1. Which Products Does the Black Friday Banner Cover?
A banner showing several products beside one discount can suggest that the offer covers the pictured range. For a campaign directed to consumers in California, check whether the headline, images, and eligible options describe the same offer.
Identify the Product Behind Each Price
Business and Professions Code (BPC) § 17507 addresses advertisements covering multiple articles within the same class of merchandise. A stated price must clearly and conspicuously identify the article to which it relates.
Check the eligible model, size, quantity, and accessories. A price beside a premium product may mislead if only the basic version qualifies. Under § 17507, an asterisk and corresponding footnote do not satisfy this identification requirement when the particular article is not pictured. A picture alone does not establish that the disclosure is sufficient.
Check the Overall Message
BPC § 17500 prohibits untrue or misleading advertising statements that the advertiser knows, or through reasonable care should know, are untrue or misleading. A correct calculation does not resolve a misleading presentation.
Review “up to,” “starting at,” and “selected styles” against the surrounding images and text. These qualifiers may not adequately explain that pictured options receive different discounts. The broader false advertising law framework addresses misleading impressions, while this campaign review focuses on the specific savings customers would expect.
2. Match the Comparison Price to the Bundle
Identify whether the claimed savings compare the bundle’s former price with its sale price or compare buying components separately with buying them together. These are different claims requiring different support.
Distinguish Former Prices from Component Totals
Under BPC § 17501, an advertised former price must have been the prevailing market price in the relevant locality within the three months before publication. Otherwise, the advertisement must clearly, exactly, and conspicuously state when that former price prevailed. An internal list price does not necessarily establish the required benchmark.
Adding component prices does not establish a new bundle’s former price. If the comparison concerns buying separately, say so and verify the component prices and separate-purchase availability.
Use the following distinctions when reviewing the pricing records.
| Discount Claim | Supporting Materials | Mismatch to Check |
|---|---|---|
| Former bundle price | Price history and relevant market evidence | Reference price concerns another configuration |
| Savings versus buying separately | Component prices and availability | Calculation includes items absent from the bundle |
| Percentage off selected options | Option-level reference and sale prices | Highest discount appears to cover the range |
Former bundle price
- Supporting MaterialsPrice history and relevant market evidence
- Mismatch to CheckReference price concerns another configuration
Savings versus buying separately
- Supporting MaterialsComponent prices and availability
- Mismatch to CheckCalculation includes items absent from the bundle
Percentage off selected options
- Supporting MaterialsOption-level reference and sale prices
- Mismatch to CheckHighest discount appears to cover the range
Recalculate When Options Change
Use matching quantities and configurations for a former-price comparison. Do not present a two-pack sale price against a three-pack reference price as though the same package has been reduced.
Calculate percentage savings by dividing the price reduction by the supported reference price. Recheck when size, capacity, accessories, or quantity changes. Civil Code § 1770(a)(13) separately prohibits misleading factual statements about the reasons for, existence of, or amounts of price reductions in covered consumer transactions.
3. Show Conditions That Change the Advertised Deal
Coupons, minimum quantities, and additional purchases can change what customers must buy to receive the discount. Review these conditions in the advertisement and through the purchase path.
Separate Optional Items from Required Purchases
An optional accessory differs from a required companion purchase. Subject to statutory exceptions, BPC § 17509(a) requires advertisements conditioned on purchasing a different product or service to conspicuously disclose the prices of the required products or services.
Check whether customers can obtain the advertised deal without buying another item or paid service. Do not present a component’s discounted price as the complete offer when another purchase is required.
Review Restrictions on Mobile Screens
Place material qualifications where customers encounter the claim. Check that coupon requirements, excluded options, and minimum spending conditions remain readable. A linked disclosure may not adequately explain a limitation that changes the headline’s meaning.
FTC Act § 5 supplies a separate federal prohibition against unfair or deceptive practices. Broader advertising and marketing law review includes the overall impression and disclosure placement. Inspect cropped images, collapsed text, and the default option customers see after clicking.
4. Keep Records of the Offer Approved for Launch
The approval file should connect the published claim with its pricing basis and purchase conditions. Keeping these records supports review but does not establish compliance by itself.
Preserve the Published Version and Supporting Evidence
Retain dated copies of the final banner and product page alongside:
- Eligible SKUs, quantities, and bundle contents.
- Reference-price evidence and applicable dates.
- Component prices supporting separate-purchase comparisons.
- Coupon restrictions and campaign dates.
- Calculations and approval records.
Compare published materials with approved drafts. Automated pricing or product substitutions can change the offer after approval.
Test Purchases before Releasing the Claim
Test the advertised configurations to check availability, coupon operation, and displayed savings. Resolve discrepancies before releasing the affected claim.
An advertising compliance review can assess unresolved wording or evidence issues. Narrow the claim when the records support only a limited offer. Review affected advertising again if bundle contents, reference prices, or eligibility conditions change during the sale.
02 Nov, 2026
