A video says "only 19.90 instead of 29.90", the brand runs it as an ad, and three weeks later a warning letter arrives. Not because of the disclosure, not because of the product, but because of the sentence with the two numbers in it.
As soon as a price is named in a video, the video is advertising that states prices. That brings the German Price Indication Ordinance into play, and it sets requirements nobody has in mind on a shoot day.
Who the ordinance actually binds
The ordinance governs price indications for goods or services by traders towards consumers. Its central duty attaches to two roles: whoever offers goods or services to consumers, and whoever as the supplier of those goods or services advertises them stating prices.
The word supplier carries the whole weight here. Someone who films a third party's product and names its price does not thereby become the supplier of that product. The supplier is whoever sells, and in a UGC campaign that is the brand.
Why that is not an all-clear for creators
The duty sits with the brand, the risk still lands on the shoot. Because if the spoken price makes the ad attackable, it is the brand that receives the warning letter, and the contract with the creator decides who pays for the reshoot.
In practice that means a price statement in a video is never a creative decision. It comes from the brief or it does not go into the video.
What a stated price drags along with it
What has to be given is the total price, meaning the price payable including VAT and other price components. A net price aimed at consumers does not satisfy that.
On top of that comes a formal requirement that weighs more heavily in video than in an online shop: the information must be clearly attributable to the offer or the advertising, and easily recognisable and clearly legible or otherwise readily perceptible. The ordinance explicitly demands price clarity and price truthfulness.
In distance selling, it must additionally be stated that the prices include VAT and other price components, and whether freight, delivery or shipping costs apply on top. Where they do, their amount must be stated as far as it can reasonably be calculated in advance.
What "readily perceptible" means in a video
An overlay that stands for four frames is not readily perceptible. Information that lives only in the description below the video, while the price is spoken on screen, is not clearly attributable to the advertising.
The reliable rule of thumb: whatever belongs to the price stands where the price stands, and long enough to be read.
Unit price: only for certain goods
This is where the most common misreading sits. The unit price is not owed for every product visible in a video, but for goods in prepackages, open packages or as sales units without wrapping, by weight, volume, length or area. For loose goods sold by those measures, by contrast, only the unit price is given.
And the ordinance expressly carves out a series of cases.
| Product in the video | Unit price owed | Basis |
|---|---|---|
| Shampoo, 500 ml, prepackage | yes | § 4 (1) PAngV |
| Serum sample, 5 ml | no | § 4 (3) no. 1, under 10 ml |
| Lipstick | no | § 4 (3) no. 7, colouring or beautifying |
| Eau de parfum with 3 % fragrance oil and 70 % ethanol | no | § 4 (3) no. 8 |
| Coffee, weighed out loose | unit price only | § 4 (2) PAngV |
| Coaching package | no | § 4 covers goods, not services |
The "cosmetics are exempt" misreading
What is exempt are cosmetic products serving exclusively to colour or beautify the skin, the hair or the nails. That is a narrow wording, and it does not cover the whole category.
A lipstick falls within it. A care serum advertised for its effect on the skin barrier cannot readily be classified as exclusively beautifying. Claiming the exemption for the entire shelf stretches it beyond its own text.
Discounts in a video: the 30-day rule
Anyone required to state a total price must, on every announcement of a price reduction for goods, state the lowest total price they applied towards consumers in the 30 days before the reduction.
Where a reduction increases in steps without interruption, the price that applied before the sequence began may be given throughout. The rule does not apply to individual price reductions, nor to perishable goods or goods with a short shelf life whose price is cut because spoilage is imminent.
A second provision has to be kept apart from this one, because the two are often confused: for generally applicable price reductions limited by calendar date and publicly announced, the duty to display a new total or unit price falls away. That does not exempt anyone from stating the reference price. The two rules stand side by side, and only one of them knows this relief.
Why this reaches the shoot
The reference price is a fact about the seller's own pricing history, not about the product. The creator cannot know it, and it can change between the shoot and the moment the ad runs.
From which follows a production rule that any brief can carry: the discount claim belongs in a layer the brand can change afterwards. An overlay, a description, an ad copy line can be adjusted. A number spoken on the audio track cannot.
What belongs in the brief
Three points are enough to keep the whole complex out of the shoot.
- Prices are not spoken when the campaign is meant to run longer than the price holds.
- If a price is named, the brand supplies it in writing, as a total price, with the 30-day reference price where a reduction is involved.
- Overlays stand long enough, and everything belonging to the price stands next to it.
The fourth point is not a brief item but a contractual one: the approved price statement stays documented, because the duty hangs on the brand's pricing history and not on the edit.
Sources
- § 1 PAngV, scope and principle
- § 3 PAngV, duty to state the total price
- § 4 PAngV, duty to state the unit price
- § 6 PAngV, price indications in distance contracts
- § 11 PAngV, additional duty on price reductions
Checked on 8 September 2026. This guide is not legal advice and does not replace an examination of the individual case. Where this guide and the official source diverge, the source prevails.
