The Price Marking Order 2004 (PMO) took effect in 2004 to provide greater transparency to consumers about the prices of goods. Unless an exemption applies, the PMO requires the selling price of a product to be displayed and sets out the circumstances in which a product must clearly display a unit price too. On 22 September 2025, the government issued guidance entitled: Price Marking Order 2004: government guidance - GOV.UK (the Guidance) reflecting amendments made to the PMO by the Price Marking (Amendment) Orders 2024 and 2025 (the PMO Amendments) which take effect from 6 April 2026.

The PMO and Guidance 

The PMO, applicable in Great Britain and limited to sales between traders and consumers (inclusive of online sales as well as physical shops) requires the transparent display of the selling price and, where applicable, the unit price so consumers can make like‑for‑like comparisons. The Guidance only applies in Great Britain; in Northern Ireland, the Price Marking Order (Northern Ireland) 2004 applies. The Guidance further includes useful examples of how traders might apply the provisions in practice, for example:

“If the selling price for box of cereal A is £3 and the packaged quantity which is for sale weighs 500 grams, the unit price is £6 per kilogram. If the selling price for box of cereal B is £3 and the packaged quantity for sale weighs 2 kilograms, the unit price is £1.50 per kilogram. If a purchaser wished to purchase the cheapest cereal, they could use the unit price information to compare the cost easily and purchase cereal B – recognising the cheaper unit price, regardless of the packaged quantity and the selling price.”

Key aspects of the Guidance include: 

• Clarification of key definitions - The amendments to the PMO include revised definitions of the terms "selling price" and "unit price" and introduce a new defined term of "deposit". The Guidance gives examples of what these terms mean in practice and how to calculate a unit price. It explains that deposits are not part of the unit or selling price.
• Explanation of the obligation to display unit pricing - The Guidance gives practical examples of when the obligation to display the unit price arises and when it does not, including addressing, for example, the position when the business offers goods as part of a package or reduces the price of a product because of damage or deterioration.
• Presentation - Prices must be unambiguous, easily identifiable, clearly legible, displayed using a font which is clear and of reasonable size 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. Prominence should not be given to one set of prices over another. The Guidance offers suggestions as to how to achieve these standards, for example, regarding the size of letters and use of white space. It notes that the unit price may be of a smaller size than the selling price to avoid potential confusion but should still be clear and easily comprehensible.
• The rules on general reductions – rather than requiring previous indications of selling and unit prices to be changed, it allows general notices to be used in certain circumstances where criteria around display and legibility are met – for example, where the offer applies to specific products with a set reduction, it would be reasonably practicable to update the pricing on the affected products.
• Accessibility  - The Guidance reminds traders about their obligations under the Equality Act 2010 when displaying prices and that they need to take account of the particular needs of people with protected characteristics, such as the elderly, and people with disabilities. Traders may wish to take account of the Royal National Institute for the Blind's Clear Print Guidelines. Online retailers may also wish to refer to the Web Content Accessibility Guidelines (WCAG).

Take aways and penalties

Traders should refer to the Guidance for practical application of their pricing and display of products online and in store. Traders might, for example, update in‑store and online materials such as signage, product labels, loyalty pricing displays and assortment promotions ahead of 6 April 2026. 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.