After Black Friday, Your Christmas Discount Starts From the Black Friday Price

Note: this post gives general information about the prior price rule. It is not legal advice. For your own store's situation, check with your legal adviser.

eMAG held Black Friday 2026 on 6 November, as it had announced back in September. If you went through the 9 Black Friday checks, your campaign's struck-through price started from the lowest price of the 30 days before. Now the Christmas campaign is coming, and the same rule works the other way round: the Black Friday price enters the 30-day window and, in most cases, becomes the new reference price.

In short: if your Christmas reduction starts less than 30 days after the last day you sold at the Black Friday price, the percentage you show is calculated from the Black Friday price, not from the full price.

The rule, in the law's own words

In Romania the rule is article 4¹ of Government Decision (HG) 947/2000 on price indication, added by HG 686/2022 and applied since 28 May 2022. Paragraph 2 says (our translation): "The prior price is the lowest price applied by the seller in the same sales area during the last 30 days before the date the price reduction is applied."

The law makes no distinction between a full price and a reduced one. If the product sold for 399 lei on Black Friday, those 399 lei are a price that was applied. The European Commission's 2021 guidance, which explains the directive the rule comes from, says so directly: the lowest price in the window includes the reduced prices of earlier promotions. As its example, the guidance names the successive Black Friday, Cyber Monday and Christmas campaigns of November and December.

The calendar: how long the Black Friday price counts

The window counts back 30 days from the day before the reduction. For a reduction that starts on 1 December, the window runs from 1 to 30 November.

An invented example: a product costs 499 lei and was not reduced in October. On Black Friday you sold it for 399 lei, from Friday 6 November to Monday 9 November. On 10 November it went back to 499 lei. For Christmas you want to sell it for 349 lei.

• 1 December: 30-day window 1 to 30 November; prior price 399 lei; 349 lei means a 12.5% reduction
• 9 December: 30-day window 9 November to 8 December; prior price 399 lei; 349 lei means a 12.5% reduction
• 10 December: 30-day window 10 November to 9 December; prior price 499 lei; 349 lei means a 30% reduction

The calculation changes on 10 December, 31 days after the last day of Black Friday, and only if there was no other reduced price in the meantime. If the Black Friday price lasted a single day, 6 November, that day is 7 December. Three situations are worth checking product by product:

• The full price struck through too early. A reduction that starts on 1 December at 349 lei, with 499 lei struck through and "-30%" next to it, shows a bigger reduction than the real one. Against the prior price, the reduction is 12.5%.
• A Christmas price above the Black Friday price. 429 lei looks like a reduction from 499, but before 10 December the prior price is 399. A price higher than the prior price cannot be announced as a reduction.
• The other promotions in the window. A Cyber Monday price, or a one-day campaign in November, counts just like the Black Friday price. The lowest of them is what matters.

If you push the campaign back to 10 December to show the percentage against the full price again, you are left with fewer delivery days before Christmas. Public holidays and courier schedules are in our post on Christmas delivery.

The exception: one campaign, with reductions that only grow

Paragraph 5 of the same article has an exception (our translation): "If the price reduction is increased step by step during the same reduction campaign, the prior price is considered to be the price without the reduction before the first application of the price reduction."

Another invented example: a holiday campaign starts on 6 November at 449 lei (10% off 499), drops to 399 lei on 27 November (20%) and to 349 lei on 11 December (30%). The price does not go back to 499 lei until the campaign ends. In this case the prior price stays 499 lei for the whole campaign, and the 20% and 30% are calculated from it.

The Commission's guidance asks for the exception to be read narrowly: it applies only when the price is reduced progressively, without interruptions and without the indicated prior price going up along the way. That has three practical consequences:

• One day at full price breaks the campaign. From that moment, every new reduction is measured against the lowest price of the last 30 days.
• Two campaigns announced separately stay two campaigns. Black Friday, then Christmas, with the full price in between, means the general rule, not the exception. The guidance allows a campaign to be extended, as long as you tell shoppers clearly that it is an extension and not a new campaign.
• The text speaks of a reduction that is increased step by step. A reduction that gets smaller along the way doesn't fit that description. If your plan looks like that, discuss it with your legal adviser before launch.

If the price has already gone back to full after Black Friday, the exception can no longer join the two campaigns.

What is at stake

Article 12 paragraph 2 of HG 947/2000 punishes a breach of article 4¹ with a fine of 5,000 to 30,000 lei. Inspections are done by inspectors of ANPC, Romania's National Authority for Consumer Protection, under article 13. When the fine is set, the nature, gravity, extent and duration of the breach and the trader's earlier breaches are among the criteria.

The store proves its prior price, with its own records, when ANPC asks. Magento Open Source doesn't keep a price history, so without a module that keeps one, or daily exports kept with their dates, the proof is missing.

How to check one product

Pick one product from your Christmas campaign and go through 6 steps:

1. Note the date the reduction starts and count 30 days back from the day before. That is the window.
2. Collect every price in the window: the regular price, the special price with its dates (in the product's Advanced Pricing), the catalog price rules active on those days (Marketing > Catalog Price Rule) and the daily price exports, if you kept them after the Black Friday post.
3. Find the lowest price. That is the prior price.
4. Compare it with the struck-through price on the page. On a standard Magento store, the struck-through price is the "price" attribute, meaning the regular price, not the lowest of the last 30 days. In the example above, a standard store would show 499 lei struck through on 1 December.
5. Recalculate the percentage from the prior price and check that the label on the product page and the one in the product listing show the same percentage.
6. Keep the proof: a dated export at the start of the campaign, covering every product in it.

For products on sale for less than 30 days, paragraph 4 requires the lowest price since launch, and that period must be shown.

On Magento and Hyvä

The Omnibus module we use keeps the lowest price of the last 30 days for every product, recalculates it when the price changes, and shows it on product pages and product listings. It is compatible with Hyvä and is installed together with the GPSR module as the EU Compliance Pack, described in our post on GPSR and Omnibus. The price is available on request.

The official texts

This post is not legal advice. The texts it relies on are HG 947/2000 in its consolidated form, articles 4¹, 12 and 13, and the European Commission's guidance on article 6a of Directive 98/6/EC, section 4.3.

Want to check one product from your Christmas campaign together? Book a free 30-minute strategy call. We'll look at its prices over the last 30 days and at what the product page shows.