Shelf price rules and electronic shelf labels in the UK

In the UK, a retailer must show the selling price and, for most goods sold by weight or volume, a unit price that is unambiguous, easily identifiable and clearly legible, near the product. A “was” price or other comparison must not mislead. None of this depends on the medium, so an electronic shelf label simply changes how a store complies.

This page maps the rules that touch the shelf price in Great Britain, with a note on the EU rules that still matter for suppliers. It is written for store and pricing managers, it is not legal advice, and medicine pricing is out of scope. The legislation was read on 9 November 2026; a solicitor’s review is still pending (see the end of the page).

A note on scope: this site’s English pages are written for UK readers. If you operate in Ireland or elsewhere in the EU, the rules differ, in particular the EU 30-day reference-price rule that does not appear in the UK texts below.

The rules at a glance

Topic	Rule	What it asks	Where to read more
Selling price and unit price	Price Marking Order 2004, arts 4 to 7	Show both, legibly, near the product	This page
Misleading prices and comparisons	DMCC Act 2024, Part 4	Do not mislead on price, including “was” prices	Reference pricing
Shelf versus till	Same misleading-actions rules	The price shown must be the price charged	Shelf versus till
Dynamic or personalised prices	Consumer law transparency	Frequent changes are not banned; personalised pricing needs care	Dynamic pricing
Device batteries	Regulation (EU) 2023/1542, art. 11	Removable and replaceable, from 18 February 2027 in the EU	Environment and ESL

Selling price and unit price: the Price Marking Order 2004

The Price Marking Order 2004 (SI 2004/102) is the rule that shapes a label most directly. Article 4 requires a selling price; article 5 requires a unit price whenever a trader indicates that a product is or may be for sale to a consumer, with limits. The unit price duty applies to products sold from bulk, or products that weights-and-measures law requires to be marked with a quantity or made up in a prescribed quantity. It does not apply where the unit price equals the selling price, and in an advertisement it applies only if the advertisement states the selling price.

Schedule 2 lists the exempt products:

• Products advertised through purely aural ads, television, cinema or inside a small shop.
• Products reduced in price because they are damaged or at risk of spoiling.
• Packs of several different items sold together.
• Products whose unit price rounds to 0.0p.

This list was checked against the Schedule as made in 2004; later amendments may have changed it, so read the current version before relying on it.

How it has to look

Article 7 is the one that constrains a label. Indications of selling price and unit price must be unambiguous, easily identifiable and clearly legible. They must be near the product (or near a description of it for distance sales and adverts), and visible without the consumer having to ask. Where a price per quantity appears alongside the unit price, the unit price must be more prominent, and the other price must use no larger characters.

For an ESL this has practical consequences. The unit price should not sit on a second screen that must be pressed, or behind a QR code. And if a label shows a multi-buy price per item next to a per-kilo price, the per-kilo figure has to win on prominence. These are our inferences from the wording, not quotations, and label templates should be checked by whoever advises you on compliance.

Prices must be in sterling (article 6), and the order sets out what a trader must show if it also accepts foreign currency.

“Was” prices and reference pricing

This is where the UK differs most from the EU. The EU’s Omnibus Directive (EU) 2019/2161 requires a price reduction announcement to show the lowest price applied in the previous 30 days. We found no equivalent fixed period in the UK legislation we read. In Great Britain, price comparisons are judged under the unfair commercial practices rules in Part 4 of the Digital Markets, Competition and Consumers Act 2024. Section 226 defines a misleading action as false information, or true information presented in a way that is likely to deceive the average consumer.

How that applies to a reference price is explained in official guidance, which has been updated since the DMCC Act: the CTSI guidance for traders replaced the government’s 2010 Pricing Practices Guide, and the CMA has published guidance on price transparency. We have not read those documents in full for this page, so the safe route is to read the current versions before setting a promotion policy. The CTSI guidance is listed in our sources.

What an ESL changes is the audit trail. If your prices move often, a “was” price that was genuinely charged for a meaningful period is much easier to defend with a per-article price history than without one. Whether any given platform keeps such a history is something to ask the vendor. The detailed analysis sits on the reference pricing page.

What the shelf shows and what the till charges

The misleading-actions provisions work in both directions: a shelf price lower than the till price is a classic complaint, and the trader carries the consequences. A sync lag between label and till is therefore not a purely technical point. It is a gap between what you advertised and what you charged. Shelf versus till covers what to do when synchronisation fails.

Dynamic and personalised pricing

Nothing we reviewed prohibits changing a shelf price several times a day. What matters is that the displayed price is the charged price and that comparisons are honest. A price that differs by customer, for example through an app, raises different questions under the consumer rules, and those are discussed on the dynamic pricing page. We did not verify the UK position on personalised pricing for this page.

Batteries

An ESL contains a battery. Regulation (EU) 2023/1542 generally applies from 18 February 2024, with article 11 from 18 February 2027. It requires portable batteries incorporated into products to be readily removable and replaceable by the end user with commercially available tools, with exceptions. That applies to products placed on the EU market (and, under the Northern Ireland arrangements, potentially there too), but we have not verified how Great Britain treats the same requirement. A UK retailer buying from a manufacturer that also sells in the EU will often meet the question through that supplier. Whether a particular label falls under article 11 depends on the model, and we cannot say without manufacturer data. See Environment and ESL.

Enforcement

Local authority trading standards services enforce the Price Marking Order, and the CMA now has direct enforcement powers under the DMCC Act. Secondary sources describe fines of up to 10 per cent of global annual turnover for breaches of UK consumer law; we have not confirmed the exact provision, so treat that figure as indicative and check the Act.

A checklist for the shelf

An operational summary derived from the above, not from official guidance:

1. Every product on sale shows its selling price including VAT.
2. Where required, the unit price appears on the same label, legible and without interaction.
3. Exempt products and non-standard units are configured in the master data.
4. Every “was” price reflects a price genuinely charged, and the price history is retained.
5. The shelf price and the till price match, and the store can show it.
6. Advertising that states a price also states the unit price where it applies.
7. The manufacturer has confirmed whether the labels’ batteries fall under article 11.

What is still open

This page has not been reviewed by a solicitor. Several points above rest on short digests or secondary sources and are flagged as such. This site is published by Keonex, as explained on About this site; regulation is described by the same standards for every vendor, as set out in the methodology.

If you are costing a rollout, the total cost calculator shows the effect of manual price-change labour, and what an ESL is explains how the technology works.