Spotlight on Pricing: Hungarian Competition Authority's Action Against Notino

With the recent EU-wide overhaul of consumer protection laws, Hungary introduced stricter regulations on unfair commercial practices on May 28, 2022. This update followed an extensive preparation period starting in December 2020, with the Hungarian Competition Authority (HCA) offering guidance to help businesses adapt.

Shortly after the new rules took effect, the HCA quickly assessed online retail practices, initially focusing on the clothing sector, where many retailers needed to adjust to ensure compliance. Following its initial findings, the HCA issued valuable recommendations, launched investigations, and already closed its first case, accepting undertakings from CCC without concluding an infringement. In this respect, please see our post here.

However, HCA’s oversight extends beyond clothing retailers. The agency recently directed attention to the cosmetics retailer Notino s.r.o., suspecting that the company may be misleading consumers with certain price displays and promotions on its website and mobile app. The investigation suggests that Notino may be employing dark patterns—manipulative design tactics that influence consumer decisions—such as pre-selected options for shipment upgrades and environmentally friendly packaging. The investigation is ongoing.

With Black Friday approaching, companies should be especially vigilant with their discount strategies and promotional practices to avoid misleading consumers and ensure compliance with these stricter regulations.