Black Friday launches the holiday shopping season with discount campaigns that start earlier and earlier. But, even though the campaigns promise unbeatable promotions in physical stores and online, an investigation by DECO PROteste shows that not all announced price reductions are good opportunities.
On the 3rd and 4th of November, the consumer protection organization analyzed the start of Black Friday campaigns in some online stores. And, as in previous years, you found several discounts that circumvent the law on promotions.
In all the online stores analyzed in the first days of November — FNAC, Darty, Auchan and Euronics — products were found on campaign that did not have a real discount and that, until a few days ago, were even cheaper.
According to DECO PROteste, all stores were circumventing the law that dictates that, to announce a promotion, the lowest price charged in the last 30 consecutive days must be considered, to then apply the discount. Furthermore, some of the stores analyzed in this study adopt communication strategies that compare their prices with supposed sales prices recommended by manufacturers, producers or suppliers (PVPR), leading consumers to believe that discounts are being given that are not real.
The Compare Prices tool, from DECO PROteste, records the evolution of product prices in online stores and allows you to know whether the consumer is actually facing a discount. Simply enter the name of the store and a product or the URL of the page where it is being sold in the search engine and, if it is in the DECO PROteste database, the comparator indicates whether it is really a good purchase in that store and what the product’s prices were in the last seven days, the last month and the last three months.
FNAC announces discount on headphones that were 11 euros cheaper the day before
On the 3rd and 4th of November, when DECO PROteste visited the FNAC online store, the “Black Friday New Opportunities” campaign was taking place, which had started on the 28th of October with the promise of several products at the “best price”. But that doesn’t mean all the discounts announced by the online store turned out to be real.
An example of this is the discount announced on the Sony WH-1000XM4 Noise Canceling Bluetooth headphones. On the days this study was carried out, they were on sale for 169.99 euros, but just one day before the start of the Black Friday campaign they were being sold at FNAC for 10.99 euros less, at 159 euros, as shown in the Compare Prices tool, from DECO PROteste.
In addition to the supposed discounted price being higher than the price charged just a few days earlier in the same store, and not respecting the law on commercial practices with price reduction, FNAC online was also making a price comparison that could lead the consumer to believe that they were enjoying a higher discount than the real one.
The online store showed next to the current sales price an alleged RRP of the product of 299.99 euros and a 43% discount on this value. If this price had previously been charged by FNAC online, the discount would be 130 euros. However, for at least the last three months, the store has never sold the product at this price. The highest price these headphones were sold at in this store was 232.99 euros.
Washing machine in Darty’s campaign cost 27 euros less weeks before
Darty’s online store, which recently arrived in the country after the purchase of MediaMarkt stores in Portugal, is also announcing discounts on products that until very recently were cheaper. The “1st Black Friday Darty Price Leap of the Year” campaign began on October 28, with supposed price reductions on products such as the LG F2WR5S8S1W washing machine, which was on sale for 399 euros. However, anyone who visited Darty’s online store between October 17th and 19th could find the same machine for 371.99 euros, that is, 27 euros less than the supposed discounted price in the campaign.
On the product’s sales page, Darty also presented a RRP of 529.99 euros next to the product’s sales price, as well as a supposed 24% discount. All things considered, the consumer could be led to think that they were saving 130.99 euros. However, although the store had already sold the washing machine for 529.99 euros, between October 4th and 9th, this was the highest price at which it was sold, and not the lowest price in the 30 days prior to the start of the campaign, as required by law when discounts are announced.

Auchan announces 5% discount on tumble dryers that are 20 euros more expensive
When DECO PROteste visited the Auchan online store, which launched its Black Friday campaign on November 1st, the Qilive Q.6273 Bomba Calor D 8 kg tumble dryer was being sold for 379.99 euros. However, just days before, on October 25th and 26th, the same dryer was on sale in the same store for 20 euros less, at 359.99 euros. Anyone who buys it now, during the campaign, will not get a real discount.
Furthermore, the online store also announced a 5% discount on a crossed out price of 399.99 euros. And although the tumble dryer was already sold at this price in the Auchan online store on October 23 and 24, this is not the lowest price in the 30 days before the start of the campaign, as required by the law on price reduction sales.

Vacuum cleaner at Euronics had a lower price the day before the campaign
In the “Finds of the Week” campaign, which runs in the Euronics online store from the 3rd to the 9th of November, the Flama 1670FL vacuum cleaner was being sold for 59.99 euros, when just a day before it had been on sale for a lower price, at 54.07 euros.
On the Euronics page where the vacuum cleaner was for sale, the online store showed a 25% discount on a crossed out price of 79.99 euros, which could lead the consumer to believe that they were saving 20 euros. However, this online store never sold this vacuum cleaner at the price shown. For the price of the product in the campaign to represent a real saving, the price reduction should apply to the price of 54.07 euros, at which the vacuum cleaner was being sold between October 24th and November 2nd and the lowest in the 30 days prior to the start of the campaign.

How stores get around the promotion law
Since May 2022, retailers have to comply with new rules on price reduction sales. Sales, promotions or sales can only be announced if, in fact, they represent a discount on the lowest price at which the product was sold, in the same store, in the 30 consecutive days prior to the application of the price reduction. Signs, labels or lists of products for sale with reduced prices must clearly show the new price and the lowest price previously charged. Indication of the discount percentage is optional.
Before 2019, the law only established that the price reduction announced by traders must be real and have as a reference the price previously charged for the same product, without defining the concept of “previously charged price”. This lack of definition allowed for several years abusive and misleading practices on the part of commerce, such as occasional price increases immediately before the start of sales or promotion periods, and then announcing greater discounts.
Reference price for the discount must be the lowest in the last 30 days
But now, with the changes to the law that came into force in 2022, the price to be considered for presenting reductions must be the lowest charged by the store in the last 30 days, even if it corresponds to a sale or promotion price.
Reacting to the greater difficulty in presenting large discounts, some stores are not applying the new rules that oblige them to indicate the lowest price charged in the 30 consecutive days prior to the start of the reduction period, maintaining the illusion of offering good discounts. In some cases, the crossed out price, that is, the reference price for calculating the discount, does not meet the legal requirement of being the lowest, in the same store, in the last 30 consecutive days. In other cases, some stores resort to practices that do not comply with the law on reduced price sales. An example of this is the comparison with the PVPR, which is likely to mislead the consumer by implying that there is a discount, when there may be no real savings.
DECO PROteste asks ASAE to reinforce inspection
In 2019, during the Black Friday period, DECO PROteste verified several violations of the law, from missing prices to some products in the campaign that did not display the price previously charged or, alternatively, the percentage of reduction. Based on the various cases found, DECO PROteste requested the Food and Economic Security Authority (ASAE) to impose fines and disclose the open processes. At the time, in a statement, ASAE reported that 387 economic operators were inspected in physical and online establishments, and 57 administrative offense proceedings were initiated.
In 2022, 2023 and 2024, the cases repeated. DECO PROteste again found infractions, this time due to non-compliance with the rules regarding the reference price to be considered for applying the discount, and reported it. However, the cases analyzed in the 2025 Black Friday campaigns reveal that online stores continue to disregard the law. In order for the law on sales with price reduction to be complied with, DECO PROteste asks ASAE to reinforce inspection actions during this period and apply fines to stores that continue to violate the law.
