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# Shopify Omnibus Directive & Cookie Consent for Black Friday
- URL: https://productessentials.app/blog/shopify-omnibus-directive-lowest-price-30-days/
- Published: 2026-09-29T15:44:34.000Z
- Updated: 2026-10-18T08:41:45.000Z
- Description: Shopify Omnibus Directive and cookie consent for Black Friday: review prior prices, check your consent setup and schedule your sale.
- Author: The Disco Team
- Tags: Guides

Before Black Friday, stores selling to EU shoppers need three checks: Shopify cookie consent, prices that meet the Shopify Omnibus Directive, and a sale scheduled on time. The Omnibus rule makes your "was" price the lowest price you charged in the 30 days before the sale, from October 28 for a November 27 sale.

Consentmo covers consent, Complimus covers price history, and Disco runs the sale. Cookie consent is a privacy rule, separate from the Omnibus price rule. This is general information, not legal advice.

In this guide

1. [How do you set up Shopify cookie consent?](#how-do-you-set-up-shopify-cookie-consent)
2. [How does the Omnibus Directive apply to Shopify sales?](#how-does-the-omnibus-directive-apply-to-shopify-sales)
3. [How should Shopify stores show their lowest price from the last 30 days?](#how-should-shopify-stores-show-their-lowest-price-from-the-last-30-days)
4. [How does the Omnibus Directive affect Black Friday discounts?](#how-does-the-omnibus-directive-affect-black-friday-discounts)
5. [What should you check before launching your sale with Disco?](#what-should-you-check-before-launching-your-sale-with-disco)
6. [FAQ](#faq)
7. [When should you run these checks?](#when-should-you-run-these-checks)

## How do you set up Shopify cookie consent?

The easiest way to set up Shopify cookie consent is to use a Built for Shopify consent management app like Consentmo. It lets you configure where your cookie banner appears, control which trackers wait for consent, scan your store for tracking technologies, and test the setup before BFCM traffic arrives.

### Set up cookie consent with Consentmo

Consentmo helps Shopify merchants manage cookie consent and privacy requirements from one place. Merchants can configure region-specific cookie banners with Smart Geotargeting, scan their store for cookies and trackers, and control when analytics and marketing technologies load based on the visitor's consent.

![Consentmo cookie consent settings and storefront cookie banner for a Shopify store.](https://productessentials.app/content/images/2026/09/01-consentmo-cookie-consent-936c0fa8.png)

#### Three checks before launch

1. **Confirm where your banner should appear:** In Consentmo, review the privacy regions you have enabled and match them against the countries you will target with BFCM campaigns. Enable Smart Geotargeting so you only show the cookie banner where privacy laws require.
2. **View your Compliance Score:** Resolve any issues flagged in Consentmo's Compliance Score. All suggestions are on a per country basis - make sure your store follows all regulations in all the countries you sell in. Guided step by step recommendations!
3. **Scan and verify your campaign trackers:** Run the Tracker Scanner and review the trackers detected on the store, especially Google Analytics, Google Ads, Meta and other BFCM marketing tools. Make sure each tracker is assigned to the correct consent category, then test the storefront to confirm restricted trackers stay blocked until the required consent is given.

#### Consentmo's BFCM tip

Don't stop at checking whether the cookie banner appears! Test exactly what happens to your analytics and advertising tags after both acceptance and rejection before sending paid BFCM traffic to the store. Or - reach out to support for a free compliance check.

[Get Compliant for BFCM with Consentmo](https://www.consentmo.com/cookie-banner-shopify?utm%5Fsource=partner&utm%5Fmedium=disco%5Fproduct%5Fessentials&utm%5Fcampaign=blog)

## How does the Omnibus Directive apply to Shopify sales?

If you sell to consumers in the European Economic Area and announce a price reduction, you must show the lowest price you charged for that product in the 30 days before the reduction. That covers percentage and amount-off claims, and was/now prices. National law can require a longer period than 30 days.

The rule sits in [Article 6a of the Price Indication Directive](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:01998L0006-20220528&ref=productessentials.app), added by the [Omnibus Directive](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32019L2161&ref=productessentials.app) (applying since May 28, 2022). See the Commission's [guidance](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52021XC1229%2806%29&ref=productessentials.app) and the [Shopify Help Center](https://help.shopify.com/en/manual/compliance/legal/pricing-indication-directive?ref=productessentials.app).

The rule doesn't cover personalized codes, loyalty offers or bundle offers. Comparisons with a recommended retail price fall under the EU's unfair-commercial-practices rules.

Take a hypothetical wool coat: €120 all autumn, with one promotion week at €108 from November 9 to 15.

## How should Shopify stores show their lowest price from the last 30 days?

Show the sale price with the lowest price you charged in the previous 30 days as your "was" price, usually as the struck-through **Compare-at price**. Any saving you advertise must be calculated from it. Shopify doesn't track it; an app can record your prices and show the lowest as its own line.

The Shopify Help Center still lists two ways to price the coat's Black Friday sale at €84:

| On the product page                     | From the 30-day lowest | From the regular price (ruled out) |
| --------------------------------------- | ---------------------- | ---------------------------------- |
| **Price**                               | €84                    | €84                                |
| **Compare-at price** (struck through)   | €108                   | €120                               |
| "Lowest price in the last 30 days" line | Not needed             | €108                               |
| Advertised saving                       | 22%                    | 30%                                |

In 2024, the [EU Court of Justice ruled out the second route](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:62023CJ0330&ref=productessentials.app) (Aldi Süd, C-330/23). Aldi had struck through its regular price and printed "Lowest price in the last 30 days" underneath. The Court held that the reduction must be calculated from the 30-day lowest.

In the product's **Price** section, click **Compare at** and enter the struck-through price. Use the bulk editor for many products, and a metafield for a separate "Lowest price" line. If your primary market isn't in the EEA, turn off compare-at price hiding in **Markets**. Our [compare-at price guide](https://productessentials.app/blog/shopify-compare-at-price-complete-guide/) walks through each step.

### Track and display prior prices with Complimus

**Complimus: Omnibus & EU Rules** saves every price daily. On discounted products, it shows the lowest 30-day price next to the sale price, per Shopify Markets country and in all currencies. Its **Not compliant** status flags a **Compare-at price** that isn't the 30-day lowest.

Complimus [starts collecting price history when you install it](https://help.complimus.com/docs/omnibus/omnibus-pricing-app-faq?ref=productessentials.app), so install it before your 30-day window opens (October 28 for a November 27 sale).

![Complimus's demo product page: a tank top at 55,00 € with 80,00 € struck through, and the line "Lowest pre-sale price: 80,00 €" underneath.](https://productessentials.app/content/images/2026/09/03-complimus-lowest-price-7e431354.png)

[Explore Complimus](https://apps.shopify.com/omnibus-price?ref=productessentials.app)

## How does the Omnibus Directive affect Black Friday discounts?

The Omnibus Directive Black Friday rule makes your "was" price the lowest price of the 30 days before the sale. For a November 27 launch, that window runs October 28 to November 26; for Black Week from November 23, it opens October 24\. Any promotion inside that window lowers it.

![Timeline of a hypothetical coat's price from October to November: €120, a €108 promotion from November 9 to 15, €120 again, then €84 from November 27. The 30 days before the sale, October 28 to November 26, are shaded, and the lowest price inside them, €108, is marked as the "was" price.](https://productessentials.app/content/images/2026/09/02-coat-price-history-bc936190.png)

Suppose your Black Week sale starts at 20% off on November 23 and deepens to 30% on Black Friday, with no price rise in between. In all four countries below, your "was" price can then stay the 30-day lowest before November 23 for the whole sale.

| Country                                                                                                               | Anything extra for a Black Friday sale?                                                                                                                                                                                                                                                 |
| --------------------------------------------------------------------------------------------------------------------- | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| [Germany](https://www.gesetze-im-internet.de/pangv%5F2022/%5F%5F11.html?ref=productessentials.app)                    | No. Perishables marked down before they expire are exempt, if you say why.                                                                                                                                                                                                              |
| [Denmark](https://forbrugerombudsmanden.dk/longreads/retningslinjer-for-prismarkedsfoering?ref=productessentials.app) | Yes: keep the sale short. A sale price can run for 10 days, or longer if you give the end date when the sale starts, but never more than half as long as the regular price ran (15 days after 30 days at full price). A Black Week sale from November 23 to Cyber Monday (8 days) fits. |
| [France](https://www.shopify.com/fr/blog/legislation-europeenne-promotions-en-ligne?ref=productessentials.app)        | No. Perishable products are exempt.                                                                                                                                                                                                                                                     |
| [Netherlands](https://www.shopify.com/nl/blog/nieuwe-regels-kortingen-webshop?ref=productessentials.app)              | No. Products on the market for less than 30 days, and perishables, are exempt.                                                                                                                                                                                                          |

**Common mistakes:**

- **Raising prices inside the window:** raise a €50 price to €65 two weeks before the sale, sell at €45, and the reference is still €50.
- **A storewide banner only:** every product page still needs its own 30-day lowest price.

Keep a record of your past prices. Before launch, open three sale products and check that the reference price matches your price history for the last 30 days.

## What should you check before launching your sale with Disco?

Disco puts the products on sale in bulk, starts and ends the campaign on schedule, and restores the original prices afterward. Before launch, check which products are in, what each will cost, and when the sale runs. Test a small campaign and check the product page before, during and after.

In Shopify you can bulk-edit **Price** and **Compare-at price**, but you change prices by hand at launch and afterward. Disco resolves this by scheduling and restoring them.

Disco writes each product's pre-sale price as the **Compare-at price**. Avoid promotions and price increases on Black Friday products inside the 30-day window, and that struck-through price is the 30-day lowest. If a product already has a higher **Compare-at price**, Disco keeps it, so check that it's the 30-day lowest too. Disco doesn't work out the legally required prior price for you.

### Prepare your campaign in Disco

1. **Choose the products and exclusions.** Click **Create sale**. Under **Include products** choose **All products** or **Select products, collections, tags or types**. Set **Exclude products / collections** ([storewide sales](https://productessentials.app/blog/shopify-bulk-discounts/)).
2. **Set the discounts and timing.** Pick **Percentage**, **Amount off** or **New price**. If products already have a compare-at price, decide on **Calculate discount from compare-at price** (when it's off, the discount is calculated from the current price). Set **Active dates** ([scheduling walkthrough](https://productessentials.app/blog/schedule-shopify-sale-starts-ends-automatically/)).
3. **Test the complete campaign.** Add `?previewSale=SALE_ID` to your store URL to preview the bar, timer and badges ([Disco FAQ](https://help.productessentials.app/article/46-faq?ref=productessentials.app)). At launch, check a product page's sale price, struck-through price and any prior-price line; after the sale ends, check that the prices are back.

![A Disco campaign named "BFCM Sale": 25% off the products in the "Black Friday Sale" collection, chosen under Include products, with active dates from November 27 to December 1, 2026. The summary on the right lists the collection's products.](https://productessentials.app/content/images/2026/09/04-disco-campaign-setup-bf50f7d7.png)

[Plan your Black Friday sale with Disco](https://apps.shopify.com/discount-app?referrer=pe&utm%5Fsource=productessentials.app&utm%5Fmedium=blog&utm%5Fcampaign=shopify-omnibus-directive-lowest-price-30-days)

## FAQ

What does the Shopify Omnibus Directive mean for merchants? 

When you advertise a reduction to EU consumers, show the lowest price you charged in the 30 days before it. It covers announced reductions of a product's price, including Black Friday deals and storewide banners.

Does Shopify show the lowest price from the last 30 days automatically? 

Not on its own: there is no Shopify lowest price 30 days field that fills itself. You enter the price as the **Compare-at price** or in a metafield, or use an app such as Complimus that saves prices daily.

How does the Omnibus Directive affect Black Friday promotions? 

The Omnibus Directive Black Friday rule is that your "was" price is the lowest price of the 30 days before launch: October 28 to November 26 for a November 27 sale. A promotion inside that window lowers it.

How should I test Shopify cookie consent before Black Friday? 

Open the store in a private window as a visitor from an EU country, reject cookies, and check that analytics and ad tags stay blocked. Accept and check they load; it works the same with Shopify's own cookie banner (**Settings > Customer privacy**) or an app like Consentmo.

## When should you run these checks?

Start now, before the 30-day window opens (October 28 for a November 27 sale, October 24 for Black Week from November 23). Test consent choices on the live store, review prior-price information on sale products, and check your campaign's timing in a test run.

Check consent. Check your prices. Then let the sale run on schedule.

[**Schedule your Black Friday sale with Disco.**](https://apps.shopify.com/discount-app?referrer=pe&utm%5Fsource=productessentials.app&utm%5Fmedium=blog&utm%5Fcampaign=shopify-omnibus-directive-lowest-price-30-days)

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**Next:** [How to schedule a Shopify sale that starts and ends automatically](https://productessentials.app/blog/schedule-shopify-sale-starts-ends-automatically/) walks through the dates and times.