Recommended Retail Price (RRP): What Businesses Must Comply With

If you sell products in Australia, you’ve probably seen “RRP” on packaging, in supplier catalogues, or across competitor ads. It’s a common pricing reference in retail - but it also sits in a sensitive legal area under the Australian Consumer Law and Australia’s competition rules.

In this guide, we’ll explain what RRP actually means, when and how you can refer to it in your marketing, and the guardrails you need to follow to stay on the right side of consumer and competition law. We’ll also cover practical steps to set up your internal processes and contracts so your pricing claims are accurate and defensible.

Let’s unpack RRP with plain-English answers to the questions business owners ask us most often - and help you price with confidence.

What Does RRP Mean In Australia?

RRP stands for Recommended Retail Price. You may also see “Suggested Retail Price” (SRP), but RRP is the common shorthand in Australia.

What RRP Is (And Isn’t)

• It’s a recommendation from the supplier or manufacturer about the price a retailer might charge to consumers.
• It’s not a fixed or mandatory price for retailers.
• It’s commonly used to give the market a benchmark and to help consumers understand the relative value of a deal.

As a retailer, you can set your own price - below, at, or above the RRP - unless another law applies (for example, a regulated industry price). The key is how you use RRP in advertising or negotiations, which is where consumer and competition laws come in.

Where You’ll See RRP

• On product packaging or supplier brochures for new or seasonal products.
• In media or online ads as a comparison point (e.g. “$79 - RRP $99”).
• In wholesale pricing sheets to guide retailers on positioning.

Used properly, RRP can help you position your offer and communicate value. Used carelessly, it can mislead customers - and invite enforcement action.

The Legal Framework: ACL And Competition Law

Two sets of laws are relevant to RRP in Australia:

• The Australian Consumer Law (ACL), which covers misleading and deceptive conduct and false or misleading price representations to consumers.
• The competition provisions of the Competition and Consumer Act 2010 (CCA), which include specific prohibitions around supplier behaviour known as resale price maintenance (RPM).

Consumer Law: Avoid Misleading Price Claims

Under the ACL, you must not mislead or deceive consumers in your marketing (the general rule in section 18), and you must not make false or misleading representations about price or discounts (more specific prohibitions in section 29).

What does this mean for RRP?

• Comparisons must be accurate. If you say “$59 - RRP $79”, the RRP should be genuine and current (for example, the supplier’s published recommendation that remains in effect). If market practice has shifted and almost nobody treats that old figure as the current reference, quoting it may be misleading.
• “Was/Now” pricing needs a real “was”. If you strike through a higher “was” price, that higher price must have been your genuine selling price for a reasonable recent period - not a token price used only to make a discount look bigger. This is a separate two-price comparison issue often seen alongside RRP claims.
• Fine print can’t fix a misleading headline. Clear, accurate headline pricing is essential. Qualifications should clarify, not contradict, the overall message.

The ACCC publishes guidance and takes enforcement action where necessary, but there isn’t a special “RRP rulebook.” The test is whether your representation is likely to mislead the ordinary consumer in context - and the ACL applies whether you operate online or in-store. For an overview of typical pitfalls around comparative and “was/now” offers, see common advertised price laws in Australia.

Competition Law: Resale Price Maintenance (Not “Price Fixing”)

On the competition side, the key concept is resale price maintenance (RPM). RPM occurs when a supplier tries to control the price at which an independent retailer resells the supplier’s goods, such as:

• Requiring a retailer not to sell below a specified price (including the RRP).
• Withholding supply, threatening penalties, or offering incentives to make the retailer stick to a minimum price.
• Setting a minimum advertised price that, in substance, prevents discounting.

RPM is generally prohibited in Australia. A supplier may recommend a price and may, in some circumstances, specify a maximum price, but it cannot impose a minimum resale price or penalise discounting.

There is a limited “notification” process under the CCA where a supplier can notify the ACCC of proposed RPM and obtain protection if the public benefit outweighs the detriment - but this is uncommon in typical retail settings. Unless you’ve seen and relied on such an ACCC notification (and understand what it permits), treat supplier pressure to enforce minimum resale prices as a red flag.

Using RRP In Advertising: What’s Allowed?

RRP comparisons can be useful to consumers - if they are truthful, current and presented fairly. Here’s how to approach them safely.

Make Sure The RRP You Quote Is Current And Real

• Use the supplier’s current, published RRP (not an outdated figure).
• If the supplier has publicly changed the RRP (e.g. a permanent price drop), update your advertising promptly.
• Where a product is widely discounted in the market over a sustained period, consider whether RRP is still meaningful context for your customers. Even if a supplier hasn’t changed the RRP on paper, a “phantom” reference to a price the market no longer treats as a benchmark can mislead.

Use Two-Price Comparisons Correctly

• “Was/Now”: ensure the “was” price was your genuine price for a reasonable time. Don’t create an artificial “was” price by briefly listing a high figure no one paid.
• “Save $X” or “Y% off”: calculate savings off a real baseline (your own prior price or a current, genuine RRP) and ensure you can substantiate the math.
• Avoid vague qualifiers. If there are limitations (e.g. “selected colours only”), state them clearly and prominently.

Present The Whole Story Clearly

• Display the actual price payable (including any mandatory fees) clearly and upfront.
• Make fine print genuinely legible and consistent with the headline.
• Ensure product pages, catalogues and shelf labels match - inconsistencies create risk.

The overarching principle is simple: would a typical customer likely be misled by your pricing message? If the answer could be “yes”, change the claim before it reaches the market.

Supplier Relationships And RPM: Can You Be Forced To Sell At RRP?

Short answer: no - not in the usual course of retailing. A supplier can recommend, but cannot require, a minimum resale price.

What Suppliers Can And Can’t Do

• Recommend a retail price (RRP): lawful.
• Set a maximum resale price: generally lawful, provided it does not have anti-competitive effects in context.
• Induce a minimum resale price (including “don’t discount below RRP”): generally unlawful RPM, unless protected by an ACCC notification (rare in typical retail).
• Threaten to cut off supply or impose penalties if you discount: strong indicator of RPM risk.

If you’re a retailer, protect your independence to set prices in your supply contracts. If you’re a supplier, ensure your team understands what constitutes unlawful RPM and how to communicate RRPs without crossing the line.

Practical Tips For Navigating RRP With Suppliers

• Keep written records of any price-related communications.
• Push back politely on any request to “hold price” or “not discount” - and offer to discuss alternative promotional support that doesn’t control retail price.
• Ensure your agreements clarify that you retain discretion over retail pricing (for example, alongside commercial terms in a Distribution Agreement).

If you suspect RPM, seeking early guidance can help you reset the relationship before issues escalate.

Practical Compliance Steps For Retailers

Good systems make compliant pricing easier. These steps help you build a reliable process around RRP and comparative pricing.

1) Create A Simple Pricing & Promotions Policy

• Set out who approves promotions and what substantiation is needed.
• Require documented evidence for every “was/now”, “save” or “RRP” comparison.
• Include a quick checklist for marketing and store teams to follow.

2) Keep Robust Records

• Store supplier RRP notices and any updates.
• Record your actual prices over time (dates and channels) so you can substantiate “was” claims.
• Capture screenshots of website offers and catalogue proofs.

3) Train Your Team

• Run short refreshers before major promotions (Black Friday, EOFY, etc.).
• Explain the difference between genuine savings and headline “hype” that could mislead.
• Empower staff to raise concerns if a claim doesn’t feel right.

4) Review Copy And Disclaimers Before Go-Live

• Ensure website and catalogue price references are consistent and supported by your evidence file.
• Use clear, consumer-friendly disclaimers where needed. A general legal notice can sit in your Website Terms and Conditions, but don’t rely on fine print to save a misleading headline.
• If you sell online, make sure your Privacy Policy and checkout disclosures align with promotional claims (e.g. timing, availability, shipping costs).

5) Refresh RRPs Regularly

• Schedule a periodic sweep to replace old RRPs across your product pages and signage.
• When a supplier updates the RRP, update comparison ads at the same time.

6) Put The Right Documents In Place

• Website Terms and Conditions: set the rules for online purchases and help manage expectations about pricing, availability and errors.
• Disclaimer: clarify general information on your site and reduce the risk of customers relying on broad, non-personalised claims.
• Warranties Against Defects Policy: explain what your business promises if things go wrong, alongside ACL rights.
• Distribution Agreement (if you’re a supplier or distributor): include clear clauses about recommended pricing and retailer independence to avoid RPM risk.

For content-heavy sites, a pre-publication check by a lawyer or a structured advertising law review can be a smart safety net before big campaigns.

Common Pitfalls And Quick Answers

Typical RRP Mistakes To Avoid

• Using an outdated RRP to make a discount seem bigger.
• Quoting “was” prices you never genuinely charged for a reasonable period.
• Relying on tiny fine print to walk back a bold headline claim.
• Agreeing (even informally) not to discount below RRP to keep a supplier happy.
• Letting web pages, email campaigns and in-store signage drift out of sync.

Do I Have To Sell At The RRP?

No. RRP is a recommendation only. You set your own retail price (subject to any industry-specific rules). A supplier cannot force a minimum price without risking RPM.

Can I Say “Was RRP $X, Now $Y”?

Only if the RRP you quote is current and genuine, and your presentation won’t mislead the average customer. Be careful: if most retailers treat a lower figure as the current point of reference, leaning on a higher, stale RRP may be misleading.

How Long Must I Have Charged The “Was” Price?

There’s no fixed number of days in the law, but the higher “was” price should be your genuine, prevailing price for a reasonable recent period given the product and market. A short, token listing at a higher figure to create an artificial discount is likely to mislead under the ACL.

Can A Supplier Run A Minimum Advertised Price (MAP) Policy?

A MAP policy that in substance prevents discounting or penalises retailers for advertising lower prices can amount to RPM. Simply calling it “advertised” price doesn’t avoid the prohibition if the effect is to set a minimum resale price.

Will A Disclaimer Fix A Risky Headline?

No. Disclaimers support clarity; they don’t cure a misleading headline. Keep your headline truthful, then use clear qualifiers only where necessary.

Should I Link To RRP In My Legal Pages?

Your customer-facing legal pages should support transparency, not enforce pricing. Place your ordering and pricing rules in your Website Terms and Conditions and ensure any general site statements are covered by a suitable Disclaimer. For the marketing team, keep a short internal policy on using RRPs and two-price comparisons.

Key Takeaways

• RRP is a supplier’s recommendation - not a mandatory price - and retailers remain free to set their own prices.
• Under the ACL, any RRP or two-price claim must be accurate, current and presented so it won’t mislead the average consumer.
• Supplier pressure to prevent discounting can cross into resale price maintenance, which is generally prohibited under competition law.
• Build a simple pricing approval process, keep records to substantiate savings claims, and refresh RRPs across your channels regularly.
• Support transparency with clear site documents such as Website Terms and Conditions, a Disclaimer and a clear Privacy Policy, and keep supplier contracts free of any minimum resale price requirements.
• If you’re unsure whether a promotion or supplier term is compliant, get advice early - it’s far easier to fix before launch than after a complaint.

If you would like a consultation on your pricing practices or the legal documents that support them, you can reach us at 1800 730 617 or team@sprintlaw.com.au for a free, no-obligations chat.