Trading Standards and the CMA are now enforcing the rules, with big fines possible, experts have confirmed
New legislation affecting shoppers at the UK’s major supermarkets, including Tesco, Morrisons, Sainsbury’s, Asda, Aldi, Waitrose and Lidl, is now being ‘enforced’ this summer, according to experts. The significant change, which impacts supermarket aisles across the UK, came into effect in April — and trading standards teams are only now clamping down to ensure retailers are complying.
Under the new regulations, prices must be clearly displayed across all products, with standardised measurements introduced to cut through confusion and allow customers to compare costs more easily and gain a clearer understanding of savings schemes.
The reforms have broadened unit pricing requirements to cover additional products, including cereals, pasta, dried fruits, detergents, cleaning products and cosmetics, with metric measurements needing to be standardised — per kilo, litre, metre — regardless of the size of the product.
The government has confirmed that ‘public and private designated enforcers’ are now empowered to take action. It stated: “In practice this means the Competition and Markets Authority (CMA), trading standards and the sector regulators can bring a civil court case. 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.”
TPP retail said: “Failing to comply with UK price labelling laws carries legal, financial and reputational risks. Enforcement is primarily carried out by Trading Standards at a local level and the Competition and Markets Authority (CMA) using a combination of routine inspections, consumer complaint investigations and test purchasing to find non-compliance.
“Trading Standards officers regularly visit physical stores and review online businesses to ensure prices are clear, accurate and not misleading; this includes checking shelf-edge prices match those charged at the till. Consumer complaints submitted through the Citizens Advice Consumer Service often bring investigations, while test purchases are commonly used to confirm that displayed prices, promotions and sale claims are genuine. They also actively track websites, online marketplaces and social media advertising for hidden charges or fake discount comparisons.”
Retail law firm Lewis Silkin said: “Prices must be unambiguous, easily identifiable, clearly legible, and close to the product (or its description online). Both selling and unit prices must be displayed for promotional offers and loyalty discounts, unless an exemption applies. If a product is offered at more than one price (for example loyalty schemes), all applicable prices and the conditions for each must be clearly shown. Care should be given to not give one set of prices prominence over the other.”
Emma Thompson Senior Knowledge Lawyer Stevens and Boulton added: “It is worth noting that the Guidance also addresses enforcement, noting that enforcement may be both criminal and civil – including by the CMA under the Digital Markets, Competition and Consumers Act 2024. Criminal enforcement of the PMO may only be undertaken by trading standards with fines of unlimited amounts, and in respect of civil enforcement; fines of up to £300,000 or 10% of the trader’s global turnover (whichever is higher) may be imposed.”
Where shops present varying prices for identical products, such as through loyalty card reductions, they are required to clearly show both the regular price and the reduced price, with the terms for securing the lower rate displayed prominently alongside the item. The reforms are designed to enhance pricing transparency and simplify the process of comparing prices, obliging retailers to review their pricing structures, train their staff, and potentially redesign both in-store and online price displays.
When retailers offer different prices for the same product – such as a standard price and a discounted price for loyalty card members- they must:
- Clearly display both prices
- Explain the conditions required to obtain the lower price
- Show these conditions prominently near the product
- Apply this requirement to both selling prices and unit prices where applicable
For instance, if a retailer sells a product for £5 at the regular price, but £4 with a loyalty card, both prices must be prominently displayed alongside a clear explanation of the loyalty card requirement, positioned where shoppers can readily see it when browsing.
