Black Friday started on 1 November. Which price is the discount cut from?

On 1 November, 26 days before Black Friday, 13 retailer storefronts in ten European markets were already showing Black Friday labels, up from 7 the day before. EU law measures a discount from the lowest price of the previous 30 days. For a cut announced on 27 November, 26 of those 30 days now fall inside a sale that has already started.

The rule: a discount starts from the 30-day low

Since 28 May 2022, article 6a of the Price Indication Directive (98/6/EC, added by the Omnibus Directive 2019/2161) has applied across the EU. A shop that announces a price reduction must show the "prior price". The directive defines it as "the lowest price applied by the trader during a period of time not shorter than 30 days prior to the application of the price reduction".

For a while, many retailers read this as a disclosure duty. They printed the 30-day low somewhere on the page and kept calculating the percentage from the last regular price. On 26 September 2024 the Court of Justice of the EU closed that gap in case C-330/23, Aldi Süd. A German consumer association had challenged a brochure in which bananas were offered at EUR 1.29, with EUR 1.69 struck through, even though EUR 1.29 had been the lowest price of the previous 30 days. The Court held that any announced reduction, as a percentage or as a claim of an advantageous price, must be based on that 30-day low. As the law firm Lewis Silkin noted, the point is to stop shops from raising a price shortly before advertising a cut from it. Printing the 30-day low next to a percentage worked out from a higher price does not meet the rule.

When Black Friday starts on 1 November, the sale price itself becomes the benchmark that the real Black Friday cut is measured from.

13 storefronts, ten markets, 26 days early

Our daily readings of retailer homepages and deal pages found Black Friday labels at 7 storefronts on 31 October and 13 on 1 November. The new labels were Shein in Belgium, Ireland, the Netherlands, Portugal and Sweden, and CDON in Sweden. MediaMarkt in Belgium and the Netherlands, Lidl in Germany, E.Leclerc in France, Euronics in Italy, Vobis in Poland and John Lewis in the United Kingdom carried the label on both days. Vobis and Morele in Poland also ran Black Week labels.

One detail matters for the rule. None of the 15 Black Friday promotions we recorded on 1 November stated a discount percentage on the page we read. All of them were event banners, such as a Black Friday sale on electronics or on fashion, plus one free-delivery offer. The 30-day rule bites at product level, on the struck-through price next to each item, not on the banner.

Starting early is not new. Press coverage of early Black Friday deals has grown edition after edition, as our three-year review of the headlines showed.

What does a month-long sale do to the reference price?

The arithmetic is simple. The prior price is set by the 30 days before the reduction begins, so it depends on when each cut starts.

Reduction starts	30-day window it is measured against	For a sale running from 1 November
1 November	2–31 October	all pre-sale prices
27 November (a new, deeper cut)	28 October–26 November	4 October days, 26 November days

For a product cut on 1 November, the prior price is its lowest October price. If a further cut is announced on Black Friday itself, the lowest price in its window is likely to be the November sale price, not the October one. Measured that way, a product reduced in early November and reduced again on 27 November can claim a smaller percentage than its banner might suggest.

There is one exception. Article 6a(5) lets each member state provide that, when a reduction is "progressively increased", the prior price stays the price before the first reduction. Whether a staged Black Friday counts as progressive depends on the national rules where the product is sold.

Shein was told to fix its discounts last year

Five of the 13 labels were Shein's. In May 2025, consumer authorities in the EU's Consumer Protection Cooperation network, coordinated by the European Commission and led by Ireland's Competition and Consumer Protection Commission, published findings that Shein's practices broke EU consumer law. The practices they listed included what they called fake discounts and false purchase deadlines. They gave the company a month to respond and propose commitments, the Law Society Gazette of Ireland reported.

That finding is the authorities' finding, not ours. What we can add is measurement. We read Shein's site in 10 markets on 1 November. The Black Friday label appeared in five of them: Belgium, Ireland, the Netherlands, Portugal and Sweden. It did not appear in France, Germany, Italy, Spain or the United Kingdom. We will check Shein's product prices against the 30-day rule in the same way as every other retailer's.

Why our price check has no verdicts yet

Our Omnibus price check re-reads each discounted product page once a day. It compares the reference price on the page, either the declared 30-day price or the struck-through price, with the lowest price we observed ourselves in the 30 days before the discount began. A discount is "consistent" when the reference is within 1% of our low. The check needs at least 5 observed days in the window before it judges anything. Progressive reductions and comparisons with a recommended retail price are counted separately and not judged.

On 1 November the check judged 0 discounts, because our scrape run captured 0 product-level discounts that day. That limits what we will be able to say. A product we first read on 1 November can be judged at the earliest for a discount that starts on 6 November. A product that was already discounted on the day we first read it has no pre-sale history in our data. We will count such products as unjudged rather than guess.

The question we can answer is the one that matters at the end of the month: when the Black Friday price arrives, is the reference next to it the lowest price we saw in November?

What to watch

• From 6 November: the first judgements, for products we start watching this week whose discounts begin afterwards. Daily figures by country appear on our price check page.
• Week of 16 November: two weeks of watched prices for the labelled storefronts. We will report the share of discounts consistent with the 30-day low, the median gap where they are not, and how many pages print a 30-day reference at all.
• 27 November: the test case, deeper Black Friday cuts measured against prices that have been on sale for most of the month.

How we measured this

Black Friday labels come from Dealmeteo's daily readings of retailer homepages and deal pages in 11 European markets on 31 October and 1 November 2026. On 1 November, 44 of the more than 150 storefronts we list returned a usable reading; the others were blocked, skipped under our crawling policy, empty or failed. A storefront counts as labelled when we recorded at least one promotion linked to Black Friday 2026. Shein's Belgian and Irish readings come from one shared storefront and are counted once per market. Price-check figures come from our Omnibus check of the same day (30-day window, at least 5 observed days, 1% tolerance). We report what we observed and make no legal findings.