelling, signage etc and related systems, as well as staff training.

Autumn 2025