Black Friday:
Real discounts, no fake crossed-out prices

Fabrice Decroo

Consulting Director

September 14, 2026

Since May 28, 2022, the crossed-out price in a promotion must correspond to the lowest price actually charged during the previous 30 days, not to a price that was artificially inflated the day before the sale. A simple rule on paper, but one that is regularly circumvented in practice: during Black Friday 2025, UFC-Que Choisir once again called out several major retailers for discounts deemed misleading.

This guide is based on two key observations—stringent regulations and increasingly wary consumers—to address a practical question: How can a retailer design a Black Friday campaign that protects its profit margin without risking an audit by the DGCCRF or damaging its brand image? A 5-step method, backed by verified data. Ensuring compliance across all promotional activities is the purpose of BOOPER’s Promotion Management module.

Table of Contents

H2 Headings

A month of tension, not a single day

Black Friday 2025 officially took place from November 21 to December 1, but in reality, the event is no longer much of a one-day affair. Retailers roll out their first discounts as early as mid-November to capture early search traffic, and November and December now account for 22% of annual online product sales in France, according to Fevad.

55 %

of sales made during Black Friday 2025 in France were made via mobile devices, confirming that the decision-making window has shifted well before checkout—often several days before the peak of the sales event (Fevad, Black Friday 2025 data).

When it comes to purchase intent, the signals remain mixed. According to a Kantar study published in October 2025, about 7 out of 10 French people plan to take advantage of end-of-year sales, a slight decline compared to 2023 (74%). Specifically regarding Black Friday, the 2025 idealo x Kantar study indicates a lower participation rate: 39% of French consumers plan to actively participate, with a reported average budget of €265. This budget is constrained by current economic conditions: according to the Cetelem Observatory (September 2025), 62% of households have already cut back on non-essential spending.

Another key trend to watch: NielsenIQ notes that the pursuit of sustainability and reliability now carries as much weight as price in the decision-making process. The Black Friday 2025 shopper is no longer just looking for the best deal; they’re looking for the right purchase—one they won’t regret come January. This is precisely where perceived value comes into play: a discount no longer reassures shoppers if the original price seems inflated just for the occasion.

The real risk is legal, not just commercial

This is the point that general Black Friday guides most often fail to mention: in France, the announcement of a price reduction is governed by specific legislation. Since May 28, 2022, Article L112-1-1 of the Consumer Code (resulting from Order No. 2021-1734 transposing the European Omnibus Directive) requires that the reference price—the price used to calculate the discount—be the lowest price charged during the 30 days preceding the start of the sale. In practical terms: a product sold for €100 for one month and then priced at €160 the week before Black Friday cannot display a discount calculated based on €160.

1.5 million euros

the maximum fine that a legal entity may face for engaging in deceptive business practices (Article L121-2 of the Consumer Code), compared to €300,000 and two years’ imprisonment for an individual. The DGCCRF monitors these advertisements every year during the campaign.

In practice, the rule is regularly circumvented. During Black Friday 2025, UFC-Que Choisir once again identified questionable practices at several major retailers, including Amazon, Boulanger, Rakuten, and Cdiscount: raising prices a few weeks before the sale to make the discount appear more dramatic, using the “suggested retail price” as an artificial benchmark, or comparing prices to a competitor’s price that is difficult to verify. A previous investigation by the association, which compared 65,000 items between Black Friday 2023 and the entire month of November, had already shown that the actual average discount remained limited across several categories: 1.6% on cell phones, 3.7% on televisions, 1.9% on laptops, and 0.5% on household appliances.

For a retailer, the operational implication is simple: the risk is no longer just that of underperforming commercially during the operation; it is the risk of being publicly identified—by store name—in a consumer investigation covered by the national press.

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Why Your Customers Aren't Falling for It Anymore

This regulatory environment is facing consumers who are better informed than they were five years ago. Price comparison features, price histories displayed directly on product pages, and the systematic coverage of UFC-Que Choisir and CLCV surveys every November: checking a crossed-out price is no longer the exclusive domain of specialized journalists—it has become second nature to the general public. An inflated reference price—even one that appears to comply with regulations—can now be spotted with just a few clicks, with a direct impact on the retailer’s image that extends far beyond the promotion itself.

It’s also a matter of consistency over time. A Black Friday discount that only makes sense when compared to the price listed the day before loses all credibility if the same customer finds it—for a few euros more or less—during the January sales or a subsequent clearance sale. Maintaining a documented reference price over the long term has become as much a trust-building asset as a legal requirement, and this requires continuously monitoring what direct competitors are doing—not just one’s own catalog—which is the role of a structured competitive price monitoring system.

The 5-Step Method for a Profitable and Compliant Black Friday

It takes just five steps to build a Black Friday campaign that protects both your profit margin and compliance—without having to scramble the day before the launch.

Set the reference price 30 days in advance, not the day before

Starting November 1, record and document the lowest price charged for each item included in the promotion, rather than reconstructing it retroactively.

Segment the catalog into loss leaders and high-margin products

Reserve the most prominent discounts for a limited number of products that are actually compared, and manage the rest of the catalog with a more sustainable margin.

Document and archive each reference price

Keep a record of the prices charged during the calculation period so that you can justify each discount in just a few minutes in the event of an audit or dispute.

Continuously monitor the competition during the operation

Track the prices of direct competitors on a daily basis for key products, so as to adjust prices without dropping them too low or offering excessive discounts out of a defensive reflex.

Secure the output bearing before startup

Decide, before November 21, when the submission period will close and what criteria will apply, rather than automatically extending it due to a lack of prior decision.

At Booper

Automate compliance, not just submission

GENIUS Price, the pricing rules module of the Booper modular platform, automatically calculates and archives the 30-day reference price for each SKU involved in a transaction, with traceability that can be accessed immediately in the event of an audit.

At the same time, GENIUS Link continuously monitors competitors’ prices for key SKUs throughout the entire campaign to fine-tune a Black Friday campaign without compromising margins or compliance.

The most costly mistakes during the operation

Raising a price a few weeks before Black Friday to make the discount seem more dramatic when the sale begins—this is exactly the practice that the DGCCRF and consumer advocacy groups are prioritizing in their monitoring efforts.
Apply a uniform discount across the entire catalog, without distinguishing between the loss leaders that are actually being compared and the rest of the product line, at the expense of the overall margin.
Launch the promotion without a predetermined end date, which effectively extends it and dilutes its sense of exclusivity for customers.
Respond to remaining inventory rather than follow a pricing plan decided in advance, which carries the risk of making panic-driven adjustments in the final days of the promotion.
Never measure actual incremental revenue after the fact by confusing the revenue generated during the promotion with sales that would have occurred anyway, either before or after: this is the pitfall we’ve already detailed in our guide on measuring the incremental impact of promotions.

Checklist Before Launching Your Campaign

5 Things to Check Before November 21

Is the 30-day reference price fixed and documented for each item included in the transaction?
Does my catalog clearly distinguish between loss leaders (with real, visible discounts) and products with protected margins?
Does my competitive intelligence monitoring continuously cover key benchmarks throughout the duration of the operation?
Is the exit point for the operation set before it begins, rather than decided at the last minute?
Have I planned to measurethe actual incremental impact of the campaign once Black Friday is over?

A Black Friday that protects the retailer’s profit margin and brand image isn’t decided on the day itself—it’s built a month in advance, based on a well-documented reference price and clear product segmentation. In an environment where regulations are tightening and consumers are becoming increasingly savvy, it is this advance preparation that makes the difference between a campaign that preserves consumer trust in the retailer and one that erodes it.

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Frequently Asked Questions

What is the rule regarding the reference price for Black Friday in France?

As of May 28, 2022 (Article L112-1-1 of the Consumer Code), the crossed-out price displayed must correspond to the lowest price charged by the seller during the 30 days preceding the start of the sale, and not to a price that was raised just before the sale began.

What are the risks for a retailer that advertises a fake discount during Black Friday?

A discount calculated based on an inaccurate reference price may be considered a misleading commercial practice (Article L121-2 of the Consumer Code), punishable by a fine of up to 300,000 euros and up to 2 years’ imprisonment for an individual, and up to 1,500,000 euros for a corporation. The DGCCRF monitors these advertisements every year during the campaign.

Is Black Friday really the best time to shop?

Not always. A study by UFC-Que Choisir covering 65,000 items showed that the actual average discounts during Black Friday 2023 remained modest across several categories: 1.6% on cell phones, 3.7% on televisions, and 0.5% on household appliances—well below the percentages listed on the price tags.

How can a retailer segment its catalog for Black Friday?

By distinguishing the items that customers actually compare—which should be treated as loss leaders with a genuine, documented discount—from the rest of the product lineup, where a more favorable margin remains justifiable without undermining the brand’s overall price perception.

How can you tell if a Black Friday promotion was profitable?

By distinguishing between truly incremental sales and sales that were simply shifted from the weeks preceding or following the promotion, rather than limiting the analysis to the gross revenue generated during the promotional period.

What tool should you use to manage your benchmark prices and monitor the competition during Black Friday?

A pricing tool that automatically documents the lowest price of the last 30 days per reference, and that continuously tracks competitors' prices during the operation, avoids having to reconstruct this traceability after the fact in the event of an audit or dispute.

Black Friday:
Real discounts, no fake crossed-out prices

A month of tension, not a single day

The real risk is legal, not just commercial

Why Your Customers Aren't Falling for It Anymore