United Kingdom · CAP Code 3.39 · reference pricing

Was/now pricing claims (incl. Black Friday) — reading UK CAP cues

Retail PDPs, category pages, and seasonal email landers lean on strike-through “was £X” lines beside a bold “now £Y”. For was now pricing claims UK pages — including Black Friday and January sale modules — published CAP materials frame reference pricing as a substantiation question: does the higher price represent a genuine established usual selling price? This guide is literacy for your claim register — not ASA clearance, not legal advice, and not price-comparison legal advice.

Not ASA clearance. Not legal advice. Not price-comparison legal advice. This guide summarises publicly available CAP/ASA guidance for marketers and agencies. CiteBefore inventories claims on live URLs; we do not assert that any specific was/now module is a “breach” or coach complaints to the ASA. The ASA decides complaints.
CAP claim substantiation workflow: inventory claims, classify risk, hold evidence before publish, log gaps in register

Where was/now and strike-through pricing appear

Reference pricing modules are everywhere in UK e-commerce creative:

Consumers often treat a crossed-out “was” price as regulated and trustworthy. ASA research on reference pricing (cited in CAP’s updated materials) underpins why substantiation and duration discipline matter in published guidance.

How published ASA/CAP guidance frames reference pricing

These are themes from AdviceOnline: Promotional savings claims (updated May 2026) — literacy only.

Genuine usual selling price (rule 3.39)

Marketers claiming a saving must not mislead by falsely claiming a price advantage (rule 3.39). AdviceOnline states that reference prices — explicit (“was £9.99”) or implied (“Save £70”, “60% OFF”) — must represent a genuine established usual selling price and not mislead.

Factors the ASA discusses in published materials

When assessing whether a price is the usual selling price, published ASA materials commonly reference:

Additional published themes

This guide quotes published themes only. It does not invent case outcomes as legal holdings on your live URL.

Black Friday checklist: what to capture before publish

Seasonal peaks compress production timelines. Before a Black Friday or peak-sale was/now module ships, capture these fields in your claim register (literacy checklist — not clearance):

  1. Exact ad copy — was price, now price, “Save £X”, “X% off”, RRP line, and any “lowest price in 30 days” footnote.
  2. SKU and channel — same product, same sales channel (web vs app vs marketplace listing).
  3. Reference price window — start/end dates the higher price was live, and total days at each intervening price in the prior three months (or longer if your pricing team holds it).
  4. Promotion window — Black Friday start/end, post-sale reversion price, and whether a countdown timer implies the deal ends.
  5. Sales volume notes — whether the product sold at the reference price during the reference window (AdviceOnline discusses sales data in Boots and similar examples).
  6. Range claims — for “up to X% off” category pages, log the highest and typical saving, not only the hero SKU.
  7. Comparator context — if the module also says “better than [competitor]”, add a separate row per comparative claims checklist; reference pricing and competitor comparison are different claim classes.
Working habit. Treat every struck-through price as a claim row with an Evidence column for pricing history — not as design chrome. The agency register template and free scan help triage savings-shaped lines before peak trading.

How to read a was/now line for a CiteBefore claim register

When pasting a URL or building a manual row:

Pair with superlatives and “best” claims when the sale tile also says “lowest price ever” or “best deal”. Pair with advertising claim substantiation for the savings claim class in your wider inventory.

What CiteBefore does — and does not do

Clear limits

  • Not ASA clearance and not a substitute for ASA Copy Advice.
  • Not legal advice and not price-comparison or consumer-law advice.
  • Not “breach” coaching — we do not tell you to complain to the ASA or label a live was/now module a breach.
  • CiteBefore inventories claims and suggests evidence columns. The ASA decides complaints.

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Primary sources

FAQ

How long must the “was” price have been charged?

Published ASA materials emphasise duration and recency: the reference price should generally have been the most recent price and charged longer than the promotional price. AdviceOnline often discusses three months of pricing history. Your pricing team holds the data; CiteBefore inventories the claim text.

Does Black Friday need different evidence?

Not a separate CAP rule — but peak campaigns compress timelines. Capture reference windows, promotion end dates, and post-sale prices in your register before publish. See the Black Friday checklist above.

Can I use a store price as the online “was” price?

Published CAP materials say a reference price for an online offer should reflect the usual selling price on that same channel. This guide does not provide legal advice on omnichannel pricing — consult your advisers if unsure.

Does CiteBefore clear was/now pricing with the ASA?

No. CiteBefore inventories claims and evidence columns on a live URL. It is not ASA clearance, not Copy Advice, and not legal advice. The ASA decides complaints.

Related guides

Guide for UK marketers and agencies. Informational only. Author: Ellis Greensitt. datePublished 2026-09-09. Last reviewed against ASA promotional savings claims AdviceOnline as of Sep 2026.