Digital Price Tags and the Price Indication Ordinance (PBV)

Are electronic price tags even allowed in Switzerland?

Yes, without restriction. The Price Indication Ordinance (PBV, Switzerland's Preisbekanntgabeverordnung) regulates WHAT must be labeled — not WHAT MEDIUM it must be labeled on. Paper, a chalkboard, a printed sticker, or an e-paper display are legally equivalent display media. The ordinance contains no clause prescribing or excluding any particular display medium. It was written to be technology-neutral, because although the legislator was thinking of paper labels at the time it was drafted, the underlying principle was kept general enough to cover later technologies too. What matters is solely the outcome: the price must be clearly recognizable to consumers, unambiguously attributable to the product, and readable without special effort. A crisp, well-sized e-paper label mounted directly on the shelf or product generally meets this requirement better than a handwritten card whose ink fades over time or whose handwriting becomes barely legible after a hasty price change. Businesses hesitant because they suspect a grey area can therefore relax: there is no grey area here, just a clear, medium-independent requirement.

What the PBV specifically requires of every price tag

The core requirement of the PBV is the obligation to state to consumers the price actually payable — in Swiss francs, including VAT and all non-optional surcharges. The amount shown must ultimately match exactly what is charged at the till; a separately added service surcharge or a hidden fee that only becomes visible at checkout would be problematic — regardless of the display medium. In addition, the attribution must be unambiguous: a price sitting somewhere on the shelf without making clear which product it belongs to is not sufficient. Where a row of similar items sits side by side — several types of cheese or wine bottles at different prices, for example — customers must be able to tell without asking which price belongs to which product. For digital labels, that means in concrete terms: correct placement directly next to the item, the correct amount, adequate font size and contrast for normal reading distance, and no ambiguity where products sit closely together.

Why the technology itself isn't a separate issue

With new technologies, the question regularly comes up of whether an authority must "approve it first" before it can be used. That is not the case with electronic price tags: this is not a procedure requiring approval, but simply a different display medium for the same, already-existing disclosure obligation. Electronic shelf labels (ESL) have been used productively in European and international retail for many years without the underlying price-labeling obligations changing in any way. Switzerland is no exception here, and there is no precedent in which the mere use of electronic labels as such has been objected to. What gets flagged — just as with paper — are exclusively content defects: wrong price, missing attribution, poor legibility.

The often-overlooked compliance advantage of digital labeling

In practice, most objections raised during price checks arise not from bad intent but from simple inconsistency: the till price was changed but the shelf label was forgotten — whether because the change got lost in the rush, the label printer wasn't at hand, or one item among many was simply overlooked during a promotion affecting a large number of products. With paper, this is a common, purely organizational risk — especially for assortments with many items or frequent price adjustments, such as seasonal products or short-term promotions. Electronic price tags maintained centrally from a single system eliminate exactly this source of error structurally: when the price changes in the system, it changes on the shelf at the same time and automatically, with no additional manual action required. The gap between till price and shelf price that a check typically flags therefore cannot arise in the first place, for purely technical reasons — not because an employee works more carefully, but because the source of error itself disappears.

Hospitality: what additionally applies

For restaurants and cafés, the same logic as in retail applies in principle: price lists posted inside or provided at the table must show the price actually payable including VAT, regardless of the medium. An important clarification many businesses aren't aware of: posting the menu outside the premises, clearly visible from the street, has no longer been a mandatory requirement since a change of practice in 2022 — it is a voluntary measure to attract guests. The actual obligation concerns the correct price list visible inside, at the table or the counter — and this is precisely where a digital table display is especially well suited, because price changes are applied correctly and immediately, for example when a lunch menu with its own price is automatically replaced by the regular evening menu in the evening, or when a daily special sells out and should no longer be mistakenly offered.

Who enforces the PBV, and what happens during an inspection

Many businesses imagine SECO inspectors making spot visits to stores and measuring labels. That is not accurate. Under Art. 22 PBV, responsibility for monitoring correct price disclosure day to day lies with the cantons: they oversee compliance on the ground and report violations found. The federal government itself does not act as the enforcement authority; under Art. 23 PBV, its supervisory role is delegated to the State Secretariat for Economic Affairs (SECO), which sits above the cantonal enforcement bodies as a coordinating and advisory body, but does not itself carry out comprehensive checks. Anyone who pictures an inspection as a federal official at the shop entrance is mistaken — it is cantonal authorities who act in the specific case. Violations of the PBV are not a trivial matter: under Art. 21 PBV in conjunction with Art. 24 of the Federal Act against Unfair Competition (UWG), intentional violations can incur fines of up to CHF 20,000. Negligent violations — an error that happens without intent, such as an overlooked label — are also punishable, though in practice judged more leniently than intentional conduct. What an on-site inspection substantively checks aligns with what has already been discussed several times in this article: does the labeled price match the price actually charged at the till, and is the attribution to the product unambiguous? These are precisely the two points that a centrally synchronized digital system structurally safeguards before an inspection even takes place — not because the system circumvents the inspection, but because the most common source of error an inspection typically uncovers doesn't arise in the first place. Anyone unsure, when introducing digital price tags, whether a layout or process meets the requirements is best advised to consult the SECO FAQ on price disclosure — the body responsible for the technical interpretation of the PBV, even though the actual on-site inspection remains a matter for the respective canton.

Reduced prices and promotions: what Art. 16 and 17 PBV require

Promotions and discounts are an area the PBV scrutinizes particularly closely, because the temptation to set a generous comparison price is great. Art. 16 PBV permits three types of comparison prices that may be used to advertise a price reduction: the self-comparison, where the business's own, actually previously charged price serves as the reference; the introductory price, where a lower introductory price is compared with the business's own regular price valid later; and the competitor comparison, referring to what competitors charge for the same product. The classic trap with the competitor comparison is what is commonly called a "phantom price": the reference price must be an actual market price that the vast majority of competitors genuinely charge for the identical product — not an artificially inflated price that hardly anyone actually charges in practice and that serves solely to make one's own reduction look bigger. Such a fictitious reference price is a PBV violation, regardless of whether it is displayed on paper or digitally. Art. 17 PBV additionally requires that, in the case of a price reduction, it must be clearly recognizable which earlier price serves as the comparison basis and which specific product the reduction relates to — arbitrariness or vagueness in attribution is not permitted. There is, however, a practical simplification: where a uniform reduction applies simultaneously to many products or entire categories — "20% off the entire range," for instance — the obligation to state the comparison price separately for each individual product no longer applies. Importantly, these comparison-price rules apply not only in flyers and advertisements outside the point of sale, but equally to labeling directly on the shelf, at the table, or at the counter — exactly where a digital label displays the reduced price. The simplification described further above for digital source references in external advertising changes nothing here: at the point of sale itself, the promotion must be fully and immediately visible together with its reference price. This is directly relevant for Vitria customers: because e-paper labels are managed centrally, the start and end of a promotion, along with the correct "old price" as reference, can be scheduled and reset simultaneously for all affected labels. This addresses exactly the core of Art. 17 — reduction and reference price must be unambiguous — and avoids the classic paper mistake of simply forgetting to remove a promotional label after it expires, thereby unintentionally continuing to display a comparison price that is long since invalid.

Digital source references in advertising — a related but different rule

Some businesses hear about a "relaxation" of the PBV for digital references and wrongly conclude that the requirements for price tags themselves have also been loosened. In fact, the relevant change concerns something else: the Federal Council amended the PBV on 19 May 2021, effective 1 July 2021, based on the Lombardi motion "A more consumer-friendly Price Indication Ordinance." Since then, advertising materials — flyers, ads, catalogues — may reference a digital source for certain mandatory disclosures, namely product specifications, provided the reference is clearly legible or audible in the advertising material and the information at the source is immediately accessible, clearly visible, and easy to read. The price actually payable must still appear directly in the advertising material itself. Crucially for businesses with digital price tags: this simplification applies expressly only to advertising outside the point of sale. On the shelf, at the table, or at the counter itself — exactly where e-paper displays are used — the full, direct price-disclosure obligation remains unchanged.

What actually happens legally with an incorrectly labeled price

What actually applies if a price tag is wrong despite everything? The principle already briefly touched on in the FAQ deserves closer examination: what ultimately governs is the amount actually charged — this corresponds to the general principles of Swiss contract and consumer law, under which the price actually billed at the till is what counts. An incorrectly labeled shelf or table price tag is therefore primarily a PBV compliance issue for the business — with the corresponding risk of an objection or, in a repeated or serious case, a fine under Art. 21 PBV — and not automatically a criminal matter against individual customers. If such a discrepancy is discovered, the expected response is simple: correct it quickly. This is exactly where the practical difference between the two systems shows. A business that notices a discrepancy between till and shelf price immediately and fixes it in seconds, because the correction only requires a single central price change in the system, is in a fundamentally different risk position than a business relying on manual paper printouts that, in the worst case, only notices a label has been wrong for days at the next inventory count or a customer complaint. So it isn't error-free operation that matters — errors happen in every system — but how quickly a business can identify and fix them. This aligns with the enforcement logic described above: a single, quickly corrected error is weighed differently in a potential objection than a discrepancy that persists despite being known for a longer period — the latter edges toward intentional violation, for which the PBV provides for higher fines. For a business with many items and frequent price changes, this speed of response is therefore not a detail but the actual lever for keeping compliance risk low.

What businesses should practically consider when introducing this

Even though the technology itself is unproblematic, a brief internal check when introducing it is worthwhile to be properly set up from the start. Is the font size readable at normal reading distance on every display format used, or was a layout chosen that crams too much text into too little space? Is the displayed price kept automatically in sync with the till system, or is it maintained manually and therefore potentially delayed and error-prone? And during promotions, is it clear which of the two prices — regular or reduced — is actually payable, or could there be a risk of confusion? A good software solution for digital displays should already check such questions automatically during the design process and warn when needed, rather than leaving it entirely up to the business. Anyone who sets these points up properly once has no additional ongoing compliance burden afterward — on the contrary, as shown above, generally less than before with paper.

Frequently asked questions

Must the price be displayed including VAT?

Yes. Vis-à-vis consumers, the final price actually payable in CHF including VAT must be stated — regardless of whether the labeling is on paper or digital.

Are e-paper price tags legally riskier than paper?

No, the opposite. Because prices are maintained centrally and update automatically on the shelf, the risk of discrepancies between shelf and till price — the most common cause of objections with manual paper labels — is reduced.

Do I need regulatory approval for digital price tags?

No. It is merely a different display medium for an existing labeling obligation, not a new procedure requiring approval.

Must a restaurant menu be posted outside?

No. An outside posting is no longer a legal requirement, but a voluntary measure to attract guests. What is required is the correct, clearly legible price list inside, at the table or the counter.

What happens if a digital label shows the wrong price?

The same principles apply as with an incorrect paper label: what ultimately governs is what is actually charged. Central, automatically synchronized maintenance significantly reduces this risk compared with manual labels.

Can I show just a QR code to a website instead of a price on the shelf?

No. The option introduced in 2021 to reference a digital source for mandatory disclosures applies only to advertising material outside the point of sale. On the shelf, at the table, or at the counter, the price actually payable must still be shown directly and fully.

How high can fines be for a PBV violation?

For intentional violations of the PBV, Art. 21 PBV in conjunction with Art. 24 UWG provides for fines of up to CHF 20,000. Negligent violations are also punishable. The cantons are responsible for on-site enforcement (Art. 22 PBV), while the federal government exercises its oversight via SECO (Art. 23 PBV).

Can I use an artificially high 'original price' as a comparison price for a promotion?

No. Under Art. 16 PBV, a comparison price for a competitor comparison must be an actual market price that competitors genuinely and predominantly charge. An artificially inflated reference price used only to make your own reduction look bigger is a PBV violation — regardless of the display medium.

Sources

• SECO — FAQ on Price Disclosure ↗
• Fedlex — SR 942.211 Price Indication Ordinance (PBV) ↗
• ZHAW — Mandatory disclosures in advertising to be simplified (SECO press release, 19 May 2021) ↗