Sale banners are a fixture of the pram market: a travel system marked “Was £400, now £250” looks like a bargain, but only if the higher price was a real price. Trading Standards guidance for traders explains how a saving claim is tested, and the same tests help a shopper judge a claim. This guide summarises the Chartered Trading Standards Institute (CTSI) guidance for traders on pricing practices, which it says was reviewed and updated in April 2026 and covers England, Scotland and Wales, together with the Competition and Markets Authority (CMA) letter to online sellers. It is general information, not legal advice, and it does not decide whether any particular price is misleading.
The rule behind the banner
The CTSI guide says pricing practices that are false or misleading, in a way likely to cause the average consumer to take a decision they would not otherwise have taken, are prohibited by the Digital Markets, Competition and Consumers Act 2024 (DMCCA). It defines reference pricing as price promotions that aim to show good value by referring to another, typically higher, price. Its rule of thumb is that if a promotion explicitly or by implication indicates a saving against another price, the trader must be able to satisfy itself that the quoted saving is genuine and therefore not unfair. The guide adds that consumers are unlikely to have recorded the earlier prices, so reference pricing calls for a high level of trust and integrity.
Four kinds of comparison
The guide lists four examples of reference pricing, all of which can appear on a pram listing:
- “was / now” prices, which compare the current price with a price the trader charged before;
- after-promotion or introductory prices, which compare with a price the trader intends to charge later;
- recommended retail prices (RRPs), which compare with a price suggested by the manufacturer or supplier; and
- external reference prices, which compare with another trader’s price for the same product.
How a “was” price is tested
The guide gives a non-exhaustive list of issues, each with a “more likely to comply” and “less likely to comply” pattern:
- How long the higher price applied. A comparison shown for a period that is the same or shorter than the period the higher price was charged is more likely to comply than one shown for a materially longer period.
- Where the higher price was charged. A comparison against a price never charged in that store is less likely to comply.
- How recently. A price charged less than two months ago with no intervening prices is the guide’s example of a genuine reference; prices charged many months earlier may no longer reflect the item’s current value.
- Season. A trader that sets a higher off-season price and then lowers it ahead of the expected demand is less likely to comply.
- Sales at the higher price. A retailer that repeatedly uses a reference price while knowing it did not sell a significant number of units at that price is less likely to comply.
RRPs and after-promotion prices
On RRPs, the guide says traders must take extra care, should clearly say the higher price is an RRP rather than a price they charged, and must not create an RRP purely to present the appearance of a discount. It says an RRP must represent a genuine selling price, and that traders should consider obtaining substantiation from suppliers. On after-promotion prices, the guide says the practice is likely to be considered unfair if the price is not subsequently increased to the advertised after-promotion price. For introductory prices, it says a “new” or “introductory” claim should not run so long that the price becomes the normal selling price.
What the CMA’s letter adds
The CMA’s 2023 open letter to online sellers was written when the earlier Consumer Protection from Unfair Trading Regulations 2008 applied, before the DMCCA replaced them, and the CTSI guide still points readers to it. It defines a price reduction claim as any discount or special offer price that refers to a higher comparison price, and gives worked examples of claims likely to mislead. Among them are: the higher price was charged only briefly compared with the time at the promotional price; very few items sold at the higher price; the price flip-flopped between two figures; the product had been sold at lower prices since the comparison price; the higher price was a short-lived hike; and the comparison price was charged a long time ago. It also says the higher price must be a genuine and realistic selling price that the business can demonstrate, and that conditions attached to an offer must be clear and prominent upfront.
Using this as a shopper
A shopper cannot see a retailer’s sales records, but a few checks follow from the tests. Note the “was” price and date when a listing first appears, take a screenshot before buying, and compare with the RRP and other retailers. The guide says the DMCCA is enforced by Trading Standards services in England, Scotland and Wales, and the site’s guides to who to contact and to false urgency banners cover related routes, and the guide to advertised pram prices covers delivery fees and the total price.
Frequently asked questions
Must “was” prices have been charged for a set number of days? The CTSI guide sets out factors rather than a fixed period; length, recency and sales volume are among them.
Is an RRP a price the shop charged? No. The guide says traders should tell consumers clearly that the higher price is an RRP.
Does this apply in Northern Ireland? The CTSI guide says it is for England, Scotland and Wales.
The bottom line
A “was” price on a pram should be a genuine, recent price at which the item really sold, not a figure created to make a sale look bigger. Trading Standards guidance tests length, recency, place and volume, and treats RRPs and after-promotion prices with the same caution, so treat the discount as a claim to check rather than a fact.