§ 4 PAngV: When Online Unit Prices Are Required

A bakery shows a 750 gram loaf online with a price, but without a price per kilogram. A pharmacy lists care products by millilitres. A florist sells potting soil in bags. In situations like these, the final price is often not the only relevant price. The unit price under § 4 PAngV can matter as well.

What the Paragraph Regulates

Traders who offer goods to consumers in prepackages, open packages or as sales units without packaging by weight, volume, length or area, or who advertise these goods to consumers with prices, must state the unit price in addition to the total price in an unambiguous, clearly recognisable and easily legible way.

§ 4 PAngV does not regulate every price on a website. It mainly applies where goods are meant to be comparable by quantity: kilograms, litres, metres, square metres or cubic metres. The unit price is the price per such comparison unit. It helps consumers compare two products that come in different package sizes.

A simple example: two bottles of olive oil cost 8.90 EUR and 12.90 EUR. Without knowing the quantity, that says little. If the first bottle contains 250 ml and the second contains 500 ml, the second product may be cheaper per litre. That is the purpose of the unit price.

The distinction between total price and unit price matters. The total price is the price someone pays for the concrete item. The unit price converts that price to a comparable unit. § 5 PAngV adds which unit must be used. In most cases this means 1 kilogram, 1 litre, 1 metre, 1 square metre or 1 cubic metre.

§ 11 PAngV is often mentioned in the same context, but it regulates a different issue: price reductions. If a trader advertises a discount on a concrete product, the lowest total price of the previous 30 days may become relevant. For unit prices themselves, § 4 PAngV is the central starting point.

Who Is Affected

§ 4 PAngV is relevant whenever goods are shown to consumers with a price and the goods are offered by weight, volume, length or area. For our typical customer groups, this can affect several industries:

• Cafes, bakeries and ice cream parlours - for example with packaged baked goods, coffee, takeaway ice cream cups or pre-orderable products with weight or volume. See our notes on a website for cafes, a bakery website and a website for ice cream parlours.
• Pharmacies, florists and jewellers - for example with care products, supplements, potting soil, fertiliser, ribbon, chain goods or other items with a quantity reference. Details are available on the website for pharmacies, the website for florists and the website for jewellers.
• Hair salons, beauty studios and local specialist shops - for example where care products, cosmetics, colouring products or similar goods are presented online or offered for enquiry. More context is available on the hair salon website, the website for beauty studios and the website for fashion boutiques.

Other industries can be affected as well. The decisive factor is not the industry label, but the concrete presentation: is a product offered or advertised to consumers with a price and a quantity reference?

Typical Use Cases

For bakeries and cafes, the question often appears when goods can be pre-ordered online. A cake slice, loaf of bread, pack of coffee or bottle of syrup can trigger a unit price issue if weight or volume is stated and consumers are expected to compare prices. Many classic gastronomy services are different. A dish served in a restaurant is usually part of a service situation with its own pricing logic. A website therefore needs to distinguish between describing food as a restaurant offer and presenting goods for sale, pickup or delivery.

For pharmacies, the quantity reference is especially common. Many non-prescription products are offered by grams, millilitres or packaged quantities. For a website, that means product-related price information should not be treated as a loose marketing line. If concrete products are shown with final prices, the quantity reference should be considered from the start.

Florists and local specialist stores often underestimate the topic because they do not see themselves as online retailers. Still, a website with prices for potting soil, substrates, fertiliser, gift ribbon or goods sold by length can quickly enter unit-price territory. Even a lean pre-order form can be relevant if it presents goods with quantity and price.

For beauty businesses, the service itself is usually not the issue. A haircut or treatment does not have a unit price per litre. The situation changes when care products, cosmetics or product sets with concrete quantities are shown online with prices. § 4 PAngV contains exceptions, for example for certain cosmetic products used exclusively to colour or beautify skin, hair or nails. Whether such an exception applies in a concrete case should not be decided inside a website project, but checked by a qualified source.

For fashion stores, normal clothing sales are usually not structured by weight, volume, length or area. The topic becomes more relevant for fabric sold by the metre, ribbons or accessories with a length reference. For ordinary garments, other price indication questions are usually more important, such as total prices, shipping costs or discount presentation.

Exceptions and De Minimis Rules

§ 4 paragraph 3 PAngV contains several exceptions. One important point is simple: no additional unit price is required if the unit price and the total price are identical. Goods with a nominal weight or nominal volume of less than 10 grams or 10 millilitres are also exempt.

Other exceptions include mixed products that are not blended or mixed together, certain offers by small direct marketers and small retail stores where goods are mainly handed over through personal service, goods offered as part of a service, vending machines, and certain cosmetic products and perfumes. This list shows why broad statements are risky. Two products may look similar at first, but the distribution channel or product type can change the assessment.

§ 5 PAngV is just as important for implementation. It defines the reference unit. For packaged goods, 1 kilogram or 1 litre will usually be the relevant basis, not a freely chosen smaller size. For loose goods, 100 grams or 100 millilitres may be relevant depending on common market practice.

Consequences of Violations

Violations of the Price Indication Regulation can be relevant as administrative offences and can also trigger competition-law warnings. For small businesses, the biggest risk is often not only a fine, but the operational effort: deadlines, lawyer costs, corrections to the website, shop or product data, and uncertainty about whether other price information is affected as well.

Case law shows that the information should not be hidden somewhere on the page. The German Federal Court of Justice has held that the unit price in online retail must be perceptible in close proximity to the total price. In practical terms, a unit price that only appears after a click, in a distant product description or only on mouse-over is risky.

Practical Implementation on the Website

For normal readers, the best solution is not a dense legal text, but a clear structure. If a website shows concrete goods with prices, each product field should consider the required price elements from the beginning: product name, quantity, total price, unit price, possible delivery or pickup information and, where relevant, discount logic.

We structure product and pre-order areas in line with the requirements of § 4 and § 5 PAngV. That means, for example: unit price directly next to the final price, clear unit, no hidden notes, consistent presentation across all product cards. If discounts are advertised, it should also be checked whether § 11 PAngV and the lowest price of the last 30 days are relevant.

The boundary is just as important: we do not replace a review of your concrete product range. Whether a single product falls under an exception, whether a discount campaign is documented correctly or whether a specialist system handles every price rule correctly should be clarified with your chamber, legal adviser or software provider. The website can, however, be built so the required information has a proper place.

Frequently Asked Questions

Does every website need to show unit prices?

No. The requirement applies only to certain goods with a quantity reference and price information for consumers. A pure service page without concrete product prices is usually not the typical case.

Can § 4 PAngV matter for pre-orders without online payment?

It can be relevant if goods are offered or advertised to consumers with price and quantity. Whether payment happens online or on site is not the only factor.

Is it enough to put the unit price in the product description?

Anything that is not clearly assigned to the total price is risky. Online, the unit price should be visible directly next to the total price without an additional click.

What is the difference between § 4 and § 11 PAngV?

§ 4 concerns unit prices for goods by weight, volume, length or area. § 11 concerns price reductions and the lowest total price of the previous 30 days.

Are services such as haircuts or treatments affected?

A service itself usually does not have a unit price by kilogram or litre. The topic can become relevant if concrete goods with quantity and price are offered in addition.

Who should check the concrete classification?

For binding guidance in a specific case, chambers, lawyers or competent professional bodies are the right contacts. The website should provide the structure, not replace the legal assessment.