Price Marking Order 2004: government guidance
Published 22 September 2025
Applies to England, Scotland and Wales
Introduction
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When shopping, consumers should be able to make informed choices. Their ability to do this rests on them being provided with clear and transparent information – especially in relation to pricing. When faced with a variety of prices, promotions, loyalty discount offers, and reductions, it can be difficult to make like-for-like comparisons between products.
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How retailers display prices for consumers is governed, in particular, by the Price Marking Order 2004 (‘PMO 2004’) (S.I 2004/102). The PMO 2004 implemented Directive 98/6/EC and came into force on 22 July 2004. The PMO 2004 has undergone various amendments since it was made, most recently by the Price Marking (Amendment) Order 2024 (‘PMO 2024’) (S.I 2024/1055) and the Price Marking (Amendment) Order 2025 (‘PMO 2025’) (S.I 2025/592). The amendments made by both these orders come into effect on 6 April 2026. This guidance concerns the PMO 2004 as it will apply, with effect from 6 April 2026, once it has been amended by the PMO 2024 and the PMO 2025.
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The PMO covers goods, not services, and is limited to sales between traders and consumers – which includes online sales as well as physical shops.
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The PMO requires traders to display the ‘selling price’ which is the price that a consumer will pay for the actual weight or volume purchased. The selling price should include any taxes.
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The PMO also requires traders, where applicable, to display the ‘unit price’ – which is the price which would be charged for the relevant unit of the goods, depending upon how the goods are sold. Unit pricing can be a useful tool for consumers. It allows consumers to compare the price and value of similar products. This can be helpful when making a decision between similar products that are sold in different sizes or quantities. For example, when choosing between 3 bottles of apple juice of differing sizes, the unit price will let consumers know which bottle of juice is the cheapest or most expensive, allowing them to pick the one which is the most suitable for their needs.
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Pricing should be clearly displayed. This makes it easier for consumers to compare product prices.
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The PMO applies to Great Britain. Consumer protection is devolved to Northern Ireland, where the Price Marking Order (Northern Ireland) 2004 (S.R. (N.I.) 2004 No 368) applies.
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This document provides guidance on the main provisions of the PMO 2004 indicating certain amendments made by the PMO 2024 and the PMO 2025 where relevant. This document provides guidance only and is not a substitute for reading the legislation. We have included a number of examples to help illustrate how the government considers the legislation will apply in practice. However, these are hypothetical scenarios and traders should consider the application of the legislation in the circumstances of each specific case. This guidance does not provide legal or other advice and, if in doubt as to your obligations, you are strongly recommended to obtain legal advice.
Articles
Article 1: citation, commencement and interpretation
9․ Article 1 defines 18 terms, which are used in the PMO 2004. Four definitions are particularly important for the purposes of the legislation. In particular, the PMO 2024 updated the definitions of ‘selling price’ and ‘unit price’ and added the new definition of ‘deposit’.
Selling price
10․ The amended definition of ‘selling price’ is:
“the final price to be paid for a unit of a product, or a given quantity of a product, including VAT and all other taxes (but excluding the amount of any deposit).”
11․ The selling price is, therefore, the price which a trader charges for the product on sale. The selling price is the price without any deposit.
Unit price
12․ The definition of ‘unit price’, as amended by the PMO 2024, is:
“the final price, including VAT and all other taxes (but excluding the amount of any deposit) which would be required to be paid–
(a) for an individual item of the product, where the product is sold by number
(b) for one kilogram of the product, where the product is permitted to be sold either by weight or by volume, and the product is marked to show only its weight
(c) for one litre of the product, where the product is permitted to be sold either by weight or by volume, and the product is marked to show only its volume
(d) in all other cases, for one kilogram, one litre, one metre, one square metre or one cubic metre of the product as appropriate.”
13․ In general, the purpose of the unit price is to enable consumers to compare the price of products per unit of measure, such as kilogram or litre, between similar items.
Example
If the selling price for box of cereal A is £3 and the packaged quantity which is for sale weighs 500 grams, the unit price is £6 per kilogram.
If the selling price for box of cereal B is £3 and the packaged quantity for sale weighs 2 kilograms, the unit price is £1.50 per kilogram.
If a purchaser wished to purchase the cheapest cereal, they could use the unit price information to compare the cost easily and purchase cereal B – recognising the cheaper unit price, regardless of the packaged quantity and the selling price.
14․ In the definition of ‘unit price’, paragraph (a) applies to items sold by number, for example, on a ‘4 apples pack’ sold at £3, unit price will be displayed as ‘£0.75 each’, whereas in a ‘2kg apples family pack’ sold at £3, unit price will be displayed as ‘£1.50 per kg’.
15․ Paragraphs (b) and (c) deal with the situation where a product is permitted to be sold either by weight or volume, but the product is marked to show only its weight or its volume.
16․ In these instances, it is recognised that there will be a need for the unit price to be displayed in either weight or volume- depending on the manufacturer’s labelling of the product. Whether displayed in weight or volume, the label must show the unit price per kilogram or litre as applicable.
Example
A bottle of tomato ketchup can be sold in the UK by either weight or volume.
A supermarket may stock bottles of tomato ketchup which are made by different manufacturers – some of which describe the content of the bottle by weight and some by volume.
Bottle A is 500g and costs £1, bottle B is 500ml and costs £2, and bottle C is 2kg and costs £3. The unit price for these can displayed accordingly a) £2 per kg, b) £4 per litre, c) £1.50 per kg.
17․ In addition to the requirements to display selling and unit prices, whilst there are exemptions to when unit pricing must be displayed (see Article 9 on general reductions and Schedule 2), to assist consumers to make informed choices, traders should endeavour to display the unit price, as well as the selling price, for promotional items including price reductions and multi-buy promotions.
Deposit
18․ The new definition of ‘deposit’ is:
“’deposit’ has the meaning which–
(a) in the case of England and Wales, is set out in paragraph 1(2)(a) of Schedule 8 (deposit schemes) to the Environment Act 2021
(b) in the case of Scotland, is set out in section 84(2)(a) (deposit and return schemes) of the Climate Change (Scotland) Act 2009.”
19․ The ‘deposit’ is expressly excluded from the amended definitions of ‘selling price’ and ‘unit price’.
20․ Under future legislation to be introduced across each nation of the UK, a trader will be required to charge the purchaser of certain items, such as a plastic drink bottle, a ‘deposit’. This will be in addition to the selling price as defined in the PMO.
21․ The information about the deposit will be governed by the legislation in each nation and will be required to be displayed separately from the selling price and the unit price.
22․ The PMO 2004 (as amended) excludes the deposit from the definition of ‘selling price’ and ‘unit price’. This is as the ‘deposit’ will be an extra returnable payment to be made in addition to the price, and which will not necessarily depend upon the weight or volume purchased.
Small shop
23․ ‘Small shop’ is defined as:
“’small shop’ means any shop which has a “relevant floor area” not exceeding 280 square metres.”
24․ ‘Relevant floor area’ is defined in relation to a shop as
“the internal floor area of the shop excluding any area not used for the retail sale of products or for the display of such products for retail sale.”
25․ The definition of ‘small shop’ as set out in PMO 2004 has not been amended by PMO 2024.
26․ The definition of ‘small shop’ is important, within the scheme of the legislation, because they are excluded from the requirement to display unit price-for products which are pre-packaged in constant quantities.
Examples
A shop has a ‘relevant floor area’ of 250 square metres – it is required to show the selling price under article 4.
A shop has a ‘relevant floor area’ of 290 square metres – it is required to show both the selling price and the unit price under articles 4 and 5.
Article 2: revocation
27․ Article 2 PMO 2004 revoked the Price Marking Order 1999.
Article 3: scope of application of the current PMO 2004
28․ Article 3(1) sets out what is outside the scope of the order.
29․ Article 3(1)(a) provides that the PMO does not apply to products which are supplied in the course of the provision of a service.
Example
A chemist which sells shampoo is required to indicate the selling price and possibly the unit price (depending upon the size of the store as defined under Article 1).
A hair salon which uses shampoo and conditioner during a wash and haircut (service) is not required to show selling price or unit price.
A hair salon which has a shelf of hair products on display to buy to take home is required to indicate selling price and possibly unit price (depending upon the size of the premises as defined under Article 1).
30․ Article 3(1)(b) states that the PMO does not apply to:
- sales by auction
- sales of works of art or antiques
Article 4: obligation to indicate selling price
31․ As a general rule, where a trader indicates that any product is or may be for sale to a consumer, they must indicate the selling price of that product in accordance with the provisions of the PMO. The general duty to indicate the selling price is subject to the provisions set out in Articles 9 (general reductions) and 10 (special provisions re precious metals).
32․ However, a trader is not required to indicate the selling price in respect of:
(a) products sold from bulk
(b) an advertisement for a product
33․ The order does not require advertisements to show a selling price, but some advertisers might choose to include one. If they do, the advertisement must also show a unit price where one is normally required under the terms of the order.
34․ However, selling and unit prices are always required (notwithstanding any other exemptions) when the advertisement is actually inviting consumers to conclude a distance contract as opposed to merely seeking to encourage them to visit another retail outlet where prices will be displayed. Examples of advertisements that invite consumers to conclude a distance contract are mail order advertisements in newspapers and goods sold direct from the Internet or the media. Catalogues do not fall within the definition of advertisement and are required to show selling and unit prices as relevant.
Article 5: obligation to indicate unit price
35․ As a general rule, where a trader indicates that any product is or may be for sale to a consumer, they must indicate the unit price of that product in accordance with the provisions of the PMO.
36․ This requirement only applies in respect of products sold from bulk or required by certain legislation to be marked with an indication of quantity or made up in a prescribed quantity.
The relevant legislation is:
- Part IV of the Weights and Measures Act 1985,
- Regulations 5, 6, or 7 of the Weights and Measures (Packaged Goods) Regulations 2006
- Article 9 of Regulation (EU) No. 1169/2011 of the European Parliament and of the Council on the provision of food information to consumers
37․ Paragraph 5(3) sets out that the Article 5(1) requirement to show the unit price, does not apply in relation to:
(a) any product which falls within Schedule 2
(b) any product the unit price of which is identical to its selling price
(c) bread made up in a prescribed quantity which is or may be for sale in a small shop, by an itinerant trader or from a vending machine
(d) any product which is pre-packaged in a constant quantity which is or may be for sale in a small shop, by an itinerant trader or from a vending machine
38․ Note that this exception does not apply to products sold from bulk.
39․ Paragraph 5(4) states that “The requirement to indicate the unit price applies in relation to an advertisement for a product only where the selling price of the product is indicated in the advertisement.”
Schedule 2 products in respect of which a trader is exempt from the requirement to unit price
40․ Schedule 2 of the PMO sets out 4 circumstances where the Article 5 requirement to show the unit price does not apply. Paragraph 3 of Schedule 2 has been substituted under the PMO 2025.
Schedule 2(1)
“Any product which is offered by traders to consumers by means of an advertisement which is:
(a) purely aural
(b) broadcast on television
(c) shown at a cinema
(d) inside a small shop”
Schedule 2(2)
“Any product the price of which has been reduced from the usual price at which it is sold, on account of:
(a) its damaged condition
(b) the danger of its deterioration.”
Example
A loaf of sliced white bread is usually sold at £1.39 for 800g. The shelf edge label would display both the price and the unit price (£1.39 and £1.75 per kg). The bread expires today and is being sold at 10 pence. The reduced price would require displaying but the reduced unit price would not.
Schedule 2(3)
“Any product which comprises an assortment of items–
(a) which are either sold in a single package or at a lower price if a prescribed number or combination of items are purchased together and at the same time
(b) where some of the items are sold–
(i) according to weight and some according to volume
(ii) at different prices
(iii) at different weights or volumes
when sold separately.”
41․ This updates the original exemption, as it appeared in the PMO 2004 -“Any product which comprises an assortment of different items sold in a single package.”
Example 1
A trader is running a ‘Dine in for 2 for £20’ deal. Customers can pick a bottle of wine, starter, main, and dessert from a range of indicated items. The items include a mixture of products. These items can also be bought separately outside the package deal. The selling price and unit price that these items can be bought individually must be displayed under the general rules. However, the unit price for the each of the items, as part of the package deal, would not need to be set out.
Example 2
A trader is running 25% off any 6 bottles of wine. The items included in the offer are all sold in volume but vary in price. Each bottle can also be bought separately outside the prescribed offer number of 6 (for example, a customer could buy 2 bottles and wouldn’t benefit from the 25% off). The price and unit price that these items can be bought individually must be displayed. However, the unit price for each bottle when bought as part of the offer of 6 bottles at a reduced price would not need to be set out.
Example 3
A trader is running a 2 for £3 on all own brand crisps. The crisps are all priced at £2 each and are all the same weight. The crisps can be bought individually or as part of the deal. This would not benefit from the unit price exemption (which is set out in Schedule 2) as the crisps are all sold at the same selling price and weight when individually priced. As a result, the ‘offer’ selling and unit price would need to be displayed in addition to the regular product selling and unit price.
Schedule 2(4)
“Any product the unit price of which is 0 pence as a result of Article 12 (Decimal places and rounding of unit prices).”
42․ In addition, the general duty on a trader to indicate the unit price is subject to the provisions of Article 9 (general reductions).
Articles 6, 7, and 8: manner of indication of selling price and unit price
Article 6: foreign currency
“Where a trader indicates a willingness to accept a foreign currency for the purchase of a product the order provides that, in addition to the sterling price indication, further specific information must also be given about exchange rates, commission etc.”
Article 7: presentation of information
43․ Article 7(1) provides that
“An indication of selling price, unit price, commission, conversion rate or a change in the rate or coverage of value added tax (VAT) given in accordance with article 11 must be–
(a) unambiguous, easily identifiable, clearly legible, and displayed using a font which is clear and of reasonable size
(b) subject to paragraph 2, given in proximity to:
(i) the product
(ii) in the case of distance contracts and advertisements, a visual or written description of the product
(c) so placed as to be available to consumers without the need for them to seek assistance from the trader or someone on his behalf in order to ascertain it”
44․ The PMO 2004 does not require each item to be price marked individually. Prices can be shown on the goods themselves, or on a ticket or notice on or near to them.
45․ Article 7(1)(a) has been amended by the PMO 2024 so that it refers to a font which is clear and of a reasonable size.
46․ Legibility of price indications in this context means legible to a consumer that is not sight impaired. Traders are, however, reminded of their obligations under the Equality Act 2010 and to take account of the particular needs of people with protected characteristics, such as the elderly, and persons with disabilities. Traders may wish to take account of the Royal National Institute for the Blind’s Clear Print Guidelines. Online retailers may also wish to refer to the Web Content Accessibility Guidelines (WCAG).
47․ It is recognised that retailers may meet these requirements in different ways and in accordance with their own in-house style and pricing templates. The following suggestions are provided as guidance to what may be considered unambiguous, easily identifiable and clearly legible, displays:
(a) Fonts should be clear and easily comprehensible.
(b) Consider using as large a letter height as possible with adequate spacing.
(c) Consider using white space or, where white space is limited, other methodologies to create an illusion of space.
(d) The unit price may be a smaller size than the selling price to avoid potential confusion but should still be clear and easily comprehensible.
(e) The unit price text may follow the same direction as the selling price- as opposed to on an angle or curved.
(f) The type face and size of the selling and unit price may be larger and more prominent than information provided for the use of retail colleagues.
(g) Text wrapping should be avoided and the unit price presented on a single line.
(h) There may be benefits in making label design and layout, where practicable, consistent across the store.
(i) Notwithstanding the use of brand palettes and fonts, where products are offered at more than one selling price, such as loyalty card schemes, care should be given to not give one set of prices prominence over the other.
48․ Where traders operate both online and instore pricing systems and it is not possible to alter one independently from the other, information provided to customers in all these instances should be clear, transparent, and in line with the legislative requirements.
49․ Article 7(2) says that
“Article 7 (1)(b)(i) does not apply to an indication given in relation to any item of jewellery, item of precious metal, or watches displayed in a window of the premises where it is or may be for sale and the selling price of which is in excess of £3,000.”
50․ Paragraph 3 states
“The indication of any freight, delivery or postal charges for a product, including any taxes payable in respect of freight, delivery or postal charges, must be unambiguous, easily identifiable, and clearly legible.”
51․ Paragraph 4 states that
“Where, in addition to a unit price, a price per quantity is indicated in relation to a supplementary indication of quantity the unit price must predominate and the price per supplementary indication of quantity shall be expressed in characters no larger than the unit price.”
52․ In paragraph (4) “supplementary indication of quantity” refers to an indication of quantity expressed in a unit of measurement other than a metric unit as authorised by section 8(5A) of the Weights and Measures Act 1985.
Article 7A: the offer of a product at more than one selling price
53․ Article 7A was inserted by the PMO 2024. It deals with the situation where the same product is sold at different prices to different consumers, for example, where members of a loyalty scheme are permitted to buy products more cheaply than those purchasers who are not members of a loyalty scheme or multibuy offers that do not meet the unit price exemption criteria in Schedule 2(3).
54․ The article requires a trader, who proposes to sell products to which the PMO applies at more than one selling price, to indicate in accordance with articles 4(1) and 5(1):
“(a) each selling price and each unit price applicable to the product
(b) whether the availability of a particular selling price is subject to the satisfaction of certain conditions, and, if so, the trader must prominently display those conditions–
(i) in a form which is unambiguous, clearly legible, easily identifiable and available to consumers without the need for them to seek assistance
(ii) in close proximity to the product”
Example 1
A trader offers a product at £2 to the general purchaser and at £1 to the holder of a loyalty card. Both the ‘normal’ and ‘loyalty’ selling price and unit price must be displayed together with an indication of the conditions which need to be satisfied in order to obtain a particular price (for example, ‘with loyalty card’).
Example 2
A retailer runs an offer on boxes of a single brand of cat food. The boxes are all the same weight and the same price. The boxes are £4 each or 2 for £7. As this does not meet the criteria of Schedule 2(3), both the individual and the offer selling and unit price would need displaying.
Article 8
55․ This article states that
“In the case of a pre-packaged solid food product presented in a liquid medium, the unit price must refer to the drained net weight of the product. Where a unit price is also given with reference to the net weight of the product, it must be clearly indicated which unit price relates to drained net weight and which to net weight.”
Article 9: special provisions relating to general reductions
56․ Article 9 applies to general reductions. Rather than requiring previous indications of selling and unit prices to be changed- it allows for the information to be given by a general notice or other visible means provided it meets certain criteria including around display and legibility and so on.
57․ The PMO 2025 clarified when Article 9 may be relied upon – that being where the characteristics of the general reduction mean it is not reasonably practicable to indicate the reduced selling price or unit price in accordance with articles 4(1) and 5(1) for each of the products falling within the reduction.
58․ Customers should be provided with the information they need to make informed choices when making purchases, and the obligations in articles 4 and 5 of the PMO 2004 recognise this. However, when retailers operate general reductions applying simultaneously to many different products, there will be circumstances where changing individual prices will not be reasonably practicable- most notably with large scale, time limited, or multi layered discounts such as the example given. In these circumstances, Article 9 may be relied upon. This ensures that retailers are not prevented from offering the proposed reduction by an impracticable administrative burden.
59․ While the examples below give guidance as to where Article 9 may or may not be relied upon, the government considers ‘not reasonably practicable’ to be a high threshold, not to be relied upon where individual repricing is merely inconvenient. Where a general notice has been used, retailers should be sufficiently prepared to explain their decision and rationale for its use to enforcers if and when required.
Example 1
A store that stocks a number of different ranges of paint sold in different sizes runs 20% off all paint over a bank holiday weekend. A sign reading ‘20% off all paint’ is displayed on a hanging banner in the corresponding aisle.
Due to the short period of the offer and the range of paint included, it would not be reasonably practicable to alter the prices. Therefore, the individual selling price and unit price of the included items would not need altering.
Example 2
A store runs an offer on one brand of make-up. Signs are erected at various contact points that details ‘Spend £50 on x brand, get 10% off. Spend £70, get 20% off’.
Due to the nature of the offer, it would not be reasonably practicable to alter all the prices to reflect all levels of discount. The individual selling price and unit price of the included items would not need altering.
Example 3
A pet shop sells multiple brands of cat litter. They run a planned offer for the month of December of 25% off one brand of cat litter. As the offer applies to specific products with a set reduction, it would be reasonably practicable to update point of sale. Changes should be made to the prices to allow consumers to compare.
Article 10: Special provisions relating to precious metals
60․ This article states that
“In the case of products the selling price of which varies from day to day according to the price of the precious metals contained in them the obligation to indicate the selling price, which is set out in article 4(1) may be complied with by indicating in a manner which is unambiguous, easily identifiable and clearly legible:
(a) the weight, type and standard of fineness of each precious metal contained in the product
(b) any element of the selling price which is not referable to weight,
accompanied by a clearly legible and prominent notice stating the price per unit of weight for the type and standard of fineness of each precious metal contained in the product”
Article 11: change in VAT or any other tax
61․ This article states that
“Where there is a change in the rate or coverage of VAT or any other tax, a trader who adjusts his prices in consequence may comply with the provisions of the PMO
(a) by means of a general notice or notices for a period of 28 days from the date any such change takes effect, indicating that any products subject to that change are not for sale at the price indicated and that such price will be adjusted to take account of the change
(b) if he continues to distribute any catalogue or sales literature printed or ordered to be printed before a change is announced and there is firmly attached to it a label which prominently states that some or all of the prices printed in it are to be adjusted to reflect the change, and:
(i) the label includes sufficient information to enable consumers to establish the adjusted price of any product listed
(ii) the label refers to and is accompanied by a supplement which enables them to do so”
Articles 12 and 13: decimal places and rounding of unit prices
62․ Article 12 provides that
“where the unit price of a product falls below £1 it shall be expressed to the nearest 0.1 pence. Where the figure denoting one hundredths of one penny in the unit price is 5 or higher, it shall be rounded up and where it is 4 or lower it must be rounded down.”
63․ Article 13 provides that
“where the unit price of a product falls above £1 it may be expressed to the nearest:
(a) one pence, in which case where the figure denoting tenths of one penny in the unit price is 5 or higher, it shall be rounded up and where it is 4 or lower it must be rounded down
(b) 0.1 pence, in which case where the figure denoting one hundredths of one penny in the unit price is 5 or higher it shall be rounded up and where it is 4 or lower it must be rounded down”
Enforcement
Criminal enforcement
64․ The Prices Act 1974 provides that anyone contravening an order made under s4 of the Act shall be guilty of a criminal offence, and liable to a fine of an unlimited amount (see s. 7 and paragraph 5 of the Schedule). Criminal enforcement of the PMO may only be undertaken by trading standards (paragraph 8 of the Schedule).
Civil enforcement
65․ The Price Marking Order is listed in Schedule 15 to the Digital Markets, Competition and Consumers Act (DMCCA), and is available to all public and private designated enforcers. In practice this means the Competition and Markets Authority (CMA), trading standards and the sector regulators can bring a civil court case for an order under Part 3 DMCCA. Such an order can impose directions, require the trader to pay redress or take other steps to improve choice and compliance, and impose fines of up to £300,000 or 10% of the trader’s global turnover (whichever is higher). In addition, Which? (the only private enforcer designated at the time of this guidance) can bring a civil action under Part 3 DMCCA, but can only obtain an order which imposes directions.
66․ The PMO is also listed in Schedule 16 to the DMCCA, meaning that the CMA can enforce the PMO directly (without having to go to court) under its powers in Chapter 4 of Part 3 DMCCA. The outcomes of such enforcement proceedings are basically the same as with a civil court case, including the level of fines.
67․ For further information on Part 3 enforcement powers, see the CMA’s guidance.
Enquiries
68․ Enquiries about provisions of the PMO 2004 may be addressed to your local trading standards department.
Copies
69․ Copies of the legislation may be purchased from the TSO Shop.
Department of Business and Trade
Consumer and Competition Policy Directorate
Old Admiralty Building
Whitehall
London
SW1A 2DY