Croatia introduces new base-price and online price-list requirements for traders

Croatia is preparing to introduce new price transparency requirements that will affect businesses selling goods and services to consumers, including foreign retailers and online platforms.

Under amendments to the Croatian Consumer Protection Act, traders will be required to display a historical reference price (the so-called “base price”) alongside the current retail price. Businesses operating websites will also have to publish machine-readable price lists to enable automated price collection and comparison. The detailed requirements are set out in two draft ordinances: (i) the Ordinance on the Display of Product Base Prices; and (ii) the Ordinance on the Manner of Publishing Product Price Lists. Both drafts are subject to public consultation until 13 November 2026, with entry into force currently scheduled for 17 November 2026.

The new framework is intended to replace the temporary measures introduced by the Croatian Government in September 2026 (whose application was in any case postponed from 1 October to 17 November 2026).

Although the Ordinances have not yet been finalised and may change following the public consultation process, businesses should begin preparing for implementation, particularly given the limited time between the consultation deadline and the anticipated entry into force.

The key requirements and their practical implications are summarised below.

1. Mandatory display of base prices

1.1 What is a base price?

A base price is the historical retail price applied to a particular product or service on a designated reference date. It serves as a comparison point for consumers and must be displayed alongside the current retail price, even where the two prices are identical.

The drafts establish two reference dates:

• 2 May 2025: for food, beverages, cosmetics, cleaning products, toiletries and household products already covered by the earlier price transparency measures; and
• 10 September 2026: for all other goods and services.

The base price is intended to provide price transparency rather than impose a price cap. Traders remain free to change their current prices, subject to applicable pricing legislation.

1.2 What about newly introduced goods and services?

For goods or services first offered after 10 September 2026, the base price is the retail price applied when the product or service was first introduced into the trader’s offering. This applies both to products introduced before the new Ordinances enter into force and to those introduced subsequently. Traders should therefore maintain reliable records of the relevant introduction date and initial price.

1.3 What if the product or service was discounted on the reference date?

Where a product or service was subject to a promotion, clearance sale or another special form of sale on the relevant reference date, the discounted price cannot be used as the base price.

Instead, the drafts provide that:

• for product categories subject to the 2 May 2025 reference date, the base price is the lowest retail price applied during the 30 days preceding the start of the discount; and
• for all other goods and services, the base price is the previously applicable non-discounted retail price.

1.4 Where and how must the base price be displayed?

The base price must be clearly visible, legible and unambiguous. The specific requirements depend on the sales channel:

• Physical retail stores: the base price must appear on the product or at the point of sale, on the same price label as the current retail price and, where applicable, the unit price.
• Online shops: the base price must be displayed in a manner that prevents confusion with the current retail price, unit price or prices of other products.
• Services: the base price must generally appear alongside the current price in the service price list. Where the number or variety of services makes this impractical, it may be included in a catalogue, brochure or leaflet displaying the relevant prices.
• Advertising: the base price must be displayed in printed and digital advertising, including online advertising. The drafts provide exceptions for radio advertising and voice messages used in other types of advertisements.

1.5 How does this interact with existing discount rules?

The existing obligation to display the lowest price applied during the preceding 30 days when announcing a price reduction remains in force.

Consequently, for goods offered at a discount, three distinct prices may need to be displayed: the current discounted price, the lowest price applied during the preceding 30 days and the historical base price.

2. Mandatory publication of machine-readable price lists

2.1 Who must publish price lists?

Traders selling goods or providing services to consumers must publish their applicable price lists on their websites if they operate a website.

The requirement is not limited to e-commerce businesses. It appears that it also extends to traders with informational or corporate websites, even where consumers cannot complete purchases online.

Traders operating multiple points of sale must publish a separate price list for each point of sale, including their physical and online shops.

2.2 What information must be included?

For goods, the price list must include: (i) product name, code and brand; (ii) net quantity and unit of measure, where applicable; (iii) current retail price, including whether it applies during a special form of sale and the name of that sale; (iv) unit price and barcode, where applicable; and (v) base price.

For services, the price list must include: (i) the service name, (ii) current retail price (including the relevant special-sale information, where applicable) and (iii) base price.

2.3 In which format must price lists be published?

Price lists must be published in a machine-readable .xml or .csv format, enabling automated processing and collection of price data.

The file name must identify the type, address and identifier of the point of sale, together with a storage number and a timestamp indicating the date and time of submission.

Traders operating multiple points of sale must ensure that their files follow a consistent structure.

Importantly, traders must also enable software tools and automated programs to retrieve price information. Merely displaying a conventional price list on a webpage or publishing it in PDF format will not satisfy this requirement.

As of the publication date of this Client Alert, Croatian authorities have not yet published a template of the price list format.

2.4 How frequently must price lists be updated?

Under the drafts, any change to a price list must be recorded and published by 11:00 a.m. on the following working day.

Previously published price lists must also be retained on the website and made available for 30 days following publication.

3. Exemptions and special pricing arrangements

The draft Ordinances provide several exemptions intended to address situations where historical price comparisons would be inappropriate or impracticable. These include:

• Regulated prices: goods and services whose prices are governed by specific legislation, such as certain regulated medicinal products and services.
• Special consumer or payment-related discounts: preferential prices granted to particular categories of consumers or under specific payment conditions, such as loyalty benefits, student discounts or discounts linked to a particular payment method.
• Personalized prices: prices offered only to an individual consumer based on their characteristics, needs or circumstances, e.g. an individually tailored offer or quote.
• Dynamic service pricing: services whose prices fluctuate according to demand, availability or other variables, where no uniform and objectively comparable pricing elements can be linked to the relevant reference date, such as services priced in real time based on demand or availability (e.g. certain transport or accommodation bookings).

4. Implications for foreign webshops and online platforms

4.1 Foreign traders selling to Croatian consumers

The new requirements are not limited to businesses established in Croatia.

Foreign traders whose commercial activities are directed at Croatian consumers may also fall within the scope of the Croatian consumer protection framework. Relevant indicators may include Croatian-language content, delivery to Croatia and indication of prices in euros, Croatian-directed advertising or the use of a Croatian domain. Whether a business directs its activities at Croatian consumers must be assessed considering the overall circumstances.

Foreign retailers and e-commerce businesses should therefore not assume that the absence of a Croatian establishment removes them from the scope of the new requirements.

4.2 Online marketplaces and intermediary platforms

The draft Ordinances distinguish between traders selling their own goods or services and platforms acting merely as intermediaries for third-party sellers.

A platform acting solely as an intermediary would not generally be required to display base prices for third-party products or publish price lists for those products under the proposed rules.

However, when a platform sells products in its own name or directly charges consumers for its own services (e.g. delivery, handling, service or cash-on-delivery charges), the relevant prices would fall within the new requirements.

5. What should businesses do now?

Given the anticipated entry into force of the Ordinances on 17 November 2026, affected businesses should assess their exposure and begin implementing the necessary changes.

Key preparatory measures include:

• Map the scope of the obligations: identify goods, services, sales channels and additional consumer-facing charges potentially covered by the new rules.
• Establish historical reference prices: identify and document the prices applicable on 2 May 2025 or 10 September 2026, as relevant or on the date a new product or service was first offered.
• Review promotional pricing: verify whether special sale conditions applied on the reference date and determine the appropriate base price.
• Update consumer-facing price displays: adapt physical price labels, service price lists, online product listings, product pages and advertising materials to accommodate additional information.
• Prepare technical implementation: establish processes for generating, publishing and archiving machine-readable price lists for each relevant point of sale.
• Review platform and marketplace arrangements: distinguish between intermediary activities, own-account sales and additional consumer-facing fees.