Alex is Sprintlaw’s co-founder and principal lawyer. Alex previously worked at a top-tier firm as a lawyer specialising in technology and media contracts, and founded a digital agency which he sold in 2015.
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If you’ve shopped online, run a retail store, or compared catalogues in Australia, you’ve probably seen “RRP” or “X% off RRP”. It’s a powerful signal for consumers - but it also comes with strict legal rules for businesses.
In this guide, we’ll unpack what “Recommended Retail Price” means in Australia, how “off RRP” promotions work, and the legal pitfalls to avoid under the Australian Consumer Law (ACL). We’ll also share practical steps to keep your pricing, advertising and website compliant from day one.
Whether you’re launching a new brand, managing a shopfront, or running an online store, getting RRP right helps build trust with customers - and reduces your legal risk.
What Does RRP Mean In Australia?
RRP stands for Recommended Retail Price. It’s a price a supplier or manufacturer suggests a retailer might sell a product for. It’s not mandatory, and it’s not enforceable on retailers.
How RRP Works
- Suppliers suggest, retailers decide: A supplier sets an RRP as a guide to the market. Retailers can sell at, above or below that price based on their strategy, costs and local competition.
- Why display RRP: It can help communicate value, create consistency across channels, and support promotions (for example, “20% off RRP”).
- GST context: In consumer-facing advertising, prices are generally presented inclusive of GST. If you’re unsure about your GST obligations or display practices, get tax advice to ensure your pricing is clear and compliant.
Important Legal Clarifications
- No resale price maintenance: In Australia, suppliers cannot force independent retailers to sell at the RRP. Imposing a minimum resale price (resale price maintenance) is prohibited unless formally authorised by the ACCC in very limited circumstances.
- RRP in ads must be truthful: If you reference an RRP in your marketing, your claims must not mislead consumers under the ACL.
How Do Businesses Use RRP In Practice?
RRP shows up in a few common ways across Australian retail and eCommerce.
“X% Off RRP” Promotions
A typical campaign might say “Save 30% off RRP” or show a strike-through like “RRP $149 - Now $99”. The idea is simple: the customer sees the recommended price and the savings clearly.
To stay on the right side of the law, ensure your comparison is genuine, current and easy to understand. This includes clear, upfront total pricing for online customers. For more on pricing presentation, also think about your Website Terms & Conditions and how you use strike-throughs, discount codes and delivery charges.
RRP As A Benchmark Across Channels
Brands selling through multiple retailers and marketplaces often use an RRP to create consistency. If you advertise an RRP on product pages or marketing assets, keep it accurate and review it regularly - otherwise it can quickly become misleading if the market moves.
“Was/Now” vs “Off RRP”
“Was/Now” pricing compares your own prior selling price (for example, “Was $129, now $89”). “Off RRP” compares against the supplier’s recommended price. The legal tests differ, but the principle is the same: your comparison must reflect a real, recent and meaningful reference point. If in doubt, choose the comparison you can substantiate with records.
What Laws Apply To RRP And “Off RRP” Advertising?
Australian pricing and advertising laws apply regardless of your size or sales channel. The main rules come from the Australian Consumer Law (ACL).
Misleading Or Deceptive Conduct
Your pricing statements - including “off RRP”, strike-throughs and savings claims - must not mislead or deceive. This core rule sits in section 18 of the ACL. If a comparison creates a false overall impression (even if individual words are technically true), it can still breach the law. Learn more about the legal test for misleading or deceptive conduct.
False Or Misleading Representations About Price
The ACL also prohibits specific misrepresentations, including about the price or the savings consumers will receive. If you use an RRP in an ad, the RRP should be a genuine, current reference price, not a figure that no one actually charges. See how section 29 operates for price-related claims in our guide to price representations under the ACL.
Advertised Price Rules
Display prices must be clear, prominent and not create confusion. Watch out for drip pricing (adding unavoidable fees later in the checkout), ambiguous “from” pricing, and complex promotions that hide real costs. Our overview of advertised price laws in Australia explains common traps to avoid.
How The Law Is Enforced
The ACCC can investigate and take enforcement action. It can issue substantiation or infringement notices, accept court-enforceable undertakings, and commence court proceedings. Civil penalties and other orders (for example, corrective advertising) are imposed by the courts, not by the ACCC directly.
Online Stores And Terms
If you sell online, make sure your pricing and promotions align with your customer-facing terms. Clear Terms of Sale and robust Website Terms & Conditions help set expectations about pricing, discounts, delivery charges and returns. If you collect personal information for promotions or loyalty programs, you’ll also need a compliant Privacy Policy.
Common Risks And How To Stay Compliant
Most issues arise when a price comparison doesn’t reflect reality. Here are common risks and practical ways to manage them.
Risk 1: Inflated Or Out‑Of‑Date RRP
If an RRP is higher than the real market price, “off RRP” savings may be misleading. This can happen where the RRP was set years ago or never used by retailers.
- What to do: Use RRPs that reflect a genuine, current market recommendation. Review RRPs periodically and retire old assets when prices change.
- Keep records: Maintain evidence showing how and when the RRP was set and updated. Document retailer uptake where possible.
Risk 2: Confusing “Was/Now” And “Off RRP” Claims
Consumers need to know exactly what you’re comparing. A muddled message can mislead even if each element is technically correct.
- What to do: Use plain language and consistent formatting. If you’re comparing to your prior price, say “Was/Now”. If you’re comparing to RRP, say “Off RRP”. Don’t mix the two in one claim.
Risk 3: Drip Pricing And Hidden Fees
Showing a discounted price but adding unavoidable fees late in checkout can be misleading.
- What to do: Present the minimum total price clearly and early (including mandatory fees). If shipping varies, be upfront about how it’s calculated.
Risk 4: “Up To” Savings That Most Customers Don’t Get
“Save up to 60% off RRP” can be misleading if only a tiny fraction of items achieve that saving.
- What to do: Ensure the claim reflects a typical consumer outcome. If it’s a limited subset, clarify the scope (“Selected styles only”). Keep substantiation to back it up.
Risk 5: Poor Internal Controls
Inconsistent pricing across channels and outdated creative can creep in when teams move fast.
- What to do: Create an internal approvals process for price claims. Train staff on ACL basics, schedule regular audits of banners and product pages, and systematise takedowns at the end of a promotion.
Risk 6: Under‑Explaining Conditions
If conditions apply (for example, discount codes, minimum spends, exclusions), burying them can mislead.
- What to do: State key conditions prominently next to the headline claim. Put the rest in accessible terms linked from the promo, consistent with your consumer law obligations.
Quick Compliance Checklist
- Use current, genuine RRPs and review them regularly.
- Match your comparison type to the truth (“Was/Now” vs “Off RRP”).
- Show clear total pricing early (avoid drip pricing).
- Prominently disclose material conditions.
- Keep evidence to substantiate all price claims.
- Align marketing with your online terms, refunds and warranty processes.
Note: Pricing in consumer ads in Australia should generally be shown inclusive of GST. For tax-specific questions (for example, GST registration or inclusive/exclusive displays in B2B contexts), speak with your accountant - this article focuses on legal compliance under the ACL.
What Legal Documents And Policies Should You Have?
Your pricing strategy should sit alongside clear customer terms and internal policies. The right documents help you manage risk and present offers consistently.
- Terms of Sale: Set out pricing, payment, delivery, discounts, returns and risk allocation with customers. These terms should align with any RRP or savings claims you make in marketing. See Terms of Sale.
- Website Terms & Conditions: Rules for website use, disclaimers and how promotions are presented online. Useful for explaining price displays and “offer” mechanics. Explore Website Terms & Conditions.
- Privacy Policy: Required if you collect personal information for sales, promotions or loyalty. It explains what you collect and how you use it. See our Privacy Policy service.
- Marketing & Promotions Playbook: An internal policy for teams covering ACL rules, required disclaimers, and sign-off workflows before promotions go live.
- Supplier or Distribution Agreements: If you’re a supplier setting an RRP for stockists, include how RRPs will be communicated (not enforced) and how marketing assets are updated over time.
- Refunds & Warranty Processes: Align your operations with your customer rights under the ACL so that your price promises and after‑sales processes are consistent.
Getting these documents tailored to your products, channels and risk profile will make it much easier to run promotions confidently and respond quickly if something needs correcting.
Key Takeaways
- RRP is a recommended price from a supplier - retailers are free to set their own prices and suppliers generally cannot require retailers to sell at RRP.
- “Off RRP” claims are legal only if the RRP is genuine, current and a real reference point for consumers; avoid inflated or outdated RRPs.
- All pricing claims must comply with the ACL, including rules against misleading or deceptive conduct and false price representations. Review your approach against section 18 ACL and section 29 requirements.
- Make total pricing clear, avoid drip pricing, disclose material conditions prominently, and keep records to substantiate every savings claim.
- Support your marketing with strong customer terms and website policies - for example, Terms of Sale, Website Terms & Conditions and a Privacy Policy.
- Enforcement can include ACCC investigations, infringement notices and court action; penalties are ultimately imposed by the courts.
If you’d like a consultation on using RRP in your pricing and promotions or making sure your online store is ACL‑compliant, you can reach us at 1800 730 617 or team@sprintlaw.com.au for a free, no‑obligations chat.
